Tax | Cross Border

A significant amount of business in the UK is generated from outside the UK and many non‑UK investors are unfamiliar with the intricacies and complexities of the UK tax system.


We help non‑UK investors understand the issues and advise on appropriate structures, often working with their non‑UK advisers.

Conversely, many UK individuals and entities are seeking to expand their businesses and investments into territories outside the UK.  It is crucial to understand the implications of the relevant structures from a UK, as well as the relevant local, tax perspective.

In particular, it is important for non‑UK persons and entities to know whether they are establishing a tax presence in the UK, and, if so, the consequences.  Conversely, for UK persons seeking to expand their business activities or invest outside the UK, they will need to understand whether they are establishing a tax presence in the non‑UK territory.


Our expertise

We work with colleagues in other teams, particularly Corporate, Commercial and Real Estate, in advising on and establishing appropriate structures and, in particular, advise on:

  • the application of double taxation agreements
  • employment and payroll tax issues relating to employees seconded to the UK
  • withholding tax issues, particular in respect of interest and royalty payments
  • the VAT aspects, both B2C and B2B, of goods and services supplied into the UK as well as from the UK


Our experience

We have advised on the following:

  • the application of the overseas Workday Relief Rules for employees seconded to the UK
  • applications or double taxation relief to exempt withholding tax on interest payments to a non‑UK resident lender
  • the application of the rules charging capital gains tax on non‑residents, including non‑resident capital gains tax and ATED-related capital gains tax on disposals of UK residential property



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