International Taxation



  • Business Restructuring / Inbound and Outbound Operations
    • Designing an entry strategy
    • Evaluating alternative intermediate holding company jurisdictions
    • Strategy on international tax
      • Tax Treaty Interpretation
      • Permanent Establishment (PE) exposure
      • Attribution of profits to a PE
      • Structuring of revenue / capital flows e.g. Royalty, FTS, Dividend, Interest, Capital gains etc.
    • Exit planning
    • Understanding the link between Transfer Pricing and Permanent Establishment
    • Vetting the legal documentation from an income-tax and transfer pricing perspective to be in synch with the business strategy