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International Tax

Specialist UK international tax advice for businesses
and individuals operating across borders

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International tax sits at the intersection of UK law, foreign law and the treaty network between them.

Decisions on group structure, financing, intellectual property, transfer pricing and the location of substance all carry tax consequences in multiple jurisdictions simultaneously. Getting the analysis right means understanding how the pieces fit together rather than looking at each in isolation – and that requires an adviser who can hold the whole picture and guide the decisions that shape it.

Our international tax team advises UK businesses with overseas operations, foreign businesses with UK operations and individuals with cross-border positions.

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How we deliver international tax advice

International tax engagements typically start with a structured review of the existing position.

The group’s footprint, the substance in each jurisdiction, the flow of profits and the treaty positions being claimed are all set out in a single document so the analysis can be done with the full picture in view.

From there, the advice is shaped to the client’s commercial direction. The partner stays close to the substantive technical work and brings in our specialists in transfer pricing, treaty analysis and the relevant areas of foreign law through our PrimeGlobal relationships.

Our international tax expertise

  • Cross-border group structuring and restructuring
  • Transfer pricing policy, documentation and dispute support
  • Permanent establishment analysis and management
  • Treaty analysis and treaty-based planning
  • Pillar Two and global minimum tax compliance
  • Withholding tax planning
  • Intellectual property and intangible asset structuring
  • Financing structures and thin capitalisation
  • Controlled foreign company rules
  • Diverted Profits Tax and anti-avoidance regimes
  • Cross-border employment and globally mobile employees

The work draws on the wider firm’s specialists in corporate tax, VAT, personal tax and forensic accounting.

Where overseas input is required, our PrimeGlobal relationships give us access to senior specialists in the relevant jurisdictions on terms that fit the engagement.

What you can expect from
our international tax team

Three principles run through our international tax work:

Technical depth without unnecessary complexity

International tax can be made more complicated than it needs to be. We focus on the analysis that matters for the client’s situation and explain the position in plain English.

Practical tax planning

Tax outcomes follow commercial substance. The planning we recommend is consistent with where the business actually operates rather than relying on arrangements that will not survive scrutiny.

Co-ordinated across jurisdictions

Cross-border work needs the position in each jurisdiction to be consistent. We co-ordinate with overseas advisers through PrimeGlobal so the position holds together across borders.

Clients come to us for international tax because they want technical depth applied to their commercial reality – and a trusted guide who can navigate the complexity of the cross-border position with them, make the interactions between jurisdictions manageable and ensure the advice they act on holds together across the whole picture.

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Why choose Macalvins?

Macalvins is a Top 100 UK accountancy firm and a member of PrimeGlobal, a network of around 300 independent firms across more than 80 countries.

That combination gives clients the depth and continuity of an experienced independent practice combined with the international reach and knowledge they increasingly need.

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Insights

Frequently Asked Questions

When do we need formal transfer pricing documentation?

The UK transfer pricing rules apply to most groups above a defined size threshold and the documentation requirements have become more prescriptive in recent years. We help clients understand when formal master file and local file documentation is required, when a country-by-country report applies and what the practical preparation involves. For groups below the threshold the documentation can be lighter but the arm’s length principle still needs to be applied to intra-group transactions.

Can you help with a specific cross-border restructuring project?

Yes. Cross-border restructuring work is a regular part of our practice. The typical project involves mapping the existing position, modelling the alternatives, agreeing the target structure with the client, co-ordinating the local advisers in each jurisdiction and running the implementation in a defined sequence. The work is scoped and quoted at the start so the client has clarity on cost and timetable.