Tax strategy in a shifting global trade environment
As tech businesses scale internationally, few elements shape their growth prospects as significantly (or as quietly) as tax. Whether structuring IP ownership, navigating export controls or managing cross-border transactions, tax strategy is a key enabler of sustainable global expansion. Yet, in a world increasingly defined by geopolitical friction, digital regulation, and economic security, international tax planning is also becoming a source of risk exposure.
Transfer pricing and tax risk
From our position as advisers to high-growth tech groups, we see increasing pressure on transfer pricing policies as global trade dynamics shift. Authorities in key jurisdictions, including the US, India, and much of Europe, are taking a more assertive stance on how value is created and shared within international groups.
For tech companies with centralised IP and R&D functions, this means regularly reassessing whether intercompany recharges and value chains remain defensible in light of changing guidance and enforcement trends. Effective transfer pricing is no longer just about documentation, it's about embedding commercial alignment, substance and adaptability into the group’s operating model.
Pillar Two and recent G7 developments
Pillar Two, the OECD’s global minimum tax regime, continues to reshape how international expansion is planned. The large UK-headquartered tech groups within scope that have traditionally routed operations through low-tax jurisdictions now face leakage unless they adapt structures to meet minimum effective tax thresholds.
Encouragingly, the recent G7 agreement in June 2025 has brought greater stability to the landscape. The UK and its partners reached a common understanding on how Pillar Two can operate alongside the US minimum tax system, and crucially, helped secure the removal of a potentially damaging retaliatory tax measure (Section 899) from US legislation.
However, the underlying challenge remains as to how UK groups can remain globally competitive while aligning with international substance and transparency requirements. Leveraging domestic tax incentives such as R&D and the Patent Box will remain vital, but these must be integrated into a broader, compliant international strategy.
Supply chains and tax technology
Supply chains also have a growing tax dimension. More companies are investing in tools that improve transparency and traceability. But few realise that the same data could streamline customs duty and VAT compliance and even support ESG-linked tax reporting in due course. Getting tax and tech teams talking is an underrated competitive advantage.
National security and IP structuring
Export controls and national security rules are playing a growing role in how tech companies structure their international operations, which increasingly overlaps with tax planning.
For example, licensing technology or software across borders may be subject to export restrictions or sanctions. If IP is held in, or licensed to or from, a jurisdiction subject to national security concerns, it can trigger unexpected withholding tax, reporting obligations, or even restrictions on receiving payments.
Businesses need to ensure that tax and legal teams work together when structuring international IP ownership or intercompany licensing, to avoid not just tax leakage, but regulatory exposure as well.
Tax as a strategic driver - future-proof tax planning
In this environment, tax should no longer be viewed as a back-office compliance cost, but as a strategic lever that needs to be aligned with commercial, operational and legal decisions from the outset.
Looking ahead, as bilateral and digital trade agreements evolve, and as new tax transparency requirements emerge globally, the most resilient tech businesses will be those who invest early in joined-up strategies, where tax planning is embedded in the business model, not just bolted on after the fact.
At Moore Kingston Smith, we work with tech companies at every stage of growth, helping them future-proof global tax strategies and build the resilience needed to thrive in a disrupted world.
Shifting Currents: Tech, Trade, and Security
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Sabina Ciofu is Associate Director – International, running the International Policy and Trade Programme at techUK.
Based in Brussels, she leads our EU policy and engagement. She is also our lead on international trade policy, with a focus on digital trade chapter in FTAs, regulatory cooperation as well as broader engagement with the G7, G20, WTO and OECD.
As a transatlanticist at heart, Sabina is a GMF Marshall Memorial fellow and issue-lead on the EU-US Trade and Technology Council, within DigitalEurope.
Previously, she worked as Policy Advisor to a Member of the European Parliament for almost a decade, where she specialised in tech regulation, international trade and EU-US relations.
Sabina loves building communities and bringing people together. She is the founder of the Gentlewomen’s Club and co-organiser of the Young Professionals in Digital Policy. Previously, as a member of the World Economic Forum’s Global Shapers Community, she led several youth civic engagement and gender equality projects.
She sits on the Advisory Board of the University College London European Institute, Café Transatlantique, a network of women in transatlantic technology policy and The Nine, Brussels’ first members-only club designed for women.
Sabina holds an MA in War Studies from King’s College London and a BA in Classics from the University of Cambridge.
Policy Manager for International Policy and Trade, techUK
Daniel Clarke
Policy Manager for International Policy and Trade, techUK
Dan joined techUK as a Policy Manager for International Policy and Trade in March 2023.
Before techUK, Dan worked for data and consulting company GlobalData as an analyst of tech and geopolitics. He has also worked in public affairs, political polling, and has written freelance for the New Statesman and Investment Monitor.
Dan has a degree in MSc International Public Policy from University College London, and a BA Geography degree from the University of Sussex.
Outside of work, Dan is a big fan of football, cooking, going to see live music, and reading about international affairs.
Theo joined techUK in 2024 as EU Policy Manager. Based in Brussels, he works on our EU policy and engagement.
Theo is an experienced policy adviser who has helped connect EU and non-EU decision makers.
Prior to techUK, Theo worked at the EU delegation to Australia, the Israeli trade mission to the EU, and the City of London Corporation’s Brussels office. In his role, Theo ensures that techUK members are well-informed about EU policy, its origins, and its implications, while also facilitating valuable input to Brussels-based decision-makers.
Theo holds and LLM in International and European law, and an MA in European Studies, both from the University of Amsterdam.
Lewis' programmes cover a range of policy areas within Market Access (international trade regulation, sanctions and export controls, technical standards and product compliance, supply chains) and Consumer Tech (media and broadcast policy, consumer electronics, and connected home technology).
Prior to joining techUK, Lewis worked in government affairs and policy roles for international trade associations in Southeast Asia including the American Malaysian Chamber of Commerce and the European Chamber of Commerce in Cambodia.
He holds an undergraduate degree in Social and Political Sciences from the University of Cambridge and an MSc in Public Policy & Management from SOAS University of London.
Tess joined techUK as an Policy and Public Affairs Team Assistant in November of 2024. In this role, she supports areas such as administration, member communications and media content.
Before joining the Team, she gained experience working as an Intern in both campaign support for MPs and Councilors during the 2024 Local and General Election, and working for the Casimir Pulaski Foundation on defence and international secuirty. She has worked for multiple charities, on issues such as the climate crisis, educational inequality and Violence Against Women and Girls (VAWG). In 2023, Tess obtained her Bachelors of Arts in Politics and International Relations from the University of Nottingham.
