What to consider and asses shall the UK exit the EEA and major operations (therefore changes to holding and financing structures) must be set up in an EEA member state:
- Tax and labour cost
- Restructuring of financing across new locations
- Contingency plan to reflect and consider the various scenarios
- Cost of Finance and access to Capital
- Capital restrictions
- Transferring or hiring new staff
- Planning and Implementing processes across new locations
- Complying with EU VAT rules – no guidance currently exists
- Reliance on tax treaties meaning frictional tax costs (withholding tax)
- The likelihood of EU corporate tax initiatives
- Tax profiles of your existing EU holding and financing structures versus existing principal entities
- Tax losses, tax attributes, tax groupings, and existing transfer pricing models
- VAT treatment of cross border operations or supplies
- Impact on FX traders and organisation because of how they are hedged
It is important that organisations focus on the road ahead and do not become embroiled in the potential chaos of watching the Brexit story unfold. Action undertaken now will be time well spent to ensure you have a well-documented and researched strategy which can be executed at pace as the Brexit direction becomes clear. Formal change management and communication is of utmost importance across all levels of your organisation to ensure the current high levels of performance are maintained allowing employees and leadership to maintain focus.