Cross Border Advice
Our advice covers:
- Cross Border Business Structures: We advise on the constituent features of a compliant structure for investments in the foreign country so that when the foreign investment is sold the foreign tax is minimal together with how best to structure the provision of loan finance, the right to use intellectual property or the receipt of dividends so that the foreign taxes deducted by the foreign in the country is reduced to the acceptable minimum.
- Cross Border Employee Services: We advise on the constituent features of a compliant structure for the provision of services by personnel or consultants travelling from the provider’s country so that taxes on the salary or on the fees in the country where the advice is delivered is minimal
As source materials for our advice, we analyse the tax laws in the resident and source countries, tax authority pronouncements and judicial authority decisions on the laws, the bi-lateral double taxation conventions together with the OECD and UN Model Conventions and the Commentary on both Models. We also analyse draft Reports published by those Committees on interpreting technical issues within the Conventions and the OECD/G20 BEPS proposals including the Multilateral and Bi-lateral Information Exchange Agreements and the proposed Common Reporting Standard and the US Intergovernmental FATCA Agreements and Peer Review Reports issued by the Global Forum on Transparency.