As businesses become more global, they’re changing their operating structures to manage complex supply chains and reflect new organisational management models. These changes often result in the need to manage many tax implications at once, including Corporate Tax, International Tax, Employee Tax, VAT and Customs duty.

How we can help you

• We can help you look at all the tax implications of your purchasing decisions to improve the after tax return
• With extensive experience of multinational clients, we can help you integrate tax into your organisational design
• We can assist you with designing and implementing a UK hub structure for your international trading activity and leverage patent box opportunities
• We have expertise implementing tax-effective structures in a digital value chain.
• Our team members have extensive experience of all tax aspects of the intellectual property (IP) life cycle and can take a broad view of your strategy
• We have business advisory capabilities enabling us to offer support on strategic, commercial, operational and legal matters
• We can also advise on ways to reduce your tax risk and become more BEPS compliant
• We can advise you about the emerging centre-led operating models, which can align your tax model with organisational change
  

Client work examples

KPMG advised a European medical technology company on the relocation of its headquarters to the UK. We provided advice on the direct and indirect tax consequences of establishing a principal company in the UK, which will be responsible for managing the Group’s IP and R&D activities. KPMG has also advised the main shareholders on the impacts of the restructuring on their personal tax circumstances.

KPMG designed a new supply chain and procurement structure for a global fashion brand and retailer. Our work extended to establishing a new procurement company and designing a transactional model to incorporate a dual principal model. We designed a model offering ultimate cash savings across indirect taxes and customs duties whilst preserving corporation tax savings and a robust final operating structure. Our work involved systems design for the new structure which involved transaction setting, template design and testing. In addition, our legal team completed the legal agreements to allow the new model to go live.

KPMG assisted with the feasibility and design of a centralised stock ownership model. The business required the new model for greater supply chain visibility, and to simplify and streamline intra-group transactions. Our work involved a detailed exploration of the business’ value drivers, manufacturing network and the necessary systems capabilities to establish the new pricing model. We prepared the transfer pricing, permanent establishment, exit charge, VAT/Good and Services Tax (GST) and customs duty risk assessment. We also coordinated thirty KPMG overseas offices’ reviewing the proposed transfer pricing model.

KPMG was engaged to produce a high level IP roadmap, setting out the current state arrangements regarding the group’s UK and Australian IP assets. It also covered potential future state arrangements involving a UK-based IP company and the operational and tax areas to consider. We carried out an analysis and high-level valuation of the IP held in Australia and the potential tax benefits and pitfalls of moving to a UK-centralised IP model.