Aberdeen – Stavanger Gateway3 June 2014International Tax IssuesKevin R Mann

Overall Tax Objectives – International Projects

Minimise risk of overseas

tax compliance

failure

Understand project

Overall Objectives“Proactive

and Commercial”

Review/amend

onerous contract

terms

Understand & minimise

overseas tax exposures

Factor additional

tax/compliance costs in bid price

“AAB are providing us with advice regarding our overseas employee assignments to Norway. In addition to providing us with guidance from a company perspective, AAB prepared summaries targeted at the employee’s perspective and these were particularly useful in effectively managing our communication of these sometimes delicate issues with our employees affected. We are confident that AAB will keep us on track in relation to our compliance obligations in Norway and are very pleased with the comprehensive and efficient service provided by the AAB team.”

Alan CormackNautronix

Corporate Tax Considerations

UK – 21% (20% from 1 April 2015)Norway – 27%

Rates of Corporation Tax on

profits of PE?

Influence of UK / Norway Double Tax Treaty (DTT)Onshore (Art 5) – Various definitions of PEOffshore (OA’s) (Art 21) – Deemed PE if OA’s > 30 days in any 12-mth period

Carrying on Business in overseas country

through permanent establishment (PE)?

Subsidiary v Branch / PE

in overseas country?Tax rates as aboveRepatriation of post-tax profits?

Other Indirect Taxes?VAT?PAYE / Wage tax?Customs duties?Overseas professional fees?

Double Tax Relief in Home Country?

UK – Restricted to 21% (20% from 1 April 2015) – 6% (7%) incremental tax costNorway – Likely full credit obtained

Employment Tax Considerations

Double Wage Tax deductions (UK and Norway)?Need to be managed

UK – Net of Tax Credit arrangement Norway – Double Tax Credit Relief

PAYE / Wage Tax Obligations of Employer?

Influence of UK / Norway DTTOnshore (Art 14) – Conditions for exemptionOffshore (OA’s) (Art 21) – All remuneration liable to tax

Income Tax Payablein Overseas Country?

National Insurance Liabilities?

Continuing liability in home country (A1 Certificate)?Both employee and employer contributions

Rates of Income Tax Payable?

UK – 20%, 40%, 45%Norway – 27%, 36%, 39%

"As a company we routinely are called to tender for projects in what are ‘frontier’ regions for us often with complex tax regimes and testing legislation relating to international suppliers. Thorough, up to date and concise advice underpin our commercial proposals, and in these respects AAB have never failed to deliver, even at very short notice”

Gary ThirkettleCalecore Limited

International Tax Team – who’s whoContact Details

Kevin R Mann - PartnerTelephone: 01224 625111Email:kevin.mann@aab.co.uk