International Tax Advisory
Our client, a technology company headquartered in Singapore had subsidiaries in various countries and its employees working out of these jurisdictions to render services to its customers.
- Evaluation of Corporate Structure & Transaction Structure within the Group from an international tax and transfer pricing perspective.
- Providing insights into PE risk and POEM risk and best practices to mitigate such risks.
- Creation of inter-company agreement and secondment agreement templates for transactions within the Group
Given the presence of the employees in various countries, there was significant exposure of a Permanent Establishment risk in various countries. In addition to this, the founder executives of the Company also carried out certain management functions in various countries exposing the headquarters to a Place of Effective Management risk. Lack on inter-company agreements and back-up documents.
- Advisory Services: Provided a comprehensive advice on mitigation of potential PE and POEM risk for the group. Set up inter-company transaction structure and a secondment structure for the group.
- Agreements: Provided the group with tax compliant inter-company agreement templates and employee secondment templates.
- Documentation: Provided guidance on the documentation to me maintained by each group company from a transfer pricing and PE and POEM risk mitigation perspective.
- Strategic Support: We continue to offer on call support for corporate and international tax matters for the group.
- Enhanced compliance and reduced risk exposure: Mitigation of PE and POEM risks, ensuring adherence to international tax laws and regulations. Streamlined operations with the implementation of tax-compliant inter-company agreements and secondment structures, directly reducing tax exposures.
- Improved documentation: Ensured rigorous compliance with transfer pricing requirements and bolstering fiscal transparency.