09.04.2025
Our specialists have prepared legal opinion for the international IT company intending to develop international group of companies for the purposes of expanding business in the United Kingdom, the United States, Switzerland, the Republic of Cyprus, Germany and some other countries.
The task was to analyse the contemplated companies group structuring as provided by the client from the tax point of view and to highlight main risks.
The research was focused on compliance of the structuring with international tax related treaties, especially, considering regulations of the Organisation for Economic Co-operation and Development and Double Tax Treaties governing, in particular, transfer pricing and the controlled foreign companies aspects. Moreover, internal tax regulations of the United Kingdom, the United States, Switzerland, the Republic of Cyprus, Germany, as well as International Financial Reporting Standards were also taken into consideration for the purposes of the advice.
During provision of the mentioned services, not only did we highlight main risks, but also suggested mitigation strategies and developed some alterations in the group setup.
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