International Corporate Taxation
The taxation of international businesses has its own framework and dynamics and calls for a high degree of specialization.
It is a field where national laws and rules intertwine with international regulations. A comprehensive analysis is vital to accurately assess the tax implications of choosing a business location or carrying out transactions with foreign counterparties.
The incidence of an international approach becomes apparent in light of the numerous diverse proposals jointly undertaken by the G20 and the OECD as regards BEPS Actions and the resulting network of Multilateral Conventions to speed up adoption of new rules established by OECD Inclusive Framework Member States. The dramatic pace of changes faces us with a new taxation structure focused on digital business (Pillar One) and taxation of multinational groups with a minimum global income tax of 15% per jurisdiction (Pillar Two), which is expected to become effective in 2023.
Our professional expertise and know-how ranges from assessing the tax effects of national (such as Income Tax and VAT) and local taxes on international transactions, to structuring and locating assets in holding entities of multinational groups.
It is a field where national laws and rules intertwine with international regulations. A comprehensive analysis is vital to accurately assess the tax implications of choosing a business location or carrying out transactions with foreign counterparties.
The incidence of an international approach becomes apparent in light of the numerous diverse proposals jointly undertaken by the G20 and the OECD as regards BEPS Actions and the resulting network of Multilateral Conventions to speed up adoption of new rules established by OECD Inclusive Framework Member States. The dramatic pace of changes faces us with a new taxation structure focused on digital business (Pillar One) and taxation of multinational groups with a minimum global income tax of 15% per jurisdiction (Pillar Two), which is expected to become effective in 2023.
Our professional expertise and know-how ranges from assessing the tax effects of national (such as Income Tax and VAT) and local taxes on international transactions, to structuring and locating assets in holding entities of multinational groups.
Our advisory services include, without limitation:
- Strategic advice considering effective taxation, based on the location of functions and transactions within a multinational group.
- International corporate reorganizations.
- Assistance in interpreting and applying Double Tax Conventions.
- Advice related to International Tax Planning, its scope and implications.
- Assistance in technology transfer.
- Final withholdings to foreign recipients.
- Treatment afforded to the exports of services, benefits if available, and tax burden.
- Assistance and negotiation of Mutual Agreement Procedures.
- Strategic assistance in tax audits and tax litigation.
Cecilia Goldemberg
