International Corporate Taxation
International taxation requires a high degree of specialization due to its regulatory complexity and the constant evolution of the global scenario.
The interaction between local and international rules poses relevant challenges in the interpretation of the tax impacts derived from cross-border operations and structures with presence in multiple jurisdictions.
The evolution of regulatory frameworks driven by the G20 and the OECD – such as BEPS Actions and multilateral conventions – requires companies to have a precise understanding of the new environment. In this context, recent developments on digital business taxation (Pillar One) and the 15% global minimum tax for multinational groups (Pillar Two), with projected application in several jurisdictions, stand out.
At Andersen we provide specialized advice on international tax planning, addressing both the effects of domestic taxes (such as income tax or VAT) and the implications of international transactions, asset localization and structuring of holdings in foreign entities.
To such end, we offer:
- Strategic advice on the effective taxation of the localization of functions and transactions within the multinational group.
- International corporate restructuring
- Assistance in the interpretation and application of double taxation treaties.
- Advice on International Tax Planning, scope and implications
- Technology transfer assistance
- Withholdings applicable to payments to beneficiaries abroad
- Treatment corresponding to the export of services, corresponding benefits and tax burdens
- Assistance and negotiation in Mutual Settlement Proceedings
- Strategic assistance in audits and litigation defenses
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