From multinationals with operations in several jurisdictions to small businesses planning their first business establishment abroad, our professional expertise in international tax planning provides in-depth analysis and effective solutions. Our cohesive international tax planning programs coordinate home and host country taxation in a cross-border context.
TRANSFER PRICING AND ADVANCE PRICING AGREEMENTS
The U.S. have enacted the most sophisticated body of transfer pricing regulations worldwide and the U.S. tax authorities have recently sought stricter enforcement with higher penalties, detailed documentation requirements, bilateral exchange of information, increased specialization and resources devoted to tax exams. The U.S. is not the only country concerned with transfer pricing issues that is why we will assist you in complying with transfer pricing rules worldwide. Unilateral and bilateral Advance Pricing Agreements with the tax authorities can provide valid alternative dispute resolution forums and the opportunity to resolve transfer pricing issues for past as well as future years in a cooperative context.
TAX TREATIES AND COMPETENT AUTHORITY
When it comes to applying or interpreting the benefits of double tax treaties we will provide you with expert assistance and consult with the U.S. and foreign Competent Authorities to obtain double tax relief.
PROFIT REPATRIATION STRATEGIES
We assist foreign-owned U.S. subsidiaries in evaluating alternatives for the tax-effective repatriation of U.S. earnings.
INTERNATIONAL ASSIGNMENT OF EXECUTIVES
Business executives are increasingly mobile internationally, our tax planning services for international assignments are a valid tool to implement cost-effective compensation packages.