International Tax

RKG Consulting has broad and deep experience in offering advice on  both direct and indirect international tax matters.

Regarding direct tax issues we regularly advise on the following international tax issues:

  • Corporate residence
  • Permanent establishments (PE)
  • Interpretation of double tax agreements
  • Transfer pricing
  • Resolution of tax disputes and tax investigations

We assist clients on a wide range of matters from obtaining certificates of tax residence for their UK companies, advising clients on avoiding a “fixed place of business” or “agency” permanent establishment in a high tax jurisdiction to successfully demonstrating to tax authorities that clients’ transfer pricing strategies and methodologies are in accordance with the OECD guidelines.

  •  Advising regarding tax-efficient royalty structures for software companies.
  •  Advice regarding double tax treaties.
  • For non-resident principals: Setting-up and administration of tax-efficient international holding company, partnership and financing structures using UK entities for both international trading and UK property holding situations.
  • Advice regarding keeping documentation under the UK transfer pricing regime, basis of attribution of foreign head office costs to UK branch, corporate allocations.
  • VAT and corporate tax implications of on-site, offshore, managed, outsourced services etc.

Regarding VAT and customs matters we offer advice on:

  • Developing VAT & customs duties strategies for companies doing business with the EU.
  • Obtaining VAT refunds in various EU member states and avoiding “irrecoverable” VAT.
  • Advice regarding choosing the correct jurisdiction for VAT registration given the multiplicity and confusing choice of VAT “standard” and “reduced” rates for different products and services.
  • Resolution of VAT and customs disputes with tax authorities.
  • E-commerce and internet trading: our specialist area in regard to international VAT

For further details regarding our indirect tax services please refer to the section “Customs, VAT & International”.  This section is about corporate income tax or “direct” UK and international tax planning.