aberdeen – stavanger gateway 3 june 2014 international tax issues kevin r mann
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Aberdeen – Stavanger Gateway 3 June 2014 International Tax Issues Kevin R Mann. Overall Tax Objectives – International Projects. Overall Objectives “Proactive and Commercial”. Understand project. Review/amend onerous contract terms. Understand & minimise overseas tax exposures. - PowerPoint PPT PresentationTRANSCRIPT
Aberdeen – Stavanger Gateway3 June 2014International Tax IssuesKevin R Mann
Overall Tax Objectives – International Projects
Minimise risk of overseas
tax compliance
failure
Understand project
Overall Objectives“Proactive
and Commercial”
Review/amend
onerous contract
terms
Understand & minimise
overseas tax exposures
Factor additional
tax/compliance costs in bid price
“AAB are providing us with advice regarding our overseas employee assignments to Norway. In addition to providing us with guidance from a company perspective, AAB prepared summaries targeted at the employee’s perspective and these were particularly useful in effectively managing our communication of these sometimes delicate issues with our employees affected. We are confident that AAB will keep us on track in relation to our compliance obligations in Norway and are very pleased with the comprehensive and efficient service provided by the AAB team.”
Alan CormackNautronix
Corporate Tax Considerations
UK – 21% (20% from 1 April 2015)Norway – 27%
Rates of Corporation Tax on
profits of PE?
Influence of UK / Norway Double Tax Treaty (DTT)Onshore (Art 5) – Various definitions of PEOffshore (OA’s) (Art 21) – Deemed PE if OA’s > 30 days in any 12-mth period
Carrying on Business in overseas country
through permanent establishment (PE)?
Subsidiary v Branch / PE
in overseas country?Tax rates as aboveRepatriation of post-tax profits?
Other Indirect Taxes?VAT?PAYE / Wage tax?Customs duties?Overseas professional fees?
Double Tax Relief in Home Country?
UK – Restricted to 21% (20% from 1 April 2015) – 6% (7%) incremental tax costNorway – Likely full credit obtained
Employment Tax Considerations
Double Wage Tax deductions (UK and Norway)?Need to be managed
UK – Net of Tax Credit arrangement Norway – Double Tax Credit Relief
PAYE / Wage Tax Obligations of Employer?
Influence of UK / Norway DTTOnshore (Art 14) – Conditions for exemptionOffshore (OA’s) (Art 21) – All remuneration liable to tax
Income Tax Payablein Overseas Country?
National Insurance Liabilities?
Continuing liability in home country (A1 Certificate)?Both employee and employer contributions
Rates of Income Tax Payable?
UK – 20%, 40%, 45%Norway – 27%, 36%, 39%
"As a company we routinely are called to tender for projects in what are ‘frontier’ regions for us often with complex tax regimes and testing legislation relating to international suppliers. Thorough, up to date and concise advice underpin our commercial proposals, and in these respects AAB have never failed to deliver, even at very short notice”
Gary ThirkettleCalecore Limited
International Tax Team – who’s whoContact Details
Kevin R Mann - PartnerTelephone: 01224 625111Email:[email protected]