Cross-border transactions

This subtopic deals with the tax considerations associated with 'inbound' transactions involving overseas businesses investing or expanding into the UK and 'outbound' transactions involving UK businesses investing or expanding overseas.

Cross-border corporate acquisitions

A non-UK based purchaser of a UK business (or UK-headquartered business) will need to consider the following UK tax issues:

•
the potential UK tax costs associated with the acquisition
•
the tax-efficient return of profits to the non-UK purchaser
•
maximising the UK tax-efficiency of the target business
•
a tax-efficient exit, and
•
structuring the transaction to mitigate tax costs and maximise tax efficiency

These issues are discussed in Practice Note: What are the UK tax considerations for an overseas purchaser acquiring a UK business?

A UK based purchaser of an overseas business will need to consider the following UK and overseas tax issues:

•
the potential overseas and UK tax costs associated with the acquisition
•
the tax-efficient return of profits from the overseas business to the UK purchaser
•
a tax-efficient exit
•
maximising the tax-efficiency of the target business
•
relevant anti-avoidance provisions, and
•
possible disclosure and filing

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