International business face increasingly complex tax challenges
Dealing with the tax authorities in one country can be difficult enough. But, when businesses expand internationally, the tax issues can multiply. And cross-border transactions and arrangements can give rise to a multitude of complex tax issues – with many evolving in tandem with global tax policy.
Internationally, there is increased momentum for finding worldwide solutions for a range of perceived tax problems, particularly those arising from globalisation and the digitalisation of the economy. Policymakers have looked at how to tax profitable multinational companies in the countries in which they operate, for example, as well as at a global minimum corporation tax rate.
Meanwhile, tax authorities and the wider public are increasingly alert to whether businesses are paying their "fair share" of tax. In this environment, tax issues are now not only a financial and legal concern but have a reputational dimension too.
Multinational businesses can face a wide range of international tax issues relating to cross-border mergers and acquisitions, inward investment and overseas expansion, holding company structures and reorganisations, international sales channels, transfer pricing and cross-border financing, intellectual property planning and tax incentives, internationally mobile employees, VAT, customs duties and EU tax.
International businesses might have to deal with tax authority investigations, arbitrations and disputes in multiple jurisdictions. They will also need to navigate a mesh of international tax reporting rules, including the Directive on Administrative Cooperation 6, which requires tax authorities to have "early warning" notification of new cross-border tax schemes; the US' Foreign Account Tax Compliance Act; and the global Common Reporting Standard.
Creative and efficient
This globalised and evolving legal and regulatory tax landscape requires creative and efficient strategies. Osborne Clarke offers the international breadth and experience to call on and coordinate experts from across jurisdictions and legal and professional disciplines to help deliver and implement international tax solutions for global business.
Tax issues are now not only a financial and legal concern but have a reputational dimension too."
Morrison & Co
We advised Morrison & Co on the acquisition of a majority interest in Fore Freedom Holdings B.V., a fibre-to-the-premises network business in the Netherlands, from funds managed by Ancala Partners.
Osborne Clarke advises CoStar Group in the acquisition of Emporis GmbH, a global provider of building data.
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