Tax Optimization for a Multinational Corporation Expanding into the UK
RECENT DEALS
2/4/20251 min read


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.
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