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Cases · Tax, finance & assurance · International tax planning & transfer pricing

Fund a new overseas subsidiary

How should we put money into our new subsidiary abroad: equity or a loan?

WONE Global compares equity, loan and other funding routes on tax, exchange control and repatriation, and documents the chosen route.

Countries in the typical case United Kingdom · Nigeria

The situation

What is happening

What is at stake

Funding the wrong way can trap cash, trigger tax or breach exchange-control rules.

A scenario

Engineering services companyMid-sized company · from United Kingdom · in Nigeria

It is funding a new Nigerian subsidiary and will need to bring the money back later.

Where it ends Money in, and a way to get it out.

A representative scenario of the work WONE Global coordinates, not a specific client’s matter.

Also asked as “Capitalising a foreign subsidiary”“Minimum share capital and funding rules abroad”

The solution

How WONE Global handles it

WONE Global compares equity, loan and other funding routes on tax, exchange control and repatriation, and documents the chosen route.

Usually led by Treasury and funding, with Tax and structuring, Banking and capital and Setting up and running a company.

Step by step, in the scenario

  1. Week 1WONE Global compares equity and loan routes.
  2. Week 2Exchange-control registration planned.
  3. Week 3Funds sent and documented.
  4. ThenRepatriation route kept open.

Timings are typical. They depend on the countries, the authorities involved and how quickly documents are available.

Decisions

The decisions involved

  1. 01Equity, loan or a mix
  2. 02Capital rules, thin-capitalisation and exchange controls
  3. 03How funds can come back later

Outcomes

What you receive

  • A funding structure for the subsidiary
  • Loan or subscription documents
  • Exchange-control filings where needed

This is a general guide. Your WONE Global professional confirms the work, timing and fees for your markets before anything starts.

Who handles it

Treasury and funding, market by market

The status of the lead service in the markets that matter for this case. A named WONE Global Partner acts under their own licence; where none is in place yet, WONE Global confirms availability before anything else.

  1. Nigeriain the typical case On request Availability confirmed before any work begins Bring a requirement →
  2. United Kingdomin the typical case On request Availability confirmed before any work begins Bring a requirement →
  3. Canada WONE Global Partner Haider Khan Fabers · Director of Advisory Services Brief this Partner →
  4. India On request Availability confirmed before any work begins Bring a requirement →
  5. Saudi Arabia On request Availability confirmed before any work begins Bring a requirement →
  6. Singapore On request Availability confirmed before any work begins Bring a requirement →
  7. United Arab Emirates On request Availability confirmed before any work begins Bring a requirement →
  8. United States On request Availability confirmed before any work begins Bring a requirement →

Other markets: WONE Global covers 100 countries. Name yours in the requirement →

Katherin Diaz VelillaBogotá · Colombia

WONE Global Capability Partner · Colombia

Katherin Diaz Velilla

Complete profile

Co-Founder · V&V Associates · Bogotá

International tax attorney and strategic advisor with 12+ years across Colombia's DIAN, Ministry of Finance, Senate, Presidency, and EY. Co-founder of V&V Asociados. Specializes in cross-border tax structuring, transfer…

Mauro Tejada RamonQuito · Ecuador

WONE Global Capability Partner · Ecuador

Mauro Tejada Ramon

Tax & Legal Partner · G&G Auditores Independientes & Lex Fiscal Corp · Quito

Professional with 20 years of experience in Tax Administration, performing functions in the managerial and tax administration fields. Experience related to the fiscal field in the main sectors of the economy: Banking, c…

Ulrike Berner, MBAMunich · Germany

WONE Global Capability Partner · Germany

Ulrike Berner, MBA

Managing Partner · BSP Berner Schaeffler & Partners GmbH · Munich

Ulrike Berner has been Managing Director and shareholder of BSP since 2021, leading the strategic direction, client relationships, and business development of the firm. She has extensive experience working with firms an…

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