Greetings Friends of Oury Clark,
Every year, we meet business owners captivated by the same idea: “What if I just moved my holding company offshore and paid no tax?” On paper, it sounds simple. A tropical island, a low tax rate, and a “promise” of effortless efficiency.
The reality? Often rather different.
What starts as a quest for tax savings can quickly become a maze of setup costs, compliance headaches, visa complications, banking challenges, and awkward questions from advisers, regulators and HMRC. Suddenly, that “simple” offshore structure doesn’t feel quite so simple.
That’s not to say international structuring doesn’t have its place. It absolutely does. But the best solution is rarely the one that looks most glamorous on a world map.
In fact, many businesses are surprised to discover that a well-structured UK holding company can offer significant advantages without the complexity. From dividend exemptions and Substantial Shareholding Exemption (SSE) benefits to group relief and robust asset protection, the UK remains one of the world’s most attractive places for holding companies.
When it comes to international tax, keeping things practical often beats chasing paradise. Whatever your next move, Oury Clark is here to help you navigate it with confidence.
Rolling with the Benefits: Mandatory Payrolling & What Employers Need to Know
HMRC has announced that there will now be a phased introduction of the mandatory payrolling of benefits in kind, based on the type of benefit being provided.
The following benefits-in-kind will still be subject to mandatory payrolling from 6th April 2027:
- company cars
- car fuel
- vans
- van fuel
- employer-provided medical benefits
The mandatory payrolling of most other BIKs will be introduced from April 2028. This excludes loans and accommodation which will remain voluntary.
Once benefits are payrolled under the new mandatory system, they will no longer be reported on a P11D because tax will be collected from employees through the payroll in real-time. A P11D (b) will no longer be needed as Class 1A NIC will also be collected in real-time. For more information, read our quick guide.
If you are a current payroll client, we will be in touch in the coming months to begin collating the information we require, to ensure that you are compliant with the move to payrolling benefits. If we do not do your payroll, please do reach out if you would like our assistance.
Did You Know? The UK’s Foreign Permanent Establishment (PE) Exemption Will Become Mandatory from 2027
Significant changes are being made to the UK tax treatment of foreign permanent establishments (PEs) of UK‑resident companies.
From 1 January 2027 (1 September 2026 for overseas oil and gas activities), the current optional foreign PE exemption regime will become mandatory.
At present, companies can choose whether to exempt foreign PE profits from UK corporation tax. This election also prevents the offset of foreign losses against UK profits.
Under the new rules, all foreign PE profits will be automatically exempt from UK corporation tax. This means that losses will also no longer be available to reduce UK taxable profits.
The future use of pre‑existing losses will be blocked, and new anti‑avoidance measures will target any attempts to accelerate loss relief.
HMRC suggests that these reforms are intended to remove perceived imbalances in the current system and align the UK more closely with international practice.
UK businesses with overseas branches should review their position now. A reassessment of whether operating through a subsidiary, rather than a branch, may be appropriate.
Please contact your regular Oury Clark partner if you wish to discuss this.
Get Assurance‑Ready for ASRS (Free Webinar)
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Colin Grevers, Sustainability Director is partnering with SGS for a practical webinar designed to help Group 2 and 3 companies prepare for Australia’s sustainability reporting requirements with confidence.
Click here to register your attendance. |
Tax Havens & The International Tax Problem Without BS
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Could you slash your tax bill by moving everything offshore?
In our latest Business Without BS podcast, Andy Oury and Jemma Hotta separate myth from reality and explain why tax havens aren’t the silver bullet many people think they are. Listen now. |
Now Playing: Can’t Tax This
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The Rebel Accountant is back with a fresh tax-rap reimagining of MC Hammer’s ‘U Can’t Touch This’.
Tackling everything from wealth taxes and tax havens to global competition for investment, ‘Can’t Tax This’ explores what happens when businesses, entrepreneurs and capital have choices. Click here to listen to the latest single. |
Find us on LinkedIn to keep up to date with our travels and any upcoming events.
As usual, if we can help with the above, or anything else, please don’t hesitate to get in touch. Until next time…