Tax implications of international joint ventures
Produced in partnership with Sara Stewart of Vinson & Elkins RLLP and Mathew Oliver of Bird & Bird
Tax implications of international joint ventures

The following Tax guidance note Produced in partnership with Sara Stewart of Vinson & Elkins RLLP and Mathew Oliver of Bird & Bird provides comprehensive and up to date legal information covering:

  • Tax implications of international joint ventures
  • Tax issues for international joint ventures
  • Choice of joint venture structure/vehicle
  • Establishment of the joint venture—contribution of assets
  • Taxation of the joint venture
  • Loss relief for the joint venture
  • Financing the joint venture—loan financing
  • Financing the joint venture—equity financing
  • Termination of the joint venture

This Practice Note considers the key tax issues arising when structuring, operating and terminating an international joint venture, over and above those raised by a domestic UK joint venture. For information on the UK tax aspects of domestic joint ventures see Practice Notes:

  1. Tax implications of contractual joint ventures

  2. Tax implications of establishing a joint venture partnership

  3. Tax implications of operating and terminating a joint venture partnership

  4. Tax implications of establishing a joint venture company

  5. Tax implications of operating and terminating a joint venture company

For the purposes of this Practice Note, an international joint venture is considered to be an arrangement where either the joint venture vehicle (if one exists) or at least one of the joint venture parties is non-UK tax resident. It is assumed for the purposes of this note that the joint venture parties are corporate entities. For information on the corporate aspects of international joint ventures, see Practice Note: Cross-border joint ventures—overview.

Tax issues for international joint ventures

International joint ventures are not fundamentally different from UK domestic joint ventures, in the sense that in both contexts consideration needs to be given to the same elements and objectives of the venture. Consideration of these aspects may however give rise to additional tax issues, over and above those that arise in a wholly domestic joint venture.