Customs, VAT and income tax are all dealt with relatively painlessly within the EU but for UK-based companies doing business in Europe, they could become a real headache. The challenge lies not only in a heavier tax burden, but also in the complication of day-to-day business. This is part one of our Brexit series.
At this stage, the final terms of Brexit are only known to those with a crystal ball. But one thing seems clear: The European Union wants Britain to feel the impact of leaving the club – and the UK itself has set course for a hard Brexit. Our analysis of possible tax implications will therefore be based on the worst-case scenario: the UK assuming a third-country status without direct links to the EU.
These are the additional burdens that UK-based international companies will need to cope with:
Until now, the principle of the free movement of goods has applied between the UK and the rest of the EU. When the UK leaves the union, customs duties may be levied on goods. "Additional costs from customs duties for buyers and sellers are not the only issue this will cause," explains Tobias Kiehl, a tax advisor at Clostermann & Jasper Partnerschaft mbB in Bremen, an internationally oriented audit and tax consultancy firm. "A lot of additional effort will be required. Companies will need to deal with customs clearance and will need to train their staff and adjust their computer systems. In addition, timelines for processing and shipping will need to be recalculated from scratch." Some companies might be forced to set up customs warehouses in other countries to ensure that they can deliver goods to their customers on schedule. The temporary storage and associated administration will put a notable dent in the companies' profits.
Within the EU, a joint VAT directive is applied. This directive sets out the rules for the imposition of value added tax among EU member states. In practical terms, this means that whenever VAT is applicable in cross-border transactions between EU countries, the tax treatment is uniform across the EU and results in a neutral tax liability. When it leaves the EU, the UK will be able to completely overhaul its VAT legislation, as the country will no longer be bound by the rules of the European VAT directive. But even if the current UK VAT rules remain in place, there will be negative consequences. VAT and the deduction of input tax are systematically coordinated and aligned for all EU-internal matters – but not for scenarios involving third countries. This poses significant risks to companies, because liquid funds could get tied up for prolonged periods of time. In addition, all affected parties face substantial legal uncertainty while the legal framework of the new UK–EU relationship remains unclear, which could greatly hinder day-to-day business.
The EU has also established successful mechanisms to prevent multiple taxation with regard to income tax, such as the Parent-Subsidiary Directive. This establishes, for instance, that a subsidiary can generally distribute profits to its parent company without any tax being withheld at source. This rule may no longer apply in future. Until new rules are in place, the applicable legal basis would be the existing double taxation treaty between Germany and the UK, which stipulates a 5 per cent rate of withholding tax.
As a rule, companies within the EU can reorganise their corporate structure as they wish, without concerns about possible negative tax implications. One of the key frameworks in this context is the EU Merger Directive. However, this might change after Brexit. Once this directive no longer applies, restructuring measures such as a relocation of a company's registered office, a change of parent company or subsidiaries or a change of legal form would lead to immediate negative tax consequences without any corresponding inflow of liquidity. This is because in these types of cross-border transaction with non-EU countries, companies are forced to utilise their hidden reserves (gains on capital invested, for example, in properties or long-term equity investments), because the governments involved would immediately charge tax on the hidden reserves that fall into their respective jurisdiction.
Tariffs, VAT and income tax, modification of corporate structures – these factors inflict a financial burden on companies, but not only in the form of new taxes and levies, but also through new and labour-intensive processes. "Companies will have to adjust their computer systems and will constantly need to consider two legal systems – German law and UK law," explains tax advisor Tobias Kiehl. "This means they will be slower, less flexible and subject to greater constraints." On top of this, there will be a lengthy period of uncertainty until all agreements have been negotiated. This could take many years.
Instead of waiting and hoping for the best, you should act now. Here are some practical tips:
What market do I want to sell in? Who do I want to target? Where are my customers based? Once you know your current and future target group, you can make a well-founded decision about where your company should be based in future. If you require access to the European market, setting up on the continent will be your safest option.
Will the current company structure still be suitable if customs duties and VAT are levied or handled in a different way? Might it be necessary to relocate production?
Where are your employees from? Will they remain available to you in future or are they affected by the loss of free movement and tied to continental Europe? Companies need to review the applicable labour law and analyse the labour market.
Will I still be able to repatriate profits without problems? New tax withholding rules could cut your profits significantly. Companies should prepare for this at an early stage.
If any of the above issues seem relevant to your company, it may be time to start seriously considering a change of location. You will probably have questions around taxation, setting up business and corporate structures, and there are many options to consider and choices to be made. We can support you on this journey and can put you in touch with competent professionals from different fields to discuss all of your questions.
As a location, Bremen offers everything you could wish for: a central position in Europe, with close links to the sea and other waterways, nearby airports that provide connections to all major European transport hubs and strong local infrastructure that makes it easy to get around. And on top of all this, highly-trained staff and internationally-oriented partners are ready to tackle your challenges with you.
The founders of Mac Panther Materials, two brothers from Bremen, produce an open-cell metal foam for use in a number of different applications. Its secret lies in the production process that is based on a brilliant and yet simple idea.
An engine under the bonnet drives the wheels – this is the configuration that has been powering cars for over a hundred years. However, wheel hub motors – i.e. motors in the hub of the wheel, not under the bonnet – promise many advantages. Electric drive systems make this possible.
The digital revolution has reached every branch of industry. Many of the technological trends associated with the Industrial Internet of Things originated in Silicon Valley. Rene van den Hoevel, managing director of the German American Chamber of Commerce in San Francisco, and Christoph Ranze, managing director of encoway GmbH and executive board member of the association bremen digitalmedia, explain why it is not only large corporations who should be looking closely at the epicentre of technological advancement.
Almost half of all coffee beans imported into Germany pass through Bremen’s ports. Coffee roasters such as Lloyd Caffee and Cross Coffee have helped to cement the image of Bremen as Germany’s coffee capital.
In the space of just a few years, the maritime city of Bremerhaven has developed into a service centre for the seafaring and shipbuilding industry. At the centre of it all is the company German Dry Docks, whose managing director, Guido Försterling, has already heralded the era of ‘seafaring 4.0’.
Bionics is the application of forms and functions found in nature to technology. Marine biologist Dr Christian Hamm and his team of researchers in Bremerhaven are leading figures in this field thanks to ELiSE. They are particularly interested in the tiny, yet incredibly complex, diatoms – nature’s experts in lightweight construction.
How will Brexit affect the trading of goods between the UK and the EU? Our guest contributor Anja Markmann, who is responsible for customs and international trade law at Bremen Chamber of Commerce, explains what is likely to change from April 2019 onwards.
A new process has been attracting attention in the food industry. Developed by the Bremerhaven Institute for Food Technology and Bioprocess Engineering, the new method enables deep frozen fish to be defrosted in record time. And the fish tastes as fresh as the day it was caught.
For over 15 years, Jacobs University in Bremen has attracted young, talented individuals from all over the world. Students from 106 countries make up a community that contributes to academic achievement and produces graduates that are highly sought after by companies.
Fiona Moore is originally from Burton-on-Trent, near Birmingham, and now works as a freelance translator in Bremen. She fell in love with Bremen in her early twenties. That was back in 2000, but 17 years later she is still as enchanted by the city as she was on the first day. She tells us about settling in Bremen, about her family and about being fortunate to have found a home in here.
Photography studios, workshops and professional kitchens are rarely fully occupied round the clock. So why not let others share them? The german start-up Craftspace brings together providers of production spaces with entrepreneurs, small business owners and artists on a single online platform. It’s an arrangement that benefits everyone.
It’s an adventure playground for kids, an idyllic sanctuary for couples, and a quiet retreat for those looking to escape from stress – from joggers and Nordic walkers to lovers of nature and culture, the Bürgerpark in the centre of Bremen has something for everyone. For the last 150 years, this protected heritage site in the centre of Bremen has relied solely on the support of donations to keep it open and well-maintained.
A great deal of manual labour goes into aircraft construction. Despite this – or perhaps even because of it – Airbus is changing its approach to make increased use of digital technologies. It’s also researching the applications of new manufacturing technologies such as 3D printing. And not a moment too soon, as Airbus’ site manager in Bremen, Dr André Walter, explains in our interview.
GeoSea, a subsidiary of the Belgian DEME group, is helping to construct of some of the largest offshore wind farms in the German North Sea – and in Bremen, the company has found the ideal location to carry out its work.
Art, design and people with disabilities make up the fascinating focus of the work of two young designers from Bremen. Working together with employees from community-based workshops, they develop and improve on designs for handmade products – and are continually thrilled by the potential they see in their co-designers.
Environmentally friendly manufacturing and ethical standards are the principles on which the fair trade clothing sector is based. Leela Cotton, a successful German-Turkish textile company, produces clothes for children and adults that are not only stylish, but also make a positive contribution to the environment in the way they are manufactured.
Why have so many IT companies chosen to establish themselves in Bremen? We asked five key business figures and researchers from various organisations to tell us what makes the city such an attractive location for the IT sector.
3D imaging with millimetre accuracy for underwater industrial activities and deep sea exploration – company founder Jakob Schwendner has a very clear goal. The first prototype of a camera with brand new sensor technology was built in Canada and presented to industry professionals at the Ocean Business conference in Southampton, United Kingdom, in April.
The Bremen Hansalinie Industrial Estate is a successful business park that is currently undergoing expansion. Several major logistics companies have based themselves here, developing increasingly sophisticated processes that aim to optimise just-in-sequence production for the automotive industry.
Of all the states in Germany, Bremen has the highest density of major research institutions in relation to its population – a fact that also benefits those who study there. It offers a range of international education opportunities for prospective academics with strong practical relevance and research activities that span a diverse range of fields.
Weatherproof displays for transport services, and screens that don’t produce glare in bright sunlight – these are just some of the devices provided by AlfaNet Computer und Electronic Handels GmbH, a Bremen-based company founded nearly 25 years ago by Thomas Lie.
They came, they saw, they marvelled – Chinese business people in Bremen visited the Mercedes-Benz plant and were surprised to find that an automotive manufacturer with a vast robot workforce was also Bremen’s largest employer, with just under 13,000 (human) employees. But where do they all work?
Three continents, four countries, and Bremen at the centre of it all – a start-up could hardly be more international. The young entrepreneurs Ahmed Cheema and Stefan Kuzmanovski want to make sustainable manufacturing and the use of ethically sourced materials standard practice.
Bremen: Down-to-earth, yet always ready to surprise you. An attractive place to live, a city through which we can move easily and without stress – on foot along the river Weser, on two wheels through the many parks, or by tram through the city centre. People from different cities and countries tell us why they fell in love with Bremen and have made their lives here.
Lighter, more bespoke and more intricate: for companies open to new ideas in manufacturing and construction, metal parts produced by 3D printers present an economic alternative to conventional die cutting, rolling and milling. Leading the way is Materialise, a company with its own metal printing plant in Bremen.
Bremen has been twinned with the city of Dalian in north-eastern China since 1985. Find out more about the similarities and connections that the two port cities share.
Up to now, cricket has been very much a niche sport in Germany. But that is changing. In Bremen, a woman is calling the shots in this male-dominated sport – with great success. Her men’s team are the 2016 German cricket champions.
Wearables and smart glasses provide hands-free digital information. A visit at the headquarter of the global market leader for Industrial Wearable Computing, Ubimax in Bremen.
In 2016, companies invested a combined total of €229 million in the federal state of Bremen. Where do these investors hail from, how many jobs have they created, and what is their line of business? Our infographics provide an overview.
How will the UK’s impending exit from the EU affect the logistics sector? Günther Hörbst, Managing Director of the Via Bremen Foundation, on the economic links between the United Kingdom and the EU
The Chinese designer Haoyu Li combines his German design degree with Chinese business acumen. Now he is opening a design office in Bremen, with the aim of making it easier for Chinese products to enter the German market, and to bring German brands to China.
The colours of the local football team are not the only thing that's green about Bremen, as you'll see when you take a stroll around its parks and open spaces. A look at the statistics shows that Bremen is not only Germany's tenth-largest city, it is also its third-greenest, offering plenty of space to enjoy nature.
Keen to remain in Bremen? Then why not combine residency status with self-employment? Manuel Kühn from Bremeninvest’s welcome service knows all about how a start-up could allow British citizens to beat Brexit and kill two birds with one stone.
The high standard of logistical expertise in the state of Bremen functioned as a key to open doors, making this a successful year for Bremen. 2016’s successes were marked by automobiles and steel, welcoming ambitious international companies.
From initial idea to successful move. Andreas Gerber, who heads up the international relocation team at Bremeninvest, knows what international companies need to do to set up a business in Bremen. Here he tells us about the most important steps on the ...
Hard facts take top priority when it comes to the choice of location for international or domestic businesses. But the faster we feel comfortable outside the workplace in the everyday routines and culture of a foreign country, the sooner we feel at home. In addition to trade, science – and of course its port, Bremen has plenty to offer when it comes to quality of life.
BLG LOGISTICS GROUP AG & Co. KG’s AutoTerminal in Bremerhaven is a record-breaking automotive hub. Every year, the terminal handles some 2.3 million vehicles. But that’s not all.
Going it alone is rarely an easy option. Co-working enables entrepreneurs to work in a shared space and experience the benefits and synergies that come with this. There are nine co-working spaces in Bremen – which one is right for you?
Permits and authorisations, a mountain of applications and a language barrier too. These are just some of the difficulties you face when starting a business abroad. Luckily, an advice centre opened in Bremen in early 2015 that can help you through the jungle: Bremeninvest’s welcome service.
Geographical distance and cultural differences make it hard to relocate or start up a company in another country. Luckily, help is at hand from the team at the World Trade Center (WTC) in Bremen. They'll do all they can to make your international business a success.
In December 2016 ministers from the European Space Agency (ESA) member states met to determine the roadmap for the European space sector for the years ahead. Baden-Württemberg, Bavaria and Bremen submitted joint recommendations. In the following interview Dr Peter Vits, Bremen's State Coordinator for the Space Sector, talks about Bremen's strengths and opportunities.
The sky is not the limit, at least not in Bremen. All parts of the aerospace sector are represented in the city, from R&D to production. Aeroplane wings, Ariane rockets and Galileo satellites – Bremen is one of the leading locations in the international aerospace industry. Here are five factors behind Bremen’s story of success.
In 2015 Bremen won the right to host the International Astronautical Congress for the second time, after having successfully held the event in 2003. Its bid was the result of a collaboration between the Bremen regional government and Bremen’s space industry and space research sector. Event partners include the Federal Ministry for Economic Affairs and Energy and the German Aerospace Centre.
The Bremen region has long been a pioneer in electric mobility and is now set to enjoy further success after Mercedes-Benz and Borgward announced that they will be making electric vehicles in the city.
Bremen knows how to make cars: the Mercedes-Benz plant by the Weser river has been in operation for almost 40 years, is the focal point of the city’s automotive industry and automotive clusters, and is now the company’s biggest global facility in terms of vehicle production numbers. Reason enough for an ever-growing number of suppliers and logistics firms to base themselves in Bremen.
Sometimes you have to learn from other people's mistakes and trust your instincts. That is what Muhammad-Farhan Aslam believed when he took over his father's business. Not only did he change the business model, but he also shelved his own plans to move to England. Instead he stayed in Bremen. And it turned out to be one of many good decisions that he made.
For 30 years, the Cargo Distribution Centre in Bremen has delivered excellence – as an investment location and a logistics hub. Today more than 150 companies employing approximately 8,000 people are based at the site. It offers direct links to the ports, the autobahn and has a close proximity to Bremen City Airport.
Language barriers, unfamiliar legal and fiscal systems, qualifications that need to be recognised. There are many additional hurdles that entrepreneurs have to overcome when setting up a new branch or a new company in a different country. Bremeninvest is committed to offering you advice and support from the outset.
You might expect a Bremen-based company specialising in innovative instruments and implants for spinal surgery to be located at the Technology Park. But you'd be wrong. NuVasive Germany GmbH has its head office at the heart of the city centre next to Wallanlagen Park. Now employing a team of 44 people, the company generates annual revenue of more than €10 million – a figure that looks set to rise.
David Zhou came to Bremen three years ago with the aim of conquering the market – and a new continent – with LEDs. He started his business selling LED lighting and electronics at the World Trade Centre at Bremen Airport and has gradually built it up over the past few years.