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International tax


Our international tax group provides tax structuring assistance to multinational businesses around the world, working closely with our clients to identify and implement efficient legal structures for their expanding international operations.

“They have a homogenous approach across the firm with a standardised and high-quality set-up that knits together separate cultures.” Chambers Global, 2015

Whether it involves a real estate investment fund seeking to undertake investments outside its home country, a manufacturing operation establishing factories overseas, a mining company proposing a new operation in a foreign company or a financial institution examining overseas expansion opportunities, our dedicated tax practitioners have the industry sector knowledge and global reach to traverse domestic and international tax regulations affecting clients’ businesses.

Our experience covers the full range of international structuring issues, including advising on the most appropriate offshore holding company structure and the use of international IP holding companies and global employment companies.  

Our areas of work include

  • anti-avoidance regimes
  • BEPS
  • capitalisation
  • choice of structure
  • income deferral
  • intellectual property
  • international funds
  • joint ventures
  • permanent establishment and branch taxation
  • profit allocation
  • resident country taxation
  • source country taxation
  • tax incentives
  • tax and investment treaties
  • transfer pricing
  • withholding taxes.

Our recent experience

  • Providing tax advice on the establishment of an international fund investing in mining services companies and mining operations in the US and Australasia.
  • Preparing a tax plan for a fund manager on the establishment of an offshore company providing management and advisory services to funds established in Australia and Singapore.
  • Advising a foreign investor on the formation of a tax preferred investment structure to facilitate investment in real estate in Australia or the US.
  • Advising on inbound US energy related structures for upstream, midstream and downstream activities.