Well isn't this good news

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Im not sure Im understanding the reason for leaving the EU nor the advantage to be here.

Are you talking of individuals that are leaving their EU job and returning to a UK firm.

No I'm talking about companies who leverage the EU open market model to channel revenues to certain EU countries where there are efficiencies. For example most UK software/hi techs channel income from sales via the RoI where corporation tax is low. Where goods are of a physical nature they use Intellectual property fees to reduce a burden, typically registering the IP in a low tax country like Denmark, Luxembourg etc and then apply "licensing fees" to their subsidiaries to ensure minimum local taxes are paid. Starbucks were famously caught out doing this.
 


Are the British Virgin Islands in the EU? Bermuda? Cayman Islands? Jersey? Guernsey? Isle of Man?

Where are the world's most corrosive Tax Havens?

How about Panama? Where Prime Minister Cameron had his secret funds?

How much UK tax does Richard Branson pay?
 
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No I'm talking about companies who leverage the EU open market model to channel revenues to certain EU countries where there are efficiencies. For example most UK software/hi techs channel income from sales via the RoI where corporation tax is low. Where goods are of a physical nature they use Intellectual property fees to reduce a burden, typically registering the IP in a low tax country like Denmark, Luxembourg etc and then apply "licensing fees" to their subsidiaries to ensure minimum local taxes are paid. Starbucks were famously caught out doing this.

I dont understand the reason for returning to the UK.

Is it to benefit from an expected low tax economy
Or is it to avoid ATAD?

My impression is that what your clients are doing rather confirms the real reason for Brexit: its an advantage to the wealthy that want a low tax economy.
Which rather underlines the fact that the average man in street that voted for brexit, voted against his own interests.

I hate to say it, but Ive come across quite a few lawyers that are on social media actively promoting brexit. I wonder if they have vested self interests.
 
Not many lawyers I know are pro-brexit. But business people look for opportunities.

The above may be considerations, but the primary is anticipated loss of a complete open market, where things can be moved easily.
 
Are the British Virgin Islands in the EU? Bermuda? Cayman Islands? Jersey? Guernsey? Isle of Man?

Where are the world's most corrosive Tax Havens?

How about Panama? Where Prime Minister Cameron had his secret funds?

How much UK tax does Richard Branson pay?

Here's the thing, if you add all those countries together, as a tax haven, even combined, it is smaller than Ireland.

https://en.wikipedia.org/wiki/Ireland_as_a_tax_haven
 
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