International taxation

Analysis of bilateral tax treaties

• Classification of income (dividends, interest, royalties, services, capital gains, etc.).
• Determination of tax residence and mechanisms to eliminate double taxation.
• Analysis of withholding tax rates, methods and applicable requirements.
• Assessment of permanent establishment risk and its tax impact.

Intragroup transactions and intercompany flows

• Review of intragroup transactions, including management fees, technical assistance, recharges, licences and intragroup financing.
• Analysis of substance, services actually provided and supporting evidence required.
• Tax and contractual alignment between invoicing, contracts, deliverables and accounting.
• Recommendations to mitigate risks and prepare supporting documentation.

Transfer pricing — documentation and compliance

• Preparation and updating of group and local transfer pricing documentation under international standards.
• Functional analysis (FAR), transaction mapping and pricing policies.
• Comparability and benchmarking studies and selection of the appropriate valuation method.
• Audit assistance: position papers, responses to requests and defence support.

Other international matters

• Tax structuring of cross-border operations, market entry, reorganisations and international services.
• Management of tax risks associated with international flows and documentary compliance.
• Review of tax impacts throughout the value chain, including supply chain, distribution and shared service centres.

Our added value

We prioritise a pragmatic, evidence-based approach: identifying risks, formalising contracts and required support, and preparing clear, robust and defensible documentation.