International tax

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Gateley Legal

Ambitious businesses often have growth aspirations in jurisdictions outside of their home country. Our tax specialists have a wealth of experience working with clients from all sectors to help them achieve their international growth ambitions.

What do we do?

Getting your international tax planning right from the start will ultimately maximise returns for all stakeholders. That’s where we can help: by planning the tax implications of how and when to launch and scale internationally to secure success with your global expansion.

Like most other sophisticated tax advisory practices, Gateley has a wealth of experience advising on the cross-border tax implications of commercial, financing and investment activities. However, Gateley and our tax team is unique, as we have practitioners who have themselves worked in companies that raised finance from different jurisdictions, operated cross-border activities within international groups and have lived and worked in other countries. This provides unmatched insight into the practical implementation of tax advice and a deep understanding of how to make international tax advice relevant and effective. 

Our international tax experts advise on:

  • permanent establishments and tax residence;
  • cross-border M&A;
  • cross-border debt and equity investments;
  • taxation of profit repatriation;
  • indirect tax in new territories;
  • transfer pricing;
  • withholding tax management on servicing debt, intellectual property royalties, real property rents and premiums;
  • internationally mobile employees and employment taxes across borders;
  • indirect tax on cross-border transactions; and
  • restructuring debt and equity investments

Who do we help? 

Our international tax experts advise organisations that are:

  • expanding into new territories, whether by establishing a green field site, joint venture, partnership or other commercial arrangement; 
  • buying a company in another jurisdiction to accelerate international expansion and growth; 
  • recruiting and retaining the key talent that will make their international operations successful; 
  • raising money in another jurisdiction to finance international ambitions; and 
  • importing and exporting goods and services across international borders.

Examples of our experience 

  • Advising US private equity investors on the finance structure to acquire a UK target group. 
  • Advising a UK group on its intellectual property and transfer pricing structure associated with the shift of its R&D function to another country. 
  • Advising on the acquisition of a Namibian mining company, including the pre-sale reorganisation. 
  • Advising the management team across various European jurisdictions on a secondary buyout by private equity of a global airline supply company. 
  • Providing tax advice on designing and implementing a share scheme for a UK recruitment business deploying UK employees to the US. 
  • Providing UK tax structuring advice to an Italian national/ UK resident disposing of the entire share capital of a global group of companies. 
  • Advising on the listed loan exemption from UK withholding tax on interest. 
  • Advising a syndicate of US investors on an investment in UK commercial property. 
  • Advising a US group on issues created by the UK and the EU’s anti-hybrid rules in relation to their UK and EU operations. 
  • Advising an AIM-listed client on the UK employment tax impact of its employees moving to work permanently outside the UK. 
  • Assisting a French company on the UK VAT and customs duties treatment of importing goods into the UK for onward sale to UK-based customers and the UK corporation tax implications of setting up a UK subsidiary to service contracts with those customers.