AI for international tax work.

Tax Intelligence / Example case

Case context (Example matter 1 · UK individual with US dividends): Jordan Example, fictional client. Residence: United Kingdom. Income flow: US dividends. Documents: Client profile.

Research in context

Example matter 2 · UK and Singapore companies

If I move to Singapore, does my UK company stop being UK tax resident?

Not automatically.

• UK incorporation generally establishes UK tax residence, subject to exceptions. Source: HM Revenue & Customs: INTM120030 - Company residence: overview
• Singapore considers where the business is controlled and managed. Source: Inland Revenue Authority of Singapore: Tax Residency of a Company / Certificate of Residence
• If both countries treat the company as resident, assess the treaty position. Source: HM Revenue & Customs: Synthesised text of the Multilateral Instrument and the 1997 UK-Singapore Double Taxation Agreement — in force

Treaty explorer

• US–UK: 2001 + protocol. Evidence: U.S. Department of the Treasury: U.S.-U.K. income tax treaty, signed July 24, 2001, London; Internal Revenue Service: United Kingdom (UK) - Tax treaty documents
• UK–Singapore: 1997 + MLI. Evidence: HM Revenue & Customs: Synthesised text of the Multilateral Instrument and the 1997 UK-Singapore Double Taxation Agreement — in force
• Singapore–Australia: 1969 + MLI. Evidence: Inland Revenue Authority of Singapore: Singapore–Australia Double Taxation Agreement (1969) with MLI amendments

US–UK article index: 4 Residence, 7 Business profits, 10 Dividends, 11 Interest, 12 Royalties, 24 Double tax relief. Eligibility label: 23 · Limitation on benefits.

Payment illustration · Article 10: US payer → Dividend → UK beneficial owner.

Documents → tax forms

Complete forms from client data.

Bring the facts from a client case into the right fields, with the source and review trail beside them.

Example matter 1 · UK individual with US dividends

Example client documents: ID, Residence, Tax profile.

US tax form W-8BEN · Draft

Line 1: Name of individual

Jordan Example

Line 2: Country of citizenship

United Kingdom

Line 3: Permanent residence address

10 Example Road, London, United Kingdom

Line 9: Treaty residence

United Kingdom

Fictional UK individual. Selected fields only.

Official IRS form | IRS field instructions

Structures + scenarios

Explore the structure. Compare the outcome.

See how ownership, income flows and assumptions connect to the tax result.

Scenario workspace · Example matter 2 · UK and Singapore companies · Illustrative model

Alternative structure

• Ownership: Founder owns 100% of the UK company.
• Ownership: the UK company owns 100% of the proposed Singapore company.
• Payment route: the Singapore company pays a dividend to the UK company.

Analysis layers: Residence, PE, CFC, Withholding. Illustrative analysis layer, not a determination of liability.

Tax comparison

• Scenario A · Higher company rate: Synthetic 25% company rate on profit, then a 20% owner rate on the amount distributed.
• Scenario B · Equal rates: Synthetic 20% company rate on profit, then a 20% owner rate on the amount distributed.
• Scenario C · Lower company rate: Synthetic 10% company rate on profit, then a 25% owner rate on the amount distributed.

Synthetic rates, not country tax rates. Excludes withholding, credits and other taxes or costs.

Outputs + continuing intelligence

Keep the tax work up to date.

Use the report, retain the evidence and see what a changed fact affects.

Example report: International tax review

Example matter 2 · UK and Singapore companies

Question

Does moving management to Singapore end the UK company’s UK tax residence?

Research finding

Not automatically. UK incorporation can establish tax residence. Open the HMRC source

Model

Scenario C · Lower company rate: £94,500 net to owner on £140,000 assumed profit, using synthetic rates.

Selected scenario split: Company tax £14,000, Owner tax £31,500, Net to owner £94,500.

Sources: HM Revenue & Customs: INTM120030 - Company residence: overview; Inland Revenue Authority of Singapore: Tax Residency of a Company / Certificate of Residence; HM Revenue & Customs: Synthesised text of the Multilateral Instrument and the 1997 UK-Singapore Double Taxation Agreement — in force.

Change impact

Example client fact (Example matter 2 · UK and Singapore companies): Management location changed. Affected work:

1. Residence analysis. Why it is affected: The UK company’s residence analysis relied on where the business was managed. What to review: Reopen the residence layer: UK incorporation can still establish UK residence, while Singapore considers where the business is controlled and managed. Sources: HM Revenue & Customs: INTM120030 - Company residence: overview; Inland Revenue Authority of Singapore: Tax Residency of a Company / Certificate of Residence.
2. Treaty position. Why it is affected: If both countries could now treat the company as resident, the treaty position needs to be reassessed. What to review: Check the UK–Singapore treaty material for how dual residence is resolved for the relevant period. Sources: HM Revenue & Customs: Synthesised text of the Multilateral Instrument and the 1997 UK-Singapore Double Taxation Agreement — in force.
3. Saved calculation. Why it is affected: The saved scenario comparison assumed the earlier residence position. What to review: Confirm the assumptions before relying on the comparison; its rates are synthetic and its figures are illustrative.

Illustrative change event, not a determination of liability. Inspect the affected work

Obligations

Fictional case / example month

• Day 12: Return — Preparation and review
• Day 21: Payment — Tax payment workflow
• Day 28: Certificate — Supporting tax documentation

Illustrative dates; not statutory deadlines.

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