Offshore Tax Planning in Practice - Governance, Substance & Compliance

Introduction

This webinar provides a structured, compliance first view of offshore tax planning for multinational and mid market groups.

Aimed at accountants, tax advisors and in-house tax professionals in the UK, this webinar will separate legitimate planning from avoidance and evasion, situate choices within OECD BEPS and UK anti avoidance guardrails, and then build up the architecture of practical holding, finance and IP platforms.

It will emphasise substance (people, decision making, premises), interactions with CFC and hybrid rules, and the governance and documentation expected by tax authorities, lenders and auditors.

On completion of this webinar, you will be able to:

• Distinguish legitimate planning from avoidance and evasion using UK GAAR principles and targeted anti avoidance rules (TAARs)
• Map the policy guardrails - OECD BEPS, economic substance requirements, and the centrality of real decision making
• Compare on shore, mid shore and offshore platform choices for holding, finance and IP - including treaty access, PPT and beneficial ownership tests
• Model CFC interactions and align transfer pricing with the location of functions, assets and risks
• Understand interactions with interest restriction (CIR), anti hybrid rules and imported mismatches - with worked mini examples
• Design risk management - disclosure regimes, documentation packs, board minutes, governance and tax control frameworks
• Evaluate ‘do/don’t’ structure patterns and plan unwind or regularisation paths when legacy structures no longer fit

What You Will Learn

This webinar will cover the following:

• Landscape & guardrails - the policy context (OECD BEPS, UK GAAR, TAARs); why ‘substance over form’ is now the baseline
• Core building blocks
• Holding platforms - jurisdiction selection filters (treaty network, participation exemptions, exit taxes, withholding outcomes)
• Finance platforms - treasury centres, interest flows, thin cap/CIR, cash pooling and guarantees, interaction with hybrids
• IP platforms - DEMPE functions, nexus and R&D incentives, residual return location, defensive vs offensive IP holding
• Treaty access & anti abuse
• Principal Purpose Test (PPT), Limitation on Benefits (where applicable), beneficial ownership and ‘relief at source’ practices
• Practical documentation: beneficial ownership evidence, board composition, officer authority, and commercial rationale
• CFC & substance
• People functions, decision minutes, premises, and services agreements
• Aligning transfer pricing: services, financing, intangibles; intercompany agreements and actual conduct
• Financing & hybrids mini examples
• CIR impact modelling; disallowed interest carryforwards and reversals
• Hybrid payer/deduction no inclusion; imported mismatch chains; sequencing with ETR calculations
• Risk management & governance
• Disclosure regimes (e.g., DOTAS style where relevant), MDR/DAC6 awareness, auditor expectations
• ‘Evidence pack’ content list: corporate documents, functional analysis, travel logs, leases, service contracts
• Case studies
• ‘Plain vanilla’ defensible holding/finance stack with clear substance
• Aggressive conduit with poor substance: red flags and unwind playbook (timeline, consents, tax and legal steps)

This pre-recorded webinar will be available to view from Thursday 2nd July 2026

Alternatively, you can gain access to this webinar and 2,100+ others via the MBL Webinar Subscription. Please email webinarsubscription@mblseminars.com for more details.