International Tax Advisory

Holding company jurisdiction creating tax leakage you did not plan for: A holding structure established for operational reasons may be creating withholding tax costs and permanent establishment risk that a proper review would eliminate.

Permanent establishment risk in markets where you operate but are not incorporated: Employees or agents acting in a jurisdiction without a local entity may be creating an unintended taxable presence that accumulates unreported liability.

Pillar Two global minimum tax creating exposure you have not assessed: Groups approaching the EUR 750M threshold need to model their Pillar Two position now, not when the first top-up tax is due.

Effective tax rate higher than it should be: The gap between your headline tax rate and your effective rate often reflects structural inefficiencies that a review would identify and correct.

Intercompany transactions priced without analysis or documentation: Related party transactions priced without an arm's length analysis and supporting documentation are the primary trigger for transfer pricing audits and assessments.

Management fees charged without a coherent policy or contract: Intercompany management fees without documented services, a pricing policy and a signed agreement are routinely disallowed by tax authorities.

Commodity trades between related entities without benchmarking: Back-to-back trades between group entities in different jurisdictions without contemporaneous benchmarking create assessment risk in both countries.

Local file and master file not prepared by the filing deadline: Missing transfer pricing documentation triggers automatic penalties in most jurisdictions before the substance of the pricing is even examined.

Dividend flows not routed to access treaty benefits: Dividends paid directly rather than through an appropriate intermediate holding jurisdiction pay withholding tax that the treaty network would reduce or eliminate.

Treaty access claimed without substance to support it: Claiming treaty benefits without genuine substance in the treaty country creates reclassification risk under the principal purpose test in most modern treaties.

Withholding tax on interest and royalties not planned: Intercompany interest and royalty payments made without treaty planning pay withholding tax at source country rates that optimised structures would reduce.

CFC rules in home country not analysed for offshore structures: Controlled foreign company rules in France, the UK, or other home jurisdictions can attribute offshore profits to domestic shareholders, creating unexpected domestic tax.

Multi-jurisdiction trading groups with intercompany flows: Groups with entities across UAE, Europe and Asia managing back-to-back trades, management charges and intercompany financing between related parties.

HNWIs and family offices with international holding structures: Private clients with assets and business interests across multiple jurisdictions where the interaction between corporate and personal tax requires coordinated planning.

Businesses entering new markets or restructuring operations: Companies establishing new entities, restructuring group ownership or entering new jurisdictions where the tax implications need to be mapped before the structure is locked in.

Groups under transfer pricing scrutiny: Businesses that have received transfer pricing queries or assessments and need professional representation supported by proper documentation.