Tax Optimization for a Multinational Corporation Expanding into the UK

RECENT DEALS

2/4/20251 min read

green vegetable on white ceramic plate
green vegetable on white ceramic plate

Background

A Hong Kong-based multinational corporation sought to expand its UK operations while optimizing corporate tax liability and profit repatriation.

Challenges

  • Reducing exposure to the 25% UK corporate tax rate.

  • Structuring operations to minimize withholding tax on cross-border transactions.

  • Ensuring compliance with UK anti-avoidance tax rules.

Solution

Treasure Well Law Associates implemented a tax-efficient corporate structuring plan:

  • Establishing a UK holding company, benefiting from UK’s extensive Double Taxation Treaty (DTT) network.

  • Utilizing a Luxembourg SPV to facilitate tax-efficient repatriation of dividends.

  • Structuring intellectual property (IP) holdings in Ireland, benefiting from 12.5% corporate tax.

Outcome

  • Corporate tax exposure was reduced by 40%.

  • The structure ensured compliance with UK and EU tax regulations.

  • The company successfully expanded, generating £10 million in annual UK revenue.