This Practice Note considers some of the tax issues that arise when structuring a private equity acquisition that has both UK and offshore elements. The issues considered include: acquisition costs, withholding tax, capital gains tax treatment on an exit, planning for UK resident investors, the importance of Luxembourg, and profit shifting. Produced in partnership with Ceinwen Rees, Shaul Steinberg and Charishma Bhujohory of Macfarlanes LLP.