Aberdeen – Stavanger Gateway 3 June 2014 International Tax Issues Kevin R Mann

1. Aberdeen – Stavanger Gateway 3 June 2014 International Tax Issues Kevin R Mann

2. Overall Tax Objectives – International Projects Overall Objectives “Proactive and Commercial” Understand project Review/amend onerous contract terms Understand & minimise overseas tax exposures Factor additional tax/compliance costs in bid price Minimise risk of overseas tax compliance failure “AAB are providing us with advice regarding our overseas employee assignments to Norway. In addition to providing us with guidance from a company perspective, AAB prepared summaries targeted at the employee’s perspective and these were particularly useful in effectively managing our communication of these sometimes delicate issues with our employees affected. We are confident that AAB will keep us on track in relation to our compliance obligations in Norway and are very pleased with the comprehensive and efficient service provided by the AAB team.” Alan Cormack Nautronix

3. Corporate Tax Considerations Carrying on Business in overseas country through permanent establishment (PE)? Influence of UK / Norway Double Tax Treaty (DTT) Onshore (Art 5) – Various definitions of PE Offshore (OA’s) (Art 21) – Deemed PE if OA’s > 30 days in any 12-mth period Rates of Corporation Tax on profits of PE? UK – 21% (20% from 1 April 2015) Norway – 27% Double Tax Relief in Home Country? UK – Restricted to 21% (20% from 1 April 2015) – 6% (7%) incremental tax cost Norway – Likely full credit obtained Subsidiary v Branch / PE in overseas country? Tax rates as above Repatriation of post-tax profits? Other Indirect Taxes? VAT? PAYE / Wage tax? Customs duties? Overseas professional fees?

4. Employment Tax Considerations Income Tax Payablein Overseas Country? Influence of UK / Norway DTT Onshore (Art 14) – Conditions for exemption Offshore (OA’s) (Art 21) – All remuneration liable to tax PAYE / Wage Tax Obligations of Employer? • Double Wage Tax deductions (UK and Norway)? • Need to be managed • UK – Net of Tax Credit arrangement • Norway – Double Tax Credit Relief "As a company we routinely are called to tender for projects in what are ‘frontier’ regions for us often with complex tax regimes and testing legislation relating to international suppliers. Thorough, up to date and concise advice underpin our commercial proposals, and in these respects AAB have never failed to deliver, even at very short notice” Gary Thirkettle Calecore Limited National Insurance Liabilities? Rates of Income Tax Payable? Continuing liability in home country (A1 Certificate)? Both employee and employer contributions UK – 20%, 40%, 45% Norway – 27%, 36%, 39%

5. Contact Details International Tax Team – who’s who Kevin R Mann - Partner Telephone: 01224 625111 Email: kevin.mann@aab.co.uk