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
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: