Restructuring processes within groups. Analysis of the tax consequences. Comprehensive legal support. Transfer pricing and the APA procedure.
International group business restructurings. Transfer pricing. APA procedure
Efficiency in conducting business at the international level requires a well-thought-out corporate structure which allows for effective management of affiliated entities as well as for cost minimizing. Entities deciding to expand abroad are not always structured efficiently enough to achieve their business goals. This often stems from decisions taken ad hoc – being a result of the current needs or the response to on-going changes. In the long run, such actions are not optimal and may trigger additional costs (including tax).
At the same time, in the world of the dynamically evolving tax provisions aiming at counteracting tax avoidance and tightening up tax provisions (i.a. permanent establishment and beneficial ownership clauses), the reasonable action to be taken is to structure the business operations adequately at the international level. The optimal shape of the structure requires a complex approach that would take into account various factors, including but not limited to: the scope of activity of the given entity on the particular markets, the investment plans or the expected cash flows.
In the case of international business restructuring, it is crucial to confirm the consequences of the conducted operations with the local advisors in all tax jurisdictions involved. However, the process of coordinating the cooperation of various advisors may appear difficult and time-consuming.
Therefore, the International Corporate Tax Team offers its Clients the following services:
- review and evaluation of the current structure,
- advisory services with regard to the possible modifications of the structure,
- comprehensive implementation of the international business restructuring (including legal, tax and accounting issues),
- coordination of the advisory teams from other countries,
- securing the international structures from the tax perspective (e.g. in the way of obtaining individual tax rulings, APA procedure, tax advance rulings).
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