Tax that keeps up with your business across borders.

Advising on international expansion, group structuring, and cross-border operating models to manage tax leakage and compliance risk.

• Subsidiary vs branch considerations
• Governance and substance
• Profit repatriation planning

When you should contact us: If you are entering a new country, hiring overseas staff, or setting up local operations.

Helping groups implement practical, defensible transfer pricing policies for related-party transactions aligned with OECD principles.

• Intercompany service fees & management charges
• IP licensing and royalty arrangements
• Intra-group loans and funding

When you should contact us: The UK's transfer pricing rules contain exemptions for many small and medium-sized groups, but a number of overseas jurisdictions apply their requirements at much lower thresholds. If you transact with overseas related parties and do not yet have a transfer pricing policy in place, it is worth reviewing your position.

Assessing whether overseas activity creates a taxable presence and what that means for filings and profit attribution.

• Overseas employees and sales activity
• Agents negotiating or concluding contracts
• Projects that extend beyond short-term thresholds

When you should contact us: Where a director, senior employee or sales team begins working regularly overseas, or where you open premises or take on staff in another country.

Reviewing treaty positions and managing withholding tax exposure on cross-border payments.

• Interest, royalties, dividends
• Treaty relief applications and documentation
• Practical approaches to avoid tax leakage

When you should contact us: Before making cross-border interest, royalty or service payments, particularly where treaty relief or domestic exemptions may apply.

Tax support for international transactions and group planning, from pre-deal structuring through to post-completion integration.

• Cross-border acquisitions and disposals
• Pre-exit restructuring
• Cross-border finance and withholding
• CFC and hybrid mismatch considerations

When you should contact us: Before heads of terms are agreed on an international deal, or when a group reorganisation is on the table, while the structure can still be shaped.

Helping companies get clarity and efficient outcomes in HMRC enquiries with a cross-border dimension, from residence and permanent establishment to transfer pricing, withholding and offshore matters.

• Managing risks and ensuring HMRC use their powers correctly
• Accelerating settlements and getting certainty of treatment
• Mitigating penalties and protecting personal liability of directors

When you should contact us: If you have an ongoing HMRC investigation, or receive a letter, we are happy to look at how we can help.