International Corporate Taxation
The taxation of international business has its own framework and dynamics that require a high degree of specialization.
This is an environment in which the domestic regulations of each country coexist with international regulations that are essential for the correct interpretation of the scope of the tax consequences of business location and transactions with counterparties residing in other jurisdictions.
The impact of the international approach is very noticeable by virtue of the breadth and diversity of the proposals jointly undertaken by the G20 and the OECD based on the BEPS Actions and the consequent framework of Multilateral Agreements to speed up the adoption of the new guidelines by the countries that are part of the Inclusive Framework. The maelstrom of changes brings us face to face with the new structuring of taxation aimed at digital businesses (Pillar One) and the taxation by multinational groups of a minimum global income tax of 15% per jurisdiction (Pillar Two), which is projected to come into effect in 2023.
Our experience and professional solvency range from the assessment of the tax effects of international transactions before national taxes (such as income tax and VAT) and local taxes, as well as the structuring and localization of holdings in holding entities of a multinational group.
To such end, we offer:
- Strategic advice on the effective taxation of the location of functions and transactions within the multinational group.
- International corporate restructuring.
- Assistance in the interpretation and application of Double Taxation Agreements.
- Advice on International Tax Planning, scope and consequences.
- Assistance in technology transfer.
- Withholdings applicable to payments to foreign beneficiaries.
- Treatment corresponding to the export of services, corresponding benefits and tax charges.
- Assistance and negotiation in Mutual Agreement Procedures.
- Strategic assistance in audits and litigation defense.