International Tax & Transfer Pricing

When companies operate across borders or have a presence in multiple jurisdictions, complying with local tax laws and ensuring that they meet prescribed reporting requirements can prove to be a complicated and onerous task. Local market knowledge from specialist advisors is required and advised.

Given our extensive network of offices around the globe, our team is ideally suited to serve large multinationals and other global companies that need on the ground expertise in multiple jurisdictions. We also provide newly formed companies with tax-efficient structuring services as they embark on international expansion. Our network allows us to have a clear view of both local and global trends.

We are valued for our deep technical expertise and insights into the cross-border activity of organisations. We can help you achieve your objectives.

Our services include:

• Advising on the tax implications of financing arrangements and capital structures.
• Assessing effective management risks and cross-border tax residency considerations.
• Evaluating the tax implications of international and cross-border transactions.
• Identifying and mitigating Controlled Foreign Company (CFC) risks.
• Advising on the design and implementation of new group structures.
• Reviewing and enhancing the tax efficiency of existing group structures.
• Assessing tax nexus and permanent establishment risks across jurisdictions.
• Developing, drafting, and reviewing transfer pricing policies and documentation frameworks.
• Performing transfer pricing benchmarking studies and economic analyses.
• Advising on the optimal pricing of intercompany transactions.
• Preparing Country-by-Country (CbC) reports and related disclosures.
• Supporting compliance with the OECD Pillar Two Global Anti-Base Erosion (GloBE) Rules, including effective tax rate calculations and reporting obligations.
• Managing the preparation and submission of required tax and transfer pricing documentation to revenue authorities.
• Assisting clients with transfer pricing audits, enquiries, and dispute resolution processes.
• Preparing and supporting Advanced Pricing Agreement (APA) applications and negotiations with tax authorities.

 
An effective international tax strategy requires not only consideration of domestic tax rules and transfer pricing requirements, but also a thorough understanding of the relief available under Double Taxation Agreements (DTAs). Treaty provisions can significantly influence the overall tax cost of cross-border investments, financing arrangements, and intellectual property structures by reducing withholding taxes on dividends, interest, and royalties. The following DTA map provides a comparative overview of treaty withholding tax rates across key jurisdictions, highlighting opportunities, trends, and potential considerations for multinational groups when structuring international operations and transactions.