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When initially setting up overseas or when reviewing international operations, there are a number of different tax issues that should be considered. It is necessary to do this in order to ensure that the group is structured in a way which both makes commercial sense and minimises tax costs (and associated administrative costs). Tax arbitrage is often the first tax point that is considered, which is discussed in the Effective tax rate planning guidance note, but there are a wide variety of tax considerations that should be reviewed.

In addition to the points discussed below, a number of employment and employment-related tax issues will need to be considered. These are discussed in detail in the Managing global mobility section of the Employment module of TolleyGuidance, but the Global mobility ― overview, Temporarily overseas, Pre-entry planning for UK inbound assignees from an employer’s perspective, Pre-departure planning from an employer’s perspective and Foreign employment guidance notes may be most useful as a starting point.