International tax is relevant to a number of different situations, from a UK company making its first trades overseas through to large multinationals needing to consider the Pillar Two multinational and domestic top up tax rules.

In addition to a company knowing where it is tax resident, UK companies will need to consider international tax issues when expanding abroad, potentially including the controlled foreign company rules, and foreign companies will need to consider the UK international tax rules when setting up in the UK. These issues are outlined below at ‘UK resident company establishing outside the UK’ and ‘Foreign resident company establishing in the UK’.

It may also be sensible to consider whether a company should change its tax residence (whether by inbound migration or by outbound migration) or where a holding company should be located. This is discussed below at ‘Structuring international groups’.

Companies undertaking digital services activities will also need to consider the digital services tax (DST), see the Digital services tax guidance note.

In addition, international groups may wish to consider