International Tax

Today business is global. For businesses to grow and compete they need to develop internationally. Tax and Revenue authorities around the world are getting
more sophisticated; they share information both on taxpayers and in developing tax laws.
Companies with international plans and operations need to be fully informed. They need tax professionals who can provide a combination of local attention and global capabilities.

Braxton Alliance, through its membership of independent professional
member firms, can provide you with the necessary proactive advice and support.

Braxton Alliance member firms international tax service teams can work together to plan for and provide a wide range of opportunities for both inbound and outbound
businesses and corporations. They also offer services to those executives whose careers take them around the world and for individuals who wish to migrate to
another tax jurisdiction.

INTERNATIONAL TAX PLANNING TAKES MANY FORMS, INCLUDING THE
FOLLOWING:

• Tax Return Compliance
The approach includes running a ‘tax check up‘ on the business. The check up involves reviewing the previous years’ tax returns with management and is aimed at identifying areas for potential tax savings. This risk management will include looking at the overall tax cost to a company of doing business overseas.

• Tax Treaty Interpretation
Many international tax questions require careful analysis of multiple tax treaties. Only professionals well-versed in reading and interpreting tax treaties can provide tax optimization strategies. Countries are now renegotiating treaties more regularly
bringing in additional anti avoidance provisions and the potential to connect tax across borders.
• Transfer Pricing issues
Transfer pricing is not only a compliance requirement, but proper multinational planning can save world-wide taxes. Most major trading nations have complex documentation requirements and penalties for non-compliance.

• Export Tax Incentives
Knowing about and understanding export tax incentives can make exporting even more profitable.

• Corporate Reorganisation: Holding, Royalty and Financing Structures
Without proper corporate tax structuring, companies doing business and having subsidiaries in foreign jurisdictions may be structured inefficiently, thereby
giving rise to a significant increase in their overall tax burden. Braxton Alliance’s member firms can review existing structures and propose positive changes.

INTERNATIONAL TAX  BOARD
Braxton Alliance has a dedicated International Tax Board comprising of committed international tax experts representing Braxton Alliance member firms with the core focus
on the development of tax services within the alliance.

MULTINATIONAL BUSINESS : A WORLD OF OPPORTUNITIES – AND
INTERNATIONAL TAX ISSUES

Today’s global economy has created tremendous opportunities for conducting business worldwide. But as more and more goods, services and intangibles are transferred across national borders, companies must contend with growing challenges by many countries
tax authorities. Any time related parties on different sides of international borders conduct business, the taxing authorities from both countries will insist on taxing their fair share of the income.

TRANSFER PRICING

Transfer pricing is the valuation of goods, services and charges for the use of intangibles, traded across national borders.

Research shows multinational companies consider transfer pricing the most important international tax issue facing their firms over the next several years. Yet most companies view transfer pricing chiefly as a compliance exercise.Braxton Alliance, through its
member firms, can help you turn Transfer Pricing into a strategic advantage. By guiding you in using transfer pricing as a core management tool, Braxton Alliance members can help your multinational firm move beyond simply avoiding the threat of double taxation.

Let member firms expert teams turn your transfer pricing strategy into a real competitive advantage and help you deal with the various taxing authorities so that you can
focus on your business objectives.

IS YOUR COMPANY PREPARED FOR A
TRANSFER TAX AUDIT?

A recent survey of multinational companies found there is a 50% chance of having to defend profits in a transfer pricing examination anywhere in the world. In cases involving adjustments, nearly half the firms reported that transfer pricing adjustments resulted in
double taxation.

Transfer pricing is one of the most disputable arenas of international tax. If your firm faced a transfer tax audit, how well would you be able to defend your profits to authorities? Instead, let the Braxton Alliance association help you make transfer pricing part of your
global strategic planning. Taking a proactive approach to transfer pricing can minimize your firms worldwide taxes, coordinate your global business strategy and improve profitability.

Transfer Pricing is a dynamic issue. For example, the strict US-initiated transfer pricing model is quickly spreading to other countries world-wide and adding to the strain multinational companies face. An integrated global documentation approach to transfer
pricing can help companies successfully compete while minimizing the risk of double taxation.

How can Braxton Alliance help?
The Transfer Pricing experts within the Braxton Alliance association will work with you to develop a transfer pricing strategy suited to your multinational company. Your objectives will depend upon your firms overall structure and international tax planning position. Or if most of your company’s transactions are between high-tax jurisdictions, it may be more important to minimize the chance of double taxation.

Additionally, your Braxton Alliance team will prepare the documentation necessary to prevent any transfer pricing penalties in the event of an adjustment upon audit.

Your Braxton Alliance team will assist in defining your strategy, helping you evaluate the many factors affecting your transfer pricing policy – including the dispute resolution forum you prefer. You may choose to resolve potential disputes by obtaining an Advance
Pricing Agreement (“APA”), in which case your approach should be tailored to the Tax Authorities’ current APA process. Or if your company expects to resolve transfer pricing disputes through competent authority, your analysis should focus on methods
most likely to be acceptable to both sides.

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