Our advice covers:
- Related Party Transactions and Transfer Pricing: We advise on how to structure international trading transactions between related parties so that the pricing satisfies local and international arms’ length rules including drafting Transfer Pricing Reports.
- Double Tax Conventions: We advise on the constituent features of such international tax law concepts as ‘residence’, ‘business substance’ ,‘beneficial ownership’, ‘principal purpose’ and ‘non discrimination’ which must be met if bi-lateral double taxation convention benefits are to be available.
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.