IFS Consultants

Office:

IFS Consultants
7/10 Chandos Street
London
W1U 6AG
United Kingdom

Tel:

44 (0) 207 034 7077

Alternate Tel:

44 (0) 203 368 3968

About IFS Consultants

IFS is a boutique international tax practice based in central London specifically created to assist entrepreneurial clients with innovative long term commercial structures for their businesses.

 

IFS routinely provides advice in the following areas:

Corporate Transactions

Transfer Pricing

Mergers and Acquisitions

Structured Finance Deals

Royalty and IPR Transactions

Private Equity and Venture Capital Funds

International Real Estate

Changes of Personal Residence

Corporate Redomiciliation

Internationally Mobile Individuals

Taxation of Entertainers and Sportsmen

Global Employment Solutions

Members

Roy Saunders
Roy Saunders
Founder and Chairman
Dmitry Zapol
Dmitry Zapol
International Tax Advisor
Igor Persidskiy
Igor Persidskiy
Of Counsel
Giselle Peters
Giselle Peters
Director of Corporate Services and Administration

Offices

IFS Consultants, London

IFS Consultants, London

Tel: 44 (0) 207 034 7077 Alternate Tel: 44 (0) 203 368 3968 Head Office:

IFS Consultants
7/10 Chandos Street
London
W1U 6AG
United Kingdom

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Articles by IFS Consultants

Changes in the world of Fund Management

The world of Fund structuring, management, regulation and compliance has been transformed in the last few years. The most recent announcement was on 5 February 2019 when the European Commission welcomed a political agreement reached by the European Parliament and EU Member[...]
Date: 12 Mar 2019

Tax planning considerations for Tier 1 HNW migrants in the UK

The UK encourages foreign direct investments by granting high net worth individual investors and entrepreneurs the right to remain temporarily in its territory, with the associated tax benefits of the resident “non-dom” regime. Similar rights are extended to members of their[...]
Date: 12 Mar 2019
Jurisdiction: United Kingdom

Virtual banking and blockchain development

On 27 May 1997 Nationwide Building Society launched the first internet-banking service in the UK. After more than twenty years, nowadays, we only need a smartphone and internet access in order to easily transfer even a large amount of money from one country to another, pay for[...]
Date: 15 Jan 2019

New Offshore Economic Substance Laws

Amidst the Brexit hullabaloo and Mr Trump’s usual inciting tweets, one would be excused not to pay much heed to the announcement of the new offshore economic substance requirements at the end of 2018. Yet the legislation passed in the Crown Dependencies — Jersey, Guernsey and[...]
Date: 08 Jan 2019

The IBSA 2018 Conference Summary

The following is a summary of the CosiPod IBSA annual conference, held at the Berkeley Hotel, Knightsbridge on 1st November 2018. It was a spectacular success, thanks to our expert speakers and delegate contributions, making this a truly memorable event. [...]
Date: 15 Nov 2018
Jurisdiction: Global

Taxation of Gifts Under UK Law

Taxation of gifts under UK law is complicated and rather counterintuitive. It throws many surprises at the parties participating in a gift arrangement, particularly, since it’s the person making a gift as opposed to the one receiving it, who may be liable for tax. This article[...]
Date: 29 Oct 2018
Jurisdiction: United Kingdom

Substance and the MLI

Lehman Brothers collapsed on 15 September 2008, and since that time there has been an unprecedented interest in protecting government budgets, with tax avoidance being as high on the agenda as bank capital adequacy. This may have heralded the start of the OECD project called[...]
Date: 27 Sep 2018
Jurisdiction:

BREXIT – The End Result!

This article is my assessment of the reality of Brexit and the likely deal that will emanate from ridiculously long and protracted negotiations, the issues of which have mystified the public in the UK and the EU. [...]
Date: 08 Sep 2018
Subjects: Brexit

US Citizenship Renunciations and its Tax Consequences

Despite the highest in the world, $2,350 citizenship renunciation fee and possible tax consequences, every year around 7,000 US citizens decide to renounce their citizenship. This amount is steadily increasing every year since 2010, when Foreign Account Tax Compliance Act[...]
Date: 28 Aug 2018
Jurisdiction: United States of America
Subjects: TaxUS Regulations

Structuring a Business in Today's Transparent World - A Discussion Group Meeting Summary

The theme of the meeting was to understand how business structures have been attacked by the OECD and other governmental bodies on the grounds that relevant entities have little or no substance behind them. Offshore companies, such as BVI companies, have typically been pulled[...]
Date: 09 Jul 2018

Trust, Capitalism and Tax – A summary of The Lord Mayor’s Tax Debates

I was invited to attend the Lord Mayor’s Tax Debates at Mansion House yesterday, 19 June 2018, as part of his Business of Trust agenda. The Lord Mayor, Charles Bowman, opened the discussion by considering why there has been an extraordinary decline in public trust in business[...]
Date: 20 Jun 2018
Jurisdiction:
Subjects: General principles

Tax Residence in the sun!

At a recent IBSA conference, advisers from Spain, Portugal, Italy, Cyprus, Switzerland and Dubai were vying with each other to demonstrate how their countries were offering better tax incentives than the UK’s non-domicile legislation - plus sunshine, or in the case of[...]
Date: 09 Oct 2017

Double Tax Treaty Denial and the BEPS Multilateral Instrument

The European branch of the IBSA held a well-attended meeting at the office of Buren NV in the Hague on Tuesday 3rd October, at which three speakers addressed the issue of double tax treaty denial and the multilateral instrument. The speakers were Roy Saunders, Chairman and[...]
Date: 09 Oct 2017

Beneficial Ownership in today’s world

Who really owns the right to income? And are they declaring it? These are the obvious two questions that tax authorities around the world want to ask. And a third question is, are intermediary entities within a group structure entitled to be separately treated as if they own the[...]
Date: 04 Jul 2017

UK Tax Primer for Entrepreneurial Clients

Advising a client is a two-way process. The client knows how to get to their end destination and our duty is to help them do this with the least tax leakage and in the most commercially sound way. Although every client is unique, inevitably after years of providing advice,[...]
Date: 08 Jun 2017
Jurisdiction: United Kingdom

The Future World of International Tax

The IBSA held its first Transatlantic video conferencing meeting at the New York and London offices of Squire Patton Boggs (SPB) on Wednesday 15th March. It was a fascinating insight into how the US and UK are likely to evolve their tax systems in the coming years,[...]
Date: 17 Mar 2017

Residence Planning for Entrepreneurial Clients

Roy Saunders, IFS Consultants, opened the floor by introducing the audience to a case study that involved a wealthy family with business and investment activity worldwide and possibilities to choose any country as their home. He explained that the panel would describe advantages[...]
Date: 07 Mar 2017

Guiding the Development of SME Clients - Conference Summary

Many of you will be familiar with the Polycon case study, which I have often used to illustrate the issues involved in structuring the development of international companies. This was the basis of the recent IBSA annual conference at the Landmark hotel in London, and the issues[...]
Date: 01 Dec 2016

Debt v Equity and Notional interest deduction

In our October 2015 newsletter, we discussed the Base Erosion and Profit Shifting (BEPS) project for which the OECD had just finalised their Action Points recommendations. Unlike EU’s legislation that has immediate effect when it becomes national law (which is obligatory for all[...]
Date: 01 Nov 2016

Developments in UK Real Estate Taxation in Recent Years

For decades, the UK has welcomed overseas investors with interests in residential and commercial properties with its benign tax regime. Admittedly there had been a few mildly irritating snags: an increasingly high stamp duty land tax (SDLT), unavoidable taxation of rental[...]
Date: 26 Sep 2016
Jurisdiction: United Kingdom

The Business of an International Family Office

A family office is often found in the list of affluent lifestyle’s attributes together with a yacht, a jet and a Swiss boarding school tie. Yet on closer inspection, out of these and similar objets du désir a family office serves a much greater practical purpose — that of[...]
Date: 15 Jun 2016
Jurisdiction: United Kingdom

THE SPECIAL TAX REGIMES APPLICABLE TO ENTERTAINERS & SPORTSMEN

There are few areas of international tax planning which offer as much scope for creative structuring as the field of entertainment generally and also for our sporting heros. This article will summarise the principal considerations to be borne in mind when structuring[...]
Date: 05 May 2016

The IBSA Conference: Issues Affecting the International Development of SMES

Covering financing, tax, intellectual property, business strategy and economic issues, the 2015 IBSA Members’ conference was a fantastic celebration of the sheer range of expertise and sectors that the association covers.[...]
Date: 04 Dec 2015
Jurisdiction:
Subjects: General principles

Investing in Africa: IBSA Lisbon Meeting Discussion Summary

​The IBSA event in Lisbon on 25 November centred around an investment project in Mozambique and the international business structuring issues related to this investment. [...]
Date: 03 Dec 2015
Subjects: General principles

Life After BEPS

The BEPS (Base Erosion and Profit Shifting) initiative of the OECD has been a fascinating insight into a politically driven project fuelled by public and media disquiet about the effectiveness the tax planning of multinationals, some of whom were paying very low levels of tax on[...]
Date: 28 Oct 2015
Jurisdiction:

UK Branch Meeting - Growth: Funding, M&A and structuring your business for success

This is a summary of the IBSA discussion group which took place on the evening of Tuesday 29 September on the subject of ‘Growth: Funding, M&A and structuring your business for success’.[...]
Date: 14 Oct 2015
Jurisdiction: United Kingdom
Subjects: General principles

THE TAX ADVISOR’S ROLE TO TAX PLANNING

This article reflects on the tax advisor’s role in the current environment of penalising what has hitherto been considered acceptable tax planning. It also highlights the demise of bank secrecy and the new role of banks as unpaid detectives for tax administrations. The article[...]
Date: 09 Sep 2015
Jurisdiction:
Subjects: General principles

Key considerations when structuring home ownership in the UK

Along with immigration procedures if required, buying a home is often the next step for those looking to relocate to the UK. There are many legal and regulatory issues that the expectant property owner should consider, but because the value of the new investment is likely to be[...]
Date: 09 Sep 2015
Jurisdiction: United Kingdom
Subjects: General principles

Developing Strategies for International Business - Workshop Summary Note

On 4th June in London, the IBSA held a workshop on Developing Strategies for International Business. Sessions from leading industry experts included treaty access limitations, the global economic outlook, transfer pricing and business investment reliefs. This article provides an[...]
Date: 23 Jun 2015
Jurisdiction:
Subjects: General principles

Can Foreign Companies be used in International Business Structuring?

This article considers the use of foreign companies in international business structures, and whether they are still viable following the treaty limitation provision of Action Plan 6 of the BEPS initiative. The review of how a client in Residonia has to work out whether a[...]
Date: 19 May 2015
Jurisdiction:

Creation of Clean Capital

Dmitry Zapol explains the concept of clean capital and its application to resident non-domiciliaries and the remittance basis.[...]
Date: 28 Apr 2015
Jurisdiction: United Kingdom
Subjects: General principles

Tax Planning for Sportsmen

Professional sportsmanship is rarely a life-long career but it can be extremely lucrative. In addition to salary, an ever increasing proportion of the income of successful sportsmen comprises income from exploitation of their image rights by international brands. Also,[...]
Date: 22 Apr 2015
Jurisdiction:

Confidentiality & Exchange of Information - Geneva launch summary

Roy Saunders rounds-up the European Branch launch from Geneva, where the topic of Confidentiality & Exchange of Information generated an excellent discussion. [...]
Date: 06 Mar 2015
Jurisdiction:

“Open all hours” – the UK approach to resident non-domiciliaries

Dmitry Zapol examines the resident but non-domiciled benefits of UK tax legislation which, despite what has been minor tinkering for wealthy beneficiaries of the system, has been around for decades and shows no sign of major new initiatives. The article also covers the[...]
Date: 19 Feb 2015
Jurisdiction: United Kingdom
Subjects: Personal taxation

"All Change" - State Aid and the BEPS Initiative in 2015

‘All Change’ shouts the guard at our local Baker Street station, and passengers have to leave the warmth and familiarity of the train they have been travelling on and stand on a cold, unfriendly platform waiting for the next train, uncertain of whether they will be able to get[...]
Date: 19 Feb 2015
Jurisdiction:

A Review of 2014 – Corporate Acquisitions and BEPS

Corporate acquisitions have returned with a vengeance in 2014 – the greatest number of deals since 2007. This is partly because the US and UK economies have recovered, partly because larger companies have amassed significant amounts of cash in the downturn and are now turning[...]
Date: 12 Dec 2014
Jurisdiction:
Subjects: General principles

Corporate Residence

The importance of determining corporate residence is that the taxing rights of any particular country are usually defined by reference to whether an entity is resident or non-resident. Depending upon the taxation policy of the country in question, residents will typically be[...]
Date: 09 Sep 2014
Jurisdiction: Israel
Subjects: Double taxation

Understanding Double Tax Treaties

The purpose of this article is to review double tax treaties with a view to gaining an understanding of what they are, how they operate, how they are interpreted and concentrate on the rationale behind them.[...]
Date: 31 Jul 2014
Jurisdiction:
Subjects: Double taxation

Politics and the BEPS Project

Base Erosion and Profit Shifting is a hot topic within the international tax community, spurred on by the G20 backed OECD initiative. The OECD has outlined a stringent time frame to implement recommendations. What are the other approaches that could be adopted?[...]
Date: 10 Dec 2013
Jurisdiction: United Kingdom

Country Overview - Russia

Date: 27 Sep 2013
Jurisdiction: Russia
Subjects: General principles

Debt v. Equity Financing

Date: 15 Aug 2013
Jurisdiction: General principles
Subjects: General principles

Beneficial Ownership

Date: 13 Aug 2013
Jurisdiction: General principles
Subjects: General principles

The Swiss/UK Tax Cooperation Agreement

Dmitry Zapol explains the new Swiss/UK Tax Cooperation Agreement that came into force on 1st January, 2013.[...]
Date: 04 Jul 2013
Subjects: General principles

International Investment in UK Real Estate

Roy Saunders examines the means and methods by which international investors can invest in UK real estate. [...]
Date: 04 Jul 2013
Jurisdiction: General
Subjects: Real estate

Holding Company Structures for Investment into Russia in Light of Recent Developments

Dmitry Zapol examines Russian holding structures in response to recent economic events in Cyprus.[...]
Date: 04 Jul 2013
Jurisdiction: CyprusRussia

Trusts - What Are They and Why Use Them?

Roy Saunders explains the principles behind trusts, how they apply to the client and how the wider acceptance across European jurisdictions of trusts as a financial vehicle is developing. Particular reference is made to Jersey as an example trust location.[...]
Date: 04 Jul 2013
Jurisdiction: JerseyGeneral