Cross-Border Corporate Tax Structuring - Aligning Business Objectives with Global Rules

Introduction

This webinar provides a case driven framework for designing robust cross border structures that align tax outcomes with business reality.

It will define objectives (capital vs debt, holding and IP chains, M&A integration), set out the non negotiable rules (treaty access, PPT/LOB, PE risk, transfer pricing and anti hybrid/interest limitations), and integrate Pillar Two touchpoints.

Finally, consideration will be given to withholding planning, migration and reorganisation routes, and how authorities challenge aggressive designs.

This webinar is pitched at advanced level, so an understanding of Double Tax Treaty, transfer pricing and Pillar Two concepts is assumed. It offers a UK perspective with global coordination.

What You Will Learn

This webinar will cover the following:

• How to translate objectives and understand constraints
• Capital vs debt mix; treasury considerations; covenants and ratings
• Holding and IP routes; post deal restructuring and integration plans
• The Gatekeepers - Rules to respect
• Treaty access proof; PPT/LOB anti abuse; beneficial ownership
• PE risk mapping; transfer pricing for financing/services/intangibles; DEMPE functions
• Interest limitations (CIR) and anti hybrid rules; interaction with loss refresh and reclassification risks
• How Pillar Two affects the following:
• Jurisdictional ETR modelling; substance based carve outs; qualified domestic top ups (QDMTT)
• Coordinating financing: where returns sit, and how QDMTT/IIR/UTPR ordering impacts cash taxes
• Practical withholding tax planning relating to:
• Relief at source vs reclaim workflows; documentation packs; BO tests for dividends, interest and royalties
• Managing timing and statute deadlines; common denial reasons and remediation
• Exit and reorganisations:
• How to plan Migrations (central management and control), branch vs subsidiary, reverse branching
• Step plans; asset vs share deals; exit charge and double tax relief considerations
• Case studies - How tax authorities typically challenge aggressive designs and how to evidence substance and commercial rationale as follows:
• ‘Plain vanilla’ defensible holding/finance chain with DEMPE aligned IP
• Aggressive design flags: conduit indicators, mismatched functions vs returns, persistent loss making risk companies

This pre-recorded webinar will be available to view from Thursday 4th June 2026

Alternatively, you can gain access to this webinar and 1,900+ others via the MBL Webinar Subscription. Please email webinarsubscription@mblseminars.com for more details.