Tax Optimization for a Multinational Corporation Expanding into the UK

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.