Corporate Tax for Treasurers

Running a tax efficient treasury function

Course overview

It is vital for treasurers to understand the tax implications of their actions a treasury activity has the opportunity to gain or lose significant amounts of tax for companies. This course consists of two half day sessions to refresh those who haven’t dealt directly with tax matters for a little while, and to focus on some advanced or topical issues. Participants may attend either or both of these sessions

Morning Session: Corporate Tax for Treasurers - Introduction / Refresher

Session overview

Do you wish you knew a bit more about how treasury transactions are taxed? Are you a little rusty on the current rules? Delivered from a UK tax perspective, but covering key international aspects, this half day workshop is designed to give you a grounding in core tax rules and answer all the basic questions you’ve ever wanted to ask! Practical examples encourage group participation and deliver an understanding of the application of tax rules in practice.

Programme

Loans, derivative contracts and FX

• An introduction to some core concepts for tax, eg taxable entities, profits versus cash flows
• An outline of the primary rules governing the tax

treatment of loans, deposits, derivatives

• Vital comparisons and distinctions with overseas regimes

Withholding taxes

• What they are and how to mitigate them

Related party transactions

• Evaluation of the specific issues affecting related party transactions, including thin capitalisation (i.e. acceptable gearing levels), transfer pricing, debt waivers, recapitalisation, debt for equity swaps

Liquidity management

• Comparing and contrasting methodologies for tax
  purposes

Afternoon Session: In-depth taxation issues - Masterclass

• Session overview

Do you have a grounding in the tax rules governing treasury transactions but want to understand more about the critical tax issues? Do you like to keep up with latest developments affecting the tax treatment of day-to-day treasury transactions?

Do you wish you could have a more informed discussion with your tax colleagues? Primarily focusing on UK tax rules, but with some comparison of overseas regimes, this interactive half day workshop is designed to give you insights into key areas of tax that impact on core treasury transactions.

Trends in accounting

• How accounting developments make a fundamental difference to the tax treatment of financing and hedging transactions, with particular reference to IFRS-SME and proposed changes to IAS 39

Hedging transactions

• The pitfalls and opportunities in securing tax-efficient hedging transactions

The UK ‘debt cap’ regime

• Practical issues with optimising UK group funding arrangements in light of the new UK ‘debt cap’ rules

Tax planning

• A look at the latest trends in anti-avoidance measuresand UK case law

What you will gain

• A half or full day’s tax update with senior specialists in treasury taxation
• Insight into the core UK tax rules governing treasury transactions, including the most up-to-date developments in relevant case law and anti-avoidance provisions
• An overview of core international tax concepts that should be borne in mind when tructuring cross-border financing activities, such as international cash management, inter-company transactions and hedging strategies

Who will benefit?

• Morning session: Anyone working in treasury who has a basic grasp of UK corporate tax principles and needs to understand more about how corporate tax can affect the value added by treasury activities.
• Afternoon session: As above, plus those who have responsibility for or who deal more directly with tax affairs in their company.

Trainer

• Sue Mainwaring and members of the PricewaterhouseCoopers Finance & Treasury Tax network