Brexit impact on US tax treaty relief

December 2018

Groups with international structures are likely to have started reviewing their group structure in the EU to assess whether it will be optimal for a post-Brexit environment. Clearly, this should encompass the customs and VAT implications and consideration of which group companies import or export and from where. However, it is also vital to review the funds flow around the group in terms of dividends, interest and royalties.

Where there are significant intra-group payments across borders, groups should pay close attention to the way withholding tax is currently mitigated and whether there is reliance on EU directives or UK membership of the EU to claim tax reliefs.