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Tax issues on setting up overseas

Tax issues on setting up overseas. Mike Hodges Tax Partner m ike.hodges @saffery.com 0161 200 8385. Forms of doing business. Representative office Permanent establishment Subsidiary Joint venture. Representative office ‘Dipping your toe in the water’. Limited activities

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Tax issues on setting up overseas

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  1. Tax issues on setting up overseas Mike Hodges Tax Partner mike.hodges@saffery.com 0161 200 8385

  2. Forms of doing business • Representative office • Permanent establishment • Subsidiary • Joint venture

  3. Representative office‘Dipping your toe in the water’ • Limited activities • No local filing requirements • Fees may be subject to withholding tax • UK tax on profits (with credit for withholding tax) • Payroll tax requirements

  4. Withholding tax on fees (1)

  5. Withholding tax on fees (2)

  6. Permanent establishment‘Going for a paddle’ • Fixed place of business or dependent agent • Overseas tax on profits • Unlikely to be withholding tax on fees • Overseas filing requirements • UK tax on profits (with credit for overseas tax) • Subject to election for companies • Likely to be UK and overseas tax on disposal

  7. Subsidiary‘Taking the plunge’ • Overseas tax on profits • Unlikely to be withholding tax on fees • Overseas filing requirements • No UK tax on distribution of profits to company • Unlikely to be tax on disposal by company • Incentivisation of local employees

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