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Brexit: An overview of the
direct and indirect
tax implications
September 24, 2019
12:00PM – 1:30PM ET
Speakers
David Sites Imran Khan Matt Stringer
Head of International Tax Transfer Pricing, Partner Head of International Tax
Grant Thornton US Grant Thornton UK Grant Thornton UK
Adam Jackson Karen Robb
Head of Brexit & Political Risk Advisory Indirect Tax, Partner
Grant Thornton UK Grant Thornton UK
© 2019 Grant Thornton LLP | All rights reserved | U.S. member firm of Grant Thornton International Ltd 2
Learning objectives
Define what the current political climate is surrounding
1 Brexit, including how we got here, what the current
landscape looks like and what the future holds.
Identify the anticipated direct tax implications and how
2 this fits together with the wider international tax
landscape.
3 Identify the anticipated indirect tax implications.
4 Identify transfer pricing implications.
© Grant Thornton LLP. All rights reserved. 3
Brexit An overview Adam Jackson Head of Brexit and Political Risk Advisory E: Adam.E.Jackson@uk.gt.com Twitter: @Adam_E_Jackson
Brexit: what on earth is going on?
© Grant Thornton LLP. All rights reserved. 5
What is Brexit?
© Grant Thornton LLP. All rights reserved. 6
Brexit – three possible outcomes
A B C
‘No Deal’ Brexit ‘Deal’ Brexit No Brexit
UK leaves the European Union UK agrees a deal with the EU and UK decides to cancel Brexit and
to trade on WTO terms. enters a transition period. During this remain in the European Union.
the UK negotiates its new relationship Political divisions will remain
There is no transition period. with the EU that will start at the earliest and we may see more radical
from Jan 2021. domestic reform.
Short term disruption, long term Short term stability, long term Short term stability, long term
uncertainty uncertainty uncertainty
© Grant Thornton LLP. All rights reserved. 7Timeline – a busy three months
ahead
• Brexit October 31 – January 31
• Election before Christmas (from
November 18)
As a high impact and medium probability
outcome, we recommend clients with any
operations, investment or customers in the
UK have active contingency plans for a
no-deal Brexit on October 31
No-deal Brexit is also a high probability for
January 2020
© Grant Thornton LLP. All rights reserved. 8How does this affect you?
© Grant Thornton LLP. All rights reserved. 9Prepare for Brexit
Continuity, Compliance and Cost
Continuity Compliance Cost
Minimise disruption Ensure your Take action to
during Brexit organization, products mitigate costs and
and services comply protect cashflow
with new rules and
processes
© Grant Thornton LLP. All rights reserved. 10Key risks and opportunities
Based on our experience of working with clients, we have identified the following
as common risks and opportunities that a no-deal Brexit could create.
Market access Supply chain New products Acquisitions
NewMarket access for
trade barriers Supplydisruption
Cross border chain and Supporting customers’
New products Acquisitions
Opportunity to acquire
goods and services impact on core operations Brexit needs under-valued assets
New trade barriers for Cross border disruption and Supporting customers’ Opportunity to acquire
goods and services impact on core operations Brexit needs under-valued assets
Cumulative cost People Foreign exchange Competitive advantage
Greater need to cost
Cumulative reduce Retention
Peopleand Increased
Foreign international
exchange How does youradvantage
Competitive exposure
costs and optimise recruitment of staff competitiveness compare to competitors?
working
Greater needcapital
to reduce Retention and Increased international How does your exposure
costs and optimise recruitment of staff competitiveness compare to competitors?
working capital Risks and opportunities from a tax perspective follow…
© Grant Thornton LLP. All rights reserved. 11Be prepared for wider political change
in the UK
Post election policy directions
Tax People Business Infrastructure Public services Climate change Trade Relations
Conservative
• Employee led • Increased • Review High
• Market
skills and competition Speed Rail? • Market • US trade
• Tax cuts provision /
training • Reduced • Continue incentives deal?
outsourcing
• Social mobility regulation Heathrow?
• Tackling
• • • •
Common
Minimum Cross- Increased Zero carbon
•
ground
BEPS Common-
wage £10/hr? • Audit market Pennine / spending on by 2050
• Digital wealth
• End free reform local education and • Regulatory
services countries?
movement transport health action
tax
• “Social • Nationalisation • Halt
Labour
• Public • EU trade deal
• Higher justice” • Controls on Heathrow? • Deliver by
sector • Ethical foreign
taxes • Employee public sector • Continue High government
solutions policy
ownership contractors Speed Rail?
© Grant Thornton LLP. All rights reserved. 12Brexit Indirect tax implications Karen Robb Indirect Tax, Partner E: Karen.Robb@uk.gt.com
Indirect taxes – status quo
Non-EU goods EU Goods
– Import declaration – Frictionless border
– Customs Duty and VAT payments UK – No customs duty
Border
– Customs controls and inspections – No adverse VAT cashflow
Non-EU Goods in free
Goods circulation
Goods in free
EU Goods
circulation
© 2019 Grant Thornton LLP | All rights reserved | U.S. member firm of Grant Thornton International Ltd 14Brexit: Key issues and considerations
Supply chain implications
• Need to keep products moving
• Additional administration
• Just in time sensitive production
Reduced working capital
• Additional VAT locked up?
• Increased absolute costs (duty isn’t recoverable)
Impact on price and profitability Interacts with
• Pass the costs on – reduced price competitiveness? broader tax
issues, such
• Bear the costs – margins might be lower? as transfer
pricing
© Grant Thornton LLP. All rights reserved. 15Indirect tax - No-deal Brexit impact
• Customs entries on EU goods
• Customs duties and Import VAT on imports and exports
• Double duties on goods moving across EU/non-EU borders multiple times
• UK content no longer counts towards EU origin
© Grant Thornton LLP. All rights reserved. 16Brexit: Pressure at ports?
• Implications for all ~ 135 UK ports and airports
• Many airports and deep sea ports already handle ROW
goods – customs systems and infrastructure
• Biggest impacts for “Roll-on / Roll-off” ports (ferry ports)
– not used to volumes and frequency, and undertaking a
number of additional checks and controls
• Critical for trade, business continuity, local and national
economies, continuity of critical goods such as food and
medicines
© Grant Thornton LLP. All rights reserved. 17HMRC – “Transitional Simplified
Procedures”
• HMRC has announced Transitional Simplified Procedures (“TSP”)
to make importing easier for a period if the UK leaves the EU
without a deal
• Can be used at all UK ports, not just ferry ports
© Grant Thornton LLP. All rights reserved. 18Eligibility requirements
To register you must:
• Have an EORI number
• Be established in the UK:
o Your company has a registered office in the UK or
o Your company has a permanent place of business in the UK where
business activities are undertaken
• Import goods from the EU into the UK
© Grant Thornton LLP. All rights reserved. 19HMRC – “Transitional Simplified
Procedures”
For non-‘controlled’ goods, trader expected to make customs declaration within their
commercial records
• A supplementary declaration will then have to be submitted to HMRC by the fourth
working day of the following month after the goods arrived into the UK
A trader needs to register with HMRC before using TSP
• A requirement to have an Economic Operator Registration and Identification (“EORI”)
number to apply for TSP
• Can also appoint a Customs agent to complete Customs declarations on the trader’s
behalf
• There is also a requirement to have an UK deferment account to pay any customs
duties that are due
© Grant Thornton LLP. All rights reserved. 20UK temporary tariff schedule
• The UK has recently published the tariff schedule that is intended to
be in place for 12 months following a no-deal Brexit
• Once the UK future trade policy is established, the permanent tariff
schedule is expected to be published
© Grant Thornton LLP. All rights reserved. 21UK temporary tariff schedule
Average UK Day 1
Product
no-deal MFN Tariff
Minerals 0.2%
Chemicals 0.1%
Plastics 0.1%
Wood 0.0%
Paper 0.0%
Animal skins 0.2%
Footwear 0.0%
Building materials 0.3%
Ceramics 1.2%
Glassware 0.2%
Precious metals and stones 0.0%
Base metals 0.0%
Machinery, electronics &
0.0%
instruments
Vehicles and transport 2.9%
Arms and ammunition 0.0%
Miscellaneous products 0.0%
© Grant Thornton LLP. All rights reserved. 22Duty and VAT Deferment
• Taxes must be ‘paid or secured’ to release goods from customs
• Possible to defer duty and import VAT until 15th of following month through
duty deferment account
• Bank guarantee required
• Must obtain approval and Deferment Approval Number from HMRC
• New announcement – UK VAT registered businesses can automatically
defer VAT and account for on VAT return
© Grant Thornton LLP. All rights reserved. 23Special Procedures to minimize
Customs Duty and VAT
• Types of Customs Special Procedures:
o Customs Warehousing
o Temporary Admission and End-Use
o Inward and Outward Processing
• Authorization required
• Improved cash flow / absolute duty savings
© Grant Thornton LLP. All rights reserved. 24Customs warehousing
• Public or private customs warehouse
• Defers payment of import VAT and duty where goods are imported
from outside EU / UK until goods are ‘removed’ from the warehouse
• Cash flow advantage
• Interaction with other reliefs
© Grant Thornton LLP. All rights reserved. 25Temporary Admission and End-Use
Temporary Admission:
• Relief from import duty
• No alterations or processing of goods
• Maximum period applies
• E.g. Professional equipment, items for auction, goods for testing, clinical trials
End-Use Relief:
• Favourable rates of duty for specific industries
• No processing required to be able to be used for prescribed end use
• Evidence of prescribed end use
• Military, aircraft, ships, bicycles and shrimps!
© Grant Thornton LLP. All rights reserved. 26Inward and Outward Processing
Inward Processing:
• Relieves import VAT and customs duty
• Import from outside of EU and re-export to outside EU (will include UK post-Brexit)
• Limited time for processing to take place
Outward Processing:
• Relieves import VAT and customs duty
• Import from non-EU country where goods have been produced from previously
exported EU goods.
• Limited time to process before duty and tax become payable
© Grant Thornton LLP. All rights reserved. 27What should businesses be thinking
about?
• Start with your supply chain. Does it include movement of goods through UK and / or EU?
• Calculate VAT and duty impact
o Are you better or worse off?
o What’s the impact on customers taking delivery in UK or EU?
• What do you want to achieve?
o BAU?
o Cost reduction?
o Keep goods flowing?
• No regrets actions
o TSP
o Simplifications
o EORI and VAT registrations
• Consider interactions with broader tax issues, such as transfer pricing
© Grant Thornton LLP. All rights reserved. 28Brexit Direct tax implications Matt Stringer Head of International Tax E: Matt.TA.Stringer@uk.gt.com Twitter: @AccioGin
Overview of the direct tax implications
EU Directives: withholding taxes
Wider international EU Directives:
implications re-organizations
Direct tax
implications
Other treaty Group structures
issues
EU State Aid
© 2019 Grant Thornton LLP | All rights reserved | U.S. member firm of Grant Thornton International Ltd 30EU Directives
Parent / Subsidiary Directive – relief from WHT
on dividends
Interest & Royalties Directive – relief from WHT
Benefits on interest and royalties
of EU
EU Merger Directive – relief from charges on
Directives certain cross-border reorganizations
Anti Avoidance and Mutual Assistance
Directives
© 2019 Grant Thornton LLP | All rights reserved | U.S. member firm of Grant Thornton International Ltd 31EU Directives
Implications of a no-deal Brexit:
• Loss of EU Directives – UK no longer treated as EU member state
• Some transposed into UK law already and more likely to be, so shall stay.
However, EU countries are unlikely to amend their domestic law to include the
UK as an EU member state
• Double tax treaty network
© Grant Thornton LLP. All rights reserved. 32Withholding tax
Impact of UK not being an EU Member State
In relation to UK withholding taxes on payments to EU Member States, HMRC
released guidance on March 21, 2019 which states that the UK will continue to
apply the EU Directives to payments from UK companies to Member States.
This means that there should be no increased UK withholding tax cost on any
interest and royalty payments to Member States. Payments which previously
qualified for the Directive exemptions should continue to qualify. NB: Clearance
process remains in place for interest payments (but not for royalties).
Member States are unlikely to take the same approach – so the relief above only
applies to payments from the UK.
© Grant Thornton LLP. All rights reserved. 33Withholding tax
Impact of UK not being an EU Member State
The impact of moving from the Parent-Subsidiary Directive & Interest and Royalties Directive onto rates agreed
with Double Tax Treaties (i.e. these are the domestic rates, as reduced by the relevant Double Tax Treaty)
Country Dividends Interest Royalties
If shareholding ≥25%, at 5% If shareholding >50%, 10%
0%
Austria Otherwise, 15% Otherwise, 0%
If shareholding ≥10%, at 0%
0%/10% 0%
Belgium Otherwise, 10%/15%
For certain dividends 0% If shareholding ≥10%, 0%
5%
Bulgaria Otherwise 5%/15% Otherwise 5%
If shareholding ≥25%, 5%
5% 5%
Croatia Otherwise 10%/15%
5% for film royalties
0% 0%
Cyprus Otherwise, 0%
If shareholding ≥25%, 5%
0% 0%/10%
Czech Republic Otherwise, 15%
Key: Unless EU country acts to treat the UK as a Member State, there will be a Brexit impact – payments
from EU to UK companies will most likely result in increased costs
Unless EU country acts to treat the UK as a Member State, then depending on facts, there may be a
Brexit impact – payments from EU to UK companies may result in increased costs
There should not be a Brexit impact – payments under treaty should not result in any additional costs
© Grant Thornton LLP. All rights reserved. 34Withholding tax
Impact of UK not being an EU Member State
The impact of moving from the Parent-Subsidiary Directive & Interest and Royalties Directive onto rates agreed
with Double Tax Treaties (i.e. these are the domestic rates, as reduced by the relevant Double Tax Treaty)
Country Dividends Interest Royalties
If shareholding ≥25%, 0%
0% 0%
Denmark Otherwise, 15%
Estonia 0% 0%/10% 0%
Finland 0% 0% 0%
If shareholding ≥10%, 0%
0% 0%
France Otherwise, 15%
If shareholding ≥10%, 5%
0% 0%
Germany Otherwise, 10%/15%
Greece 15% 0% 0%
If shareholding ≥10%, 0%
0% 0%
Hungary Otherwise, 10%/15%
Key: Unless EU country acts to treat the UK as a Member State, there will be a Brexit impact – payments
from EU to UK companies will most likely result in increased costs
Unless EU country acts to treat the UK as a Member State, then depending on facts, there may be a
Brexit impact – payments from EU to UK companies may result in increased costs
There should not be a Brexit impact – payments under treaty should not result in any additional costs
© Grant Thornton LLP. All rights reserved. 35Withholding tax
Impact of UK not being an EU Member State
The impact of moving from the Parent-Subsidiary Directive & Interest and Royalties Directive onto rates agreed
with Double Tax Treaties (i.e. these are the domestic rates, as reduced by the relevant Double Tax Treaty)
Country Dividends Interest Royalties
For certain qualifying companies 0%
0% 0%
Ireland Otherwise, 5%/15%
If shareholding ≥10%, 5%
10% 8%
Italy Otherwise, 15%
If shareholding ≥25%, 5%
10% 5%/10%
Latvia Otherwise, 15%
If shareholding ≥25%, 5%
10% 5%/10%
Lithuania Otherwise, 15%
If shareholding ≥25%, 5%
0% 0%
Luxembourg Otherwise, 15%
Malta 0% 0% 0%
If shareholding ≥10%, 0%
0% 0%
Netherlands Otherwise, 10%/15%
Key: Unless EU country acts to treat the UK as a Member State, there will be a Brexit impact – payments
from EU to UK companies will most likely result in increased costs
Unless EU country acts to treat the UK as a Member State, then depending on facts, there may be a
Brexit impact – payments from EU to UK companies may result in increased costs
There should not be a Brexit impact – payments under treaty should not result in any additional costs
© Grant Thornton LLP. All rights reserved. 36Withholding tax
Impact of UK not being an EU Member State
The impact of moving from the Parent-Subsidiary Directive & Interest and Royalties Directive onto rates agreed
with Double Tax Treaties (i.e. these are the domestic rates, as reduced by the relevant Double Tax Treaty)
Country Dividends Interest Royalties
If shareholding ≥10% for 2 consecutive years, 0%
5% 5%
Poland Otherwise, 10%
If shareholding ≥25%, 10%
10% 5%
Portugal Otherwise, 15%
If shareholding ≥25%, 10%
10% 10%/15%
Romania Otherwise, 15%
If shareholding ≥25%, 5%
0% 10%
Slovakia Otherwise, 15%
If shareholding ≥20%, 0% If shareholding ≥20%, 0%
5%
Slovenia Otherwise, 15% Otherwise, 5%
If shareholding ≥10%, 0%
0% 0%
Spain Otherwise, 10%/15%
If shareholding ≥10%, 0%
0% 0%
Sweden Otherwise, 5%/15%
Key: Unless EU country acts to treat the UK as a Member State, there will be a Brexit impact – payments
from EU to UK companies will most likely result in increased costs
Unless EU country acts to treat the UK as a Member State, then depending on facts, there may be a
Brexit impact – payments from EU to UK companies may result in increased costs
There should not be a Brexit impact – payments under treaty should not result in any additional costs
© Grant Thornton LLP. All rights reserved. 37Withholding tax
Impact of UK not being an EU Member State
Call to action:
• Review any reliance on EU Directives for cross border dividend, interest or
royalty payments
• Think about making best use of Directives before Brexit – NB dividends
• Admin burden: updated clearances (even where 0% rate under treaty)
© Grant Thornton LLP. All rights reserved. 38Practical examples
• Generally no tax credit available for
UK Co foreign dividend withholding tax in the
UK
• German Co dividend attracts a 5%
WHT (at best) under double tax treaty
Dividend payment from date of Hard Brexit
German
Co
WHT leakage
© Grant Thornton LLP. All rights reserved. 39Other EU Directives
Impact of UK not being an EU Member State
EU Mergers Directive ceases to apply, removing tax relief for certain cross border
re-organization activity.
Member States may have clawback provisions for prior reliance after UK
company is deemed to exit an EU grouping.
© Grant Thornton LLP. All rights reserved. 40Group structures
Implications of a no-deal Brexit:
• Do EU-wide tax groupings or consolidations cease to apply?
• Risk of claw back of previously claimed reliefs and inability to claim future
reliefs
• Some EU Member States have a CFC exemption for EU resident companies –
may be lost for UK subsidiaries post-Brexit
• There may be other EU references in domestic tax code of other EU Member
States that would now exclude the UK
© Grant Thornton LLP. All rights reserved. 41EU state aid
Implications of a no-deal Brexit:
• The EU State Aid rules prevent advantages being given on a selective basis by government
authorities which may distort competition (e.g. if tax rebates are given to certain industries)
• Post-Brexit, the UK may no longer be bound by these rules
• Certain UK tax rules are restricted by these rules, for example:
• SME R&D tax relief
• Creatives industries reliefs
• CFC Finance Company exemption (re recent European Commission challenge)
• Post-Brexit – more freedom for UK to relax restrictions and incentivize taxpayers, subject to usual
WTO restrictions
© Grant Thornton LLP. All rights reserved. 42US withholding tax
Impact of UK not being an EU Member State
A number of US treaties include an Equivalent Beneficiaries sub-clause in the Limitation on
Benefits clause. This generally allows a Contracting State to qualify for treaty benefits
where other tests are failed (e.g. the Active Trade or Business test), but a parent company
is in an EU/EEA Member State or is a party to NAFTA and that parent company would itself
qualify for treaty benefits.
Brexit may remove UK companies from such a clause (i.e. no longer EU, nor NAFTA),
meaning any reliance on the Equivalent Beneficiaries sub-clause is not sufficient.
Could lead to 30% US WHT in certain circumstances.
© Grant Thornton LLP. All rights reserved. 43Practical examples
• Domestic rate of WHT in US for royalties is
30%
UK Co • Relief available to reduce this to 0% under the
US-Luxembourg double tax treaty
• LOB clause may deny relief
• Historically where no Lux Active Trade or
License of IP
Business, reliance could have been placed on
the UK’s Active Trade or Business as an
Equivalent Beneficiary in an EU Member State
Lux Co US Co • If UK is no longer an EU Member State, Lux
Co may lose treaty benefits
Can apply to
other forms of
Royalty payment 30% WHT leakage payment and
scenarios
© Grant Thornton LLP. All rights reserved. 44Brexit Transfer pricing implications Imran Khan Transfer Pricing, Partner E: Imran.Khan@uk.gt.com
Transfer pricing considerations
TP considerations arise from two Brexit related scenarios
1. Business restructurings which arise 2. Post-Brexit restructuring steady-
as a direct consequence of Brexit state transactions
Key issue
Key issue
Is there a need, at arm’s length, for
What are the arm’s length pricing
one-off/on-going compensation
outcomes, where do profits and value
(“Exit”) – such compensation would
reside post-Brexit, is this defensible?
be subject to UK taxation
© Grant Thornton LLP. All rights reserved. 46Transfer pricing considerations
1. Business restructuring 2. Steady-state transactions
• Transfers, in particular of intangibles/IP • Arm’s length pricing for new steady-
such as: state transactions such as:
Customer contacts/relationships/list Licensing of intangibles
Supplier contracts Sale of goods
Marketing intangibles, e.g. trade marks Provision of services
Trading intangibles, e.g. technology
Licenses
Interacts with
Other rights such as authorizations other areas of
• Termination or substantial renegotiation of tax, such as
customs duties
terms and conditions
• Significant change in profit potential
© Grant Thornton LLP. All rights reserved. 47Transfer pricing considerations
1. Business restructuring 2. Steady-state transactions
Key considerations
In reaching appropriate and defensible views it is important to consider:
• Legal arrangements, rights and obligations between the related parties
pre and post Brexit
• Underlying substance of the functions, assets and risks of the parties,
how this influences exit and on-going pricing valuations
• Bargaining positions of the related parties
• Options realistically available to the parties
© Grant Thornton LLP. All rights reserved. 48Transfer pricing considerations
Practical example
Brexit related TP considerations apply to a wide range of industries and sectors. Taking the example of a
pharmaceutical business, set out below are potential TP considerations.
1. Brexit related business restructuring – 2. Post-restructuring transactions
transfers to EU related parties of:
• Customer contracts • License of intangibles by
UK entity – e.g. trade
• Supplier contracts Should the UK entity marks
How should
receive, at arm’s • Provision of services by UK such
• Marketing length, any entity – e.g. strategic transactions be
authorizations compensation for management priced at arm’s
transfer of intangibles length?
• Certifications – e.g. to EU related parties? • Remuneration in UK/EU
QP release entities – e.g. distributions,
QP release etc
© Grant Thornton LLP. All rights reserved. 49Any questions?
© Grant Thornton LLP. All rights reserved. 50Speakers
David Sites Imran Khan -Matt Stringer
Head of International Tax Transfer Pricing, Partner Head of International Tax
Grant Thornton US Grant Thornton UK Grant Thornton UK
Adam Jackson Karen Robb
Head of Brexit & Political Risk Advisory Indirect Tax, Partner
Grant Thornton UK Grant Thornton UK
© 2019 Grant Thornton LLP | All rights reserved | U.S. member firm of Grant Thornton International Ltd 51Disclaimer
• This Grant Thornton LLP presentation is not a comprehensive analysis of
the subject matters covered and may include proposed guidance that is
subject to change before it is issued in final form. All relevant facts and
circumstances, including the pertinent authoritative literature, need to be
considered to arrive at conclusions that comply with matters addressed in
this presentation. The views and interpretations expressed in the
presentation are those of the presenters and the presentation is not intended
to provide accounting or other advice or guidance with respect to the matters
covered
For additional information on matters covered in this presentation, contact
your Grant Thornton LLP adviserDisclaimer
**********************
IRS Circular 230 disclosure: To ensure compliance with requirements imposed by the U.S. Internal
Revenue Service, we inform you that any U.S. federal tax advice contained in this PowerPoint is not intended or written
to be used, and cannot be used, for the purpose of (a) avoiding penalties under the U.S. Internal Revenue Code or (b)
promoting, marketing or recommending to another party any transaction or matter addressed herein.
*********************
The foregoing slides and any materials accompanying them are educational materials prepared by Grant Thornton LLP and are not intended as
advice directed at any particular party or to a client-specific fact pattern. The information contained in this presentation provides background
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You may contact us or an independent tax advisor to discuss the potential application of these issues to your particular situation. In the event that
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