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International business operating models: the tax issues

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In view of the changing international landscape and increased globalisation of workforces, this article examines key existing tax considerations for global operating models, including the UK’s diverted profits tax, withholding tax issues on royalties allocable to permanent establishments, the UK’s anti-hybrid and offshore receipts in respect of intangible property rules, transfer pricing, permanent establishment and residence. It then assesses the key UK tax issues associated with restructurings that seek to ensure that the operating model is sustainable and aligned to business strategy. The impact of Brexit, digital taxes and the OECD’s two pillar proposals is also considered, and the commentary highlights the increasing importance of considering international tax, transfer pricing and indirect taxes holistically.

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