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A single hire in another country opens a second payroll and tax system there, and if that person habitually closes deals in the company’s name they can give the company a taxable presence it never meant to create.
Follow the chain in order, or open any term for the full definition and its legal basis.
A fixed place of business, or a dependent agent, through which a company carries on business in another country. Creating a PE can give that country the right to tax the profits attributable to it, even without a local company.
The long-standing test that treats a company as tax resident where its real top-level decisions are actually made, rather than where it is registered. A founder who relocates but keeps controlling the company from the old country may not have moved its residence at all.
The test that decides which country has primary taxing rights over a company, usually based on where it is incorporated or where its central management and control sits. A company can be resident in more than one country, which double taxation agreements then resolve.
A treaty between two countries that allocates taxing rights and provides relief so the same income is not taxed twice. DTAs are central to structuring cross-border dividends, interest, royalties, and employment income.
The UK system by which an employer deducts income tax and National Insurance from wages and reports them to HMRC in real time on each pay run. Any company that pays a salary, including to its own director, has to operate it.
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