International Tax Accountants for Cross-Border Business
We handle the tax that arises when a business, its owners or its property sit in more than one country. Transfer pricing, permanent establishment, double-tax relief and cross-border VAT, from a firm regulated by the ACCA, with a fixed fee agreed before the work starts.
- Transfer pricing, permanent establishment and treaty relief
- Overseas landlords and the non-resident landlord scheme
- Cross-border VAT, withholding tax and double-tax relief
- An ACCA-regulated practice, fixed fees agreed first
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Where the Tax Is Owed, and How the Treaty Bridges It
The problem in one picture: the same profit can be taxable in two countries at once. A double-tax treaty and the relief rules decide who taxes what, so it is taxed once rather than twice.
United Kingdom
- A UK-resident company is taxed here on its worldwide profits
- A UK permanent establishment of an overseas company is taxed here
- UK rental income of an overseas landlord is taxed under the non-resident landlord scheme
Overseas
- The other country taxes the profit that arises there
- Withholding tax may be deducted at source on interest and royalties
- Transfer pricing sets the arm's-length price for dealings between the two
International tax is not a separate tax. It is what happens when the ordinary rules of two countries both apply to the same money at once: a UK company with an overseas branch, an overseas company selling into the UK, a landlord abroad with a flat in London, a group that moves goods and services between its own entities. Each country wants to tax the part that belongs to it, and without the treaty rules the same profit can be taxed twice.
We do the cross-border side for companies and the businesses behind them. International tax accountants exist because the rules that carve up a profit between countries, transfer pricing, permanent establishment, double-tax relief and the place-of-supply VAT rules, are specific enough that a purely domestic accountant tends to miss where they bite.
Guides to Cross-Border Tax
Plain explanations of the rules that decide who taxes what, written for the people who run internationally-active businesses rather than for other accountants.
Transfer Pricing Explained
This guide covers the arm's-length principle, the SME exemption and the documentation UK groups have to keep
Read the guideDouble-Taxation Relief
This guide covers treaty, unilateral and deduction relief, and how the credit for foreign tax is capped
Read the guidePermanent Establishment
This guide covers the domestic and treaty tests for a permanent establishment and the corporation tax that follows
Read the guideThe Non-Resident Landlord Scheme
This guide covers how UK rent to landlords abroad is taxed, how to receive it gross, and the company rules
Read the guideWithholding Tax on Cross-Border Payments
This guide covers the duty to deduct tax from interest and royalties paid abroad and how treaty relief applies
Read the guideControlled Foreign Companies
This guide covers what makes a company a CFC, when a UK shareholder is charged, and the main exemptions
Read the guideWhat We Do for Internationally-Active Businesses
The corporation tax return where a foreign branch or an overseas subsidiary is in the picture, the transfer pricing policy and the master file or local file documentation where a group is large enough to need it, the double-tax relief claimed so foreign tax is credited rather than lost, and the cross-border VAT position on goods and services that move between countries. Where an overseas business is coming into the UK, or a UK business is expanding out, we set the structure up so the permanent establishment and residence questions are answered before they become an assessment.
For overseas landlords with UK property we run the non-resident landlord scheme and the return, which since April 2020 sits in corporation tax for companies and in Self Assessment for individuals.
Where the Cross-Border Position Gets Hard
Three things trip up a domestic accountant here. Transfer pricing requires dealings between connected companies in different countries to be priced at arm's length, with documentation to back it, and the rules reach medium-sized businesses in more cases than people expect. Permanent establishment turns on whether activity in another country creates a taxable presence, which is a question of fact rather than a box that is ticked. And relief for foreign tax is capped and has to be claimed correctly, or it is simply lost.
Getting those right, and reconciling them to the treaty between the two countries, is most of what a specialist adds.
How We Quote
A fixed fee in writing before anything starts, set by the countries involved and the complexity rather than by an hourly clock. A single overseas landlord with one UK flat is a different price from a group with entities in several countries and a transfer pricing policy to document.
If the position is straightforward, we will tell you what you can reasonably do yourself rather than quote for it.
What We Do Not Do
We do not sell tax-avoidance schemes, and we do not advise on offshore structures, trusts or investment products. Tidy Money Ltd is regulated by the ACCA for accountancy and tax, not authorised by the FCA for investment advice, and the job is to apply the cross-border rules correctly and claim the relief you are due, not to sell you a structure HMRC will later unpick.
We are also not a directory. Your enquiry does not go to a panel of firms, nobody pays us to be recommended, and there are no testimonials on this site, because we will not publish any we cannot evidence. We do not run an inbound phone room either, so you will not be cold-called.
What We Are Engaged to Do
Cross-Border Corporate Tax
Permanent establishment, corporate residence, treaty relief and withholding tax, run as one ongoing engagement.
Transfer Pricing
Policy design, benchmarking, master file and local file, and defending the arm's length position.
Non-Resident Landlord Tax
Scheme registration, gross-payment applications, and the return for overseas owners of UK rental property.
International VAT
Place of supply, the reverse charge, exports, and the OSS and IOSS schemes for EU and NI consumers.
UK Inbound and Outbound Structuring
Branch versus subsidiary, when a UK PE arises, and the residence and treaty position for expanding abroad.
Common questions
What does an international tax accountant do?
We handle the tax that arises when more than one country has a claim on the same business, income or property: transfer pricing between connected companies, whether activity abroad creates a permanent establishment, relief for tax already paid overseas, the non-resident landlord scheme, and cross-border VAT. The aim is that a profit is taxed once, in the right place, rather than twice or under the wrong rules.
What is transfer pricing and does it apply to my business?
Transfer pricing is the rule that transactions between connected companies in different countries must be priced as if they were between independent parties, at arm's length. There is an exemption for small and, in most cases, medium-sized enterprises, but HMRC can still direct a medium-sized business to apply the rules, and the exemption does not cover dealings with certain non-treaty territories. We assess whether it applies to you and prepare the documentation if it does.
When does activity in another country create a permanent establishment?
Broadly when a business has a fixed place of business in the other country, such as an office or branch, or an agent there who habitually concludes contracts for it. The precise test comes from UK law and the treaty between the two countries, and construction projects have their own time threshold that varies by treaty. It is a question of fact, so we look at what is actually happening on the ground before a filing position is taken.
How does double-taxation relief work?
Where the same income is taxed in two countries, the UK generally gives credit for the foreign tax against the UK tax on that income, capped at the lower of the two amounts, either under the treaty with that country or under unilateral relief. It has to be claimed correctly and is limited, so foreign tax can be lost if the return is not prepared with the relief in mind. We make sure the credit is claimed and the position matches the treaty.
I am an overseas landlord with a UK property. What do I need to do?
UK rental income is taxable in the UK even when you live abroad. Under the non-resident landlord scheme your agent or tenant deducts tax at the basic rate unless HMRC has approved you to receive the rent gross, and you then file a return: since April 2020 that is a corporation tax return for companies and Self Assessment for individuals. We register you, apply for gross payment where appropriate, and file the return.
Tell Us About the Cross-Border Position and We Will Quote
Tell us which countries are involved, what the business is, and what you need: transfer pricing, a permanent establishment question, the non-resident landlord scheme, cross-border VAT or a return. We come back with a fixed fee for the work and the dates that apply. If the position is straightforward, we will say so rather than quote for a full package.
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