Recent major developments in international tax regulations have drastically reshaped the global tax landscape for companies operating in multiple jurisdictions with more and more changes coming each year. Therefore, particular care should be taken when structuring cross-border transactions.
International tax issues are taking on greater significance for companies operating throughout the world. It is vital to manage your cross-border activity from an international tax standpoint, as well as to ensure compliance with legislative and regulatory requirements across different jurisdictions.
We have an advanced knowledge which enables us to provide you with international tax solutions that are tailored to specific needs of your business. We are delighted to offer you services in case:
and many others...
We are ready to provide you with a wide range of complex solutions drawing on profound expertise of international taxation matters and benefit from our extensive global network of tax professionals:
Assessment of risks related to place of effective management and creation of permanent establishments
Advising upon planning of the financial flows, elaboration of operational, holding, financial and IP structures and modelling related tax burden
Reviewing group structures and identifying their weak spots in light of the latest tax initiatives in Ukraine and across the globe
Elaboration of a defense file to support the eligibility for reduced tax rates and other tax treaty benefits, including evidencing the beneficial owner status and compliance with the principal purpose test
Support in set-up and tuning of internal bank procedures to comply with the initiatives on tax information exchange (FATCA, CRS)
Identification of issues worth solving via mutual agreement procedures and assistance with related practical matters
Comparison of options for financing the business
Modeling the tax impact of CFC rules on the tax liabilities of the Ukrainian controlling person
Pre- and post-M&A structuring