Entering the UK market presents tremendous growth potential for international businesses, but tax compliance and efficiency are vital to long-term success. From choosing the right entity type to optimising cross-border profits, corporate tax structuring in the UK is a strategic process that impacts every area of your operations.
The UK’s competitive corporate tax environment, double taxation treaties, and legal transparency make it a favourable destination for global firms. However, to benefit fully, foreign businesses must structure their tax affairs with foresight and regulatory precision.
At Fraser Bond, we guide overseas companies through the intricacies of UK tax planning—ensuring efficiency, compliance, and sustainable growth.
HMRC (Her Majesty’s Revenue & Customs) enforces strict rules on income, VAT, transfer pricing, and reporting. Proper tax structuring helps avoid penalties and reputational risk.
Strategic tax planning allows companies to minimise their effective tax rate using allowable deductions, group reliefs, R&D credits, and treaty benefits.
Cross-border structuring ensures tax-efficient movement of funds between UK operations and your global headquarters or parent company.
Whether planning acquisitions, fundraising, or a future sale, clean and transparent tax structuring enhances your credibility with investors and regulators.
Most foreign businesses operate in the UK through a private limited company (Ltd) or a UK branch. Each structure has different tax implications.
Ltd Company: Subject to UK corporation tax on global income; offers more flexibility and credibility.
Branch Office: Taxed only on UK-sourced profits but less attractive to some clients and partners.
As of 2025, the UK corporation tax rate is 25% (with small profit relief available for companies earning under £50,000). Planning includes:
Group relief
Capital allowances
Interest deductibility
Loss utilisation
Tax-efficient financing structures
UK subsidiaries or branches of foreign companies must comply with OECD-aligned transfer pricing rules, including documentation of intercompany transactions.
Businesses may need to register for VAT (20%) depending on turnover and sector. Structuring can reduce VAT exposure via exemptions, group registration, and supply chain planning.
The UK has 130+ double taxation agreements, allowing for reduced withholding tax on dividends, interest, and royalties between the UK and many foreign jurisdictions.
UK-based or international holding structures can be used for IP ownership, profit repatriation, and investment flexibility—subject to substance and anti-avoidance rules.
Technology & SaaS: R&D tax credits, IP box planning, and digital VAT compliance
Real Estate & Property Investment: Use of UK REITs or non-resident landlord structures
Retail & Ecommerce: Distance selling thresholds, VAT OSS/IOSS planning
Manufacturing & Distribution: Customs duties, bonded warehousing, and import VAT deferral
Financial Services: Regulatory licensing and sector-specific exemptions
Fraser Bond works with tax professionals and sector specialists to ensure optimal structuring for your industry.
Fraser Bond helps international businesses plan, implement, and manage UK tax structures with confidence. Our services include:
Initial tax feasibility analysis for UK entry
Entity selection and group structuring
VAT, PAYE, and corporation tax registration
Transfer pricing policy design and documentation
Advisory on profit repatriation and double taxation relief
Coordination with legal, accounting, and payroll teams
Ongoing tax compliance monitoring and updates
Whether you’re launching a UK operation or restructuring existing activities, we deliver tailored, compliant, and growth-aligned solutions.
A robust corporate tax structure is the foundation of a successful UK operation. For foreign companies, it’s not just about minimising liabilities—it’s about ensuring legal compliance, operational efficiency, and strategic clarity.
Fraser Bond provides trusted, expert-led tax structuring services for international businesses entering or expanding in the UK. With our guidance, you can navigate HMRC regulations, reduce risks, and build long-term financial sustainability.
