International Tax

Your business is global, taxes stay local

The operational functions of your company (R&D, production, sales, etc.) have come to spread across a large number of domestic and international sites.

The tax regulations abroad differ significantly from the tax treatment in your home country. Application of constantly changing local-country rules and international tax conventions needs to be observed thoroughly.

Avoiding unnecessary taxes as a cost factor and reducing the tax quota is of central importance to your company.

The international projects of your company, e.g. in the sectors of machinery and plant construction business or e.g. in IT business, reach a high degree of tax complexity. From your experience you are well aware that only a service provider who is familiar with international project business can render competent tax service for this purpose. 

Our services in the sector of international tax

Tax structuring of international business

  • consulting with regard to the corporate structure: subsidiary versus permanent establishment
  • consulting with regard to the organization of sales structures: distributor, commission agent, agent
  • tax planning in relation to the structuring of cross-border intercompany activities (in collaboration with our Transfer Pricing team)

Optimization of holding structures with regard to

  • exemptions of dividend income or capital gains
  • deductibility of business expense and loss utilization within the group
  • avoidance of Controlled Foreign Companies taxation
  • reduction of withholding taxes
  • thin capitalization / earnings stripping rules

Withholding tax consulting and compliance

  • analysis of applicability of withholding tax re. technology contracts
  • advising on contractual tax clauses
  • obtaining exemption certificates, preparing applications for tax refund

Project-related consulting (e.g. in the machinery and plant construction sector)

  • quantification of taxes to be calculated in the bid price
  • project structuring with regard to the establishment or avoidance of a permanent establishment
  • profit allocation between head office and permanent establishment, both for taxation in the source country as well as for exemption/credit in the home country
  • avoidance of foreign VAT/GST as a cost factor
  • tax consulting concerning deployment of staff with regard to taxation on company level as well as on the expatriate's level (in collaboration with our Global Expatriate Services team)

Our consulting approach

Our team consists of specialists with extensive hands-on experience, partially gained in inhouse corporate tax departments. We understand your concerns and expectations. We develop our practical solutions in a succinct and readily comprehensible form and provide concrete proposals to help you implement our structuring concepts.

Our tax advice benefits from the combined knowledge of an integrated team of tax lawyers and accountants. We work closely with our specialists in M&A, Transfer Pricing, VAT/GST and Expatriate Tax Services. By making sure consideration of the interdependencies between these tax disciplines, we help to minimize the global company's effective tax rate.

Our team members are experienced projects managers who are accustomed to act as single point of contact for the client. They provide our clients with a harmonized and well-coordinated approach across various jurisdictions. The close cooperation, proven working relationships and team spirit between the WTS Alliance Members make our clients benefit from immediate access to the relevant experts in any of the countries involved.

We are not involved in audit work. Being an independent service provider without regulatory restrictions, we are able to deliver tax services in an efficient manner.

 

Nicolas Kypreos

Partner
Tel: +357 22 028700
Fax: +357 22 028709
nicolas.kypreos[at]wtscyprus.com

 


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