Roy Saunders
Founder of IFS Consultants (retired)
Previous Specialisations
Private Client
Corporate Tax Planning
Company Structuring
International Taxation
Roy's Articles
There is no such thing as a No-Deal Brexit
The Brexit discussion meeting at Close Brothers Asset Management on Thursday, 30th May was a fascinating insight into the legal, political and economic consequences of Brexit. Despite my having chosen a date for this discussion some months ago, thinking that 30th May would be[...]
Date:
03 Jun 2019
Subjects:
Brexit
The True Impact of BEPS on International Business Structures
In the last decade, OECD officials have recommended measures to combat tax avoidance, culminating first in the BEPS (Base Erosion and Profit Shifting) initiative in 2015 and then the MLI (Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS) effective[...]
Date:
28 May 2019
Jurisdiction:
Changes in the world of Fund Management
The world of Fund structuring, management, regulation and compliance has been transformed in the last few years. The most recent announcement was on 5 February 2019 when the European Commission welcomed a political agreement reached by the European Parliament and EU Member[...]
Date:
12 Mar 2019
The IBSA 2018 Conference Summary
The following is a summary of the CosiPod IBSA annual conference, held at the Berkeley Hotel, Knightsbridge on 1st November 2018. It was a spectacular success, thanks to our expert speakers and delegate contributions, making this a truly memorable event.
[...]
Date:
15 Nov 2018
Jurisdiction:
Global
Substance and the MLI
Lehman Brothers collapsed on 15 September 2008, and since that time there has been an unprecedented interest in protecting government budgets, with tax avoidance being as high on the agenda as bank capital adequacy. This may have heralded the start of the OECD project called[...]
Date:
27 Sep 2018
Jurisdiction:
BREXIT – The End Result!
This article is my assessment of the reality of Brexit and the likely deal that will emanate from ridiculously long and protracted negotiations, the issues of which have mystified the public in the UK and the EU. [...]
Date:
08 Sep 2018
Subjects:
Brexit
Structuring a Business in Today's Transparent World - A Discussion Group Meeting Summary
The theme of the meeting was to understand how business structures have been attacked by the OECD and other governmental bodies on the grounds that relevant entities have little or no substance behind them. Offshore companies, such as BVI companies, have typically been pulled[...]
Date:
09 Jul 2018
Trust, Capitalism and Tax – A summary of The Lord Mayor’s Tax Debates
I was invited to attend the Lord Mayor’s Tax Debates at Mansion House yesterday, 19 June 2018, as part of his Business of Trust agenda. The Lord Mayor, Charles Bowman, opened the discussion by considering why there has been an extraordinary decline in public trust in business[...]
Date:
20 Jun 2018
Jurisdiction:
Subjects:
General principles
Tax Residence in the sun!
At a recent IBSA conference, advisers from Spain, Portugal, Italy, Cyprus, Switzerland and Dubai were vying with each other to demonstrate how their countries were offering better tax incentives than the UK’s non-domicile legislation - plus sunshine, or in the case of[...]
Date:
09 Oct 2017
Double Tax Treaty Denial and the BEPS Multilateral Instrument
The European branch of the IBSA held a well-attended meeting at the office of Buren NV in the Hague on Tuesday 3rd October, at which three speakers addressed the issue of double tax treaty denial and the multilateral instrument. The speakers were Roy Saunders, Chairman and[...]
Date:
09 Oct 2017
Beneficial Ownership in today’s world
Who really owns the right to income? And are they declaring it? These are the obvious two questions that tax authorities around the world want to ask. And a third question is, are intermediary entities within a group structure entitled to be separately treated as if they own the[...]
Date:
04 Jul 2017
The Future World of International Tax
The IBSA held its first Transatlantic video conferencing meeting at the New York and London offices of Squire Patton Boggs (SPB) on Wednesday 15th March. It was a fascinating insight into how the US and UK are likely to evolve their tax systems in the coming years,[...]
Date:
17 Mar 2017
Guiding the Development of SME Clients - Conference Summary
Many of you will be familiar with the Polycon case study, which I have often used to illustrate the issues involved in structuring the development of international companies. This was the basis of the recent IBSA annual conference at the Landmark hotel in London, and the issues[...]
Date:
01 Dec 2016
Subjects:
Corporate structuring and taxationIdentification, Protection and Exploitation of IPRR & D Tax Credits and Patent Box RegimesBrandingInvestor Requirements and Financing TechniquesOverseas Joint Venture AgreementsPersonal taxationGeneral principlesCorporate structuring and taxationIP Box RegimeIndirect taxation
Debt v Equity and Notional interest deduction
In our October 2015 newsletter, we discussed the Base Erosion and Profit Shifting (BEPS) project for which the OECD had just finalised their Action Points recommendations. Unlike EU’s legislation that has immediate effect when it becomes national law (which is obligatory for all[...]
Date:
01 Nov 2016
THE SPECIAL TAX REGIMES APPLICABLE TO ENTERTAINERS & SPORTSMEN
There are few areas of international tax planning which offer as much scope for creative structuring as the field of entertainment generally and also for our sporting heros. This article will summarise the principal considerations to be borne in mind when structuring[...]
Date:
05 May 2016
The IBSA Conference: Issues Affecting the International Development of SMES
Covering financing, tax, intellectual property, business strategy and economic issues, the 2015 IBSA Members’ conference was a fantastic celebration of the sheer range of expertise and sectors that the association covers.[...]
Date:
04 Dec 2015
Jurisdiction:
Subjects:
General principles
Investing in Africa: IBSA Lisbon Meeting Discussion Summary
The IBSA event in Lisbon on 25 November centred around an investment project in Mozambique and the international business structuring issues related to this investment. [...]
Date:
03 Dec 2015
Subjects:
General principles
Life After BEPS
The BEPS (Base Erosion and Profit Shifting) initiative of the OECD has been a fascinating insight into a politically driven project fuelled by public and media disquiet about the effectiveness the tax planning of multinationals, some of whom were paying very low levels of tax on[...]
Date:
28 Oct 2015
Jurisdiction:
UK Branch Meeting - Growth: Funding, M&A and structuring your business for success
This is a summary of the IBSA discussion group which took place on the evening of Tuesday 29 September on the subject of ‘Growth: Funding, M&A and structuring your business for success’.[...]
Date:
14 Oct 2015
Jurisdiction:
United Kingdom
Subjects:
General principles
THE TAX ADVISOR’S ROLE TO TAX PLANNING
This article reflects on the tax advisor’s role in the current environment of penalising what has hitherto been considered acceptable tax planning. It also highlights the demise of bank secrecy and the new role of banks as unpaid detectives for tax administrations. The article[...]
Date:
09 Sep 2015
Jurisdiction:
Subjects:
General principles
Can Foreign Companies be used in International Business Structuring?
This article considers the use of foreign companies in international business structures, and whether they are still viable following the treaty limitation provision of Action Plan 6 of the BEPS initiative. The review of how a client in Residonia has to work out whether a[...]
Date:
19 May 2015
Jurisdiction:
Tax Planning for Sportsmen
Professional sportsmanship is rarely a life-long career but it can be extremely lucrative. In addition to salary, an ever increasing proportion of the income of successful sportsmen comprises income from exploitation of their image rights by international brands. Also,[...]
Date:
22 Apr 2015
Jurisdiction:
Confidentiality & Exchange of Information - Geneva launch summary
Roy Saunders rounds-up the European Branch launch from Geneva, where the topic of Confidentiality & Exchange of Information generated an excellent discussion. [...]
Date:
06 Mar 2015
Jurisdiction:
"All Change" - State Aid and the BEPS Initiative in 2015
‘All Change’ shouts the guard at our local Baker Street station, and passengers have to leave the warmth and familiarity of the train they have been travelling on and stand on a cold, unfriendly platform waiting for the next train, uncertain of whether they will be able to get[...]
Date:
19 Feb 2015
Jurisdiction:
A Review of 2014 – Corporate Acquisitions and BEPS
Corporate acquisitions have returned with a vengeance in 2014 – the greatest number of deals since 2007. This is partly because the US and UK economies have recovered, partly because larger companies have amassed significant amounts of cash in the downturn and are now turning[...]
Date:
12 Dec 2014
Jurisdiction:
Subjects:
General principles
Corporate Residence
The importance of determining corporate residence is that the taxing rights of any particular country are usually defined by reference to whether an entity is resident or non-resident. Depending upon the taxation policy of the country in question, residents will typically be[...]
Date:
09 Sep 2014
Jurisdiction:
Israel
Subjects:
Double taxation
Understanding Double Tax Treaties
The purpose of this article is to review double tax treaties with a view to gaining an understanding of what they are, how they operate, how they are interpreted and concentrate on the rationale behind them.[...]
Date:
31 Jul 2014
Jurisdiction:
Subjects:
Double taxation
Politics and the BEPS Project
Base Erosion and Profit Shifting is a hot topic within the international tax community, spurred on by the G20 backed OECD initiative. The OECD has outlined a stringent time frame to implement recommendations. What are the other approaches that could be adopted?[...]
Date:
10 Dec 2013
Jurisdiction:
United Kingdom
International Tax Efficient Exploitation of Intellectual Property Rights
Date:
16 Aug 2013
Jurisdiction:
General principles
International Tax Aspects of Intellectual Property
Date:
16 Aug 2013
Jurisdiction:
General principles
Low-Tax Jurisdictions or Tax Havens
Date:
15 Aug 2013
Jurisdiction:
General principles
Subjects:
General principles
Beneficial Ownership
Date:
13 Aug 2013
Jurisdiction:
General principles
Subjects:
General principles
International Investment in UK Real Estate
Roy Saunders examines the means and methods by which international investors can invest in UK real estate. [...]
Date:
04 Jul 2013
Jurisdiction:
General
Subjects:
Real estate
Trusts - What Are They and Why Use Them?
Roy Saunders explains the principles behind trusts, how they apply to the client and how the wider acceptance across European jurisdictions of trusts as a financial vehicle is developing. Particular reference is made to Jersey as an example trust location.[...]
Date:
04 Jul 2013
Subjects:
Trusts and similar entities