International taxation - Windram Miller

International taxation: Some planning - or, at least, reconnaissance - is a good idea where two or more tax systems may affect the total impact of taxation on a holding or operation. Virtually all types of direct tax may have an effect, including corporation tax, income tax, capital gains tax and gifts and inheritance taxes.


Circumstances where this may occur can be as simple as a married couple of English domicile and residence owning a holiday home in Spain. A more complex example may be the establishment by a business resident in one jurisdiction of a sales operation in another. In all such cases, it is necessary to consider not only any bi-lateral and multinational (EU, for example) treaties between the states involved, but also the domestic tax and other relevant laws of all those states.


It is often possible to modify the ultimate tax consequences of such cross-border holdings or operations by procedural changes, contract wordings, and other such "non-invasive" techniques.


Change in the overall distribution or amount of the tax take can also be achieved by the introduction into the owning and/or operating structure of additional or different elements (commonly companies or trusts), often established in different jurisdictions. Restructuring of this nature usually requires careful cost/benefit analysis.


International tax planning is Windram Miller's headline service. We can advise on many jurisdictions (and obtain specialised local expertise from our associated and representative offices in other countries). Without doubt, our primary expertise is in the Anglo-Spanish field.


Please follow this link for further information on Spanish Tax.