1. Small Business Seminar 5 February 2004 Maturity Victor Dauppe BSc CTA FCA AIIT TEP MacIntyre Hudson, London

2. Scenario The business is expanding into new markets and it needs to rationalise its structure to remove obsolete commercial entities and consider import/export procedures and cross border tax implications.

3. Overseas Element Overseas Sourcing Overseas Sales Overseas Representation

4. Overseas Sourcing CT: IP and Interest Withholding Analysis of Agreement VAT: Goods – Acquisition and Imports Services – Reverse Charge

5. Overseas Sales CT: Double Tax Relief Treaty Relief VAT: Goods – Zero Rating Proof of Export Services – Place of Supply Rules and Schedule 5

6. Overseas Representation Entity Independent Agent Branch Subsidiary Funding and Thin Capitalisation Transfer Pricing

7. Rationalisation Objectives and Reliefs Tax Goals Personnel & Succession

8. Objectives and Reliefs Objectives Rationalisation (slimming down the structure) Separation of Activities Reliefs (Deferral of Tax Charge or Occasion of Charge) CGT Reconstruction Relief CT Reconstruction Relief Anti-Avoidance & Clearance Inc s776

9. Tax Goals Loss of: Small Company Rate of CT CGT Business Asset Taper Relief IHT Business Property Relief Substantial Shareholding Relief

10. Personnel & Succession Share Schemes Purchase of Own Shares S 110 Reconstructions Demerger Relief