It is common for multinational companies to have foreign subsidiaries. Each subsidiary may have different purposes, such as representing the group aboard, holding intellectual properties, shares, and provide financing to the group. Having branches or subsidiaries outside the residence country can raise complex legal and tax issues, such as transfer pricing, recognition of the structure by source country, and the application of international tax treaties.
To successful international tax planning, it is important to have an understanding of the international tax law, the local tax law, and the tax practice and procedures of the countries involved, in particularly the necessary substance required in terms of office space, tangible assets and employees. Therefore, this work requires significant experience and training.
Our firm advice many organizations in establishing their international structures. In this context, we assist our clients by setting up company structures, determining transfer pricing in collaboration with specialized firms, negotiating tax rulings, and representing them in front of the tax authorities or the courts.
Do not hesitate to consult our tax experts who are happy to assist you with your international planning.