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Tax & International Structuring across borders
Tax and structuring for businesses, investments and deals that cross borders. Led by a WONE Global Partner where one is named. Elsewhere, WONE Global confirms on request whether a vetted Associate firm can act.
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Professional knowledge centre
Tax & International Structuring: how it works
International tax structuring is the work of deciding where a group's entities sit, how they are owned and financed, and how money moves between them, so that profit is taxed once, in the right place, at a rate the business can defend. It shapes decisions on whether to open a branch or a subsidiary, where to put a holding company, whether to fund a new market with debt or equity, how to price and invoice cross-border services, and what each entity must register for on day one. Since 2019 the room for manoeuvre has narrowed: anti-avoidance rules on controlled foreign companies, interest and hybrids are now standard in the EU, and large groups face a 15% global minimum tax. The practical goal is a structure with real substance that survives scrutiny in every country it touches.
Source-checked research88% of statements checked against a source99 checked against an official source23 checked against a secondary sourceChecked 2026-10-18Not yet professionally reviewed
Overview
Cross-border tax has two layers that behave differently. Direct taxes (corporate income tax, withholding tax, minimum top-up taxes) fall on profits and payments and depend on where entities are resident, where they have a taxable presence and what tax treaties say. Indirect taxes (VAT and GST) fall on transactions and depend on where a supply is treated as made; they are usually neutral for a fully taxable business but create cash-flow, registration and invoicing obligations that catch out new entrants.
The rules in this centre come from three sources that have to be read together: domestic law in each country, bilateral tax treaties, and international standards set through the OECD and, for EU Member States, binding directives. The EU Anti-Tax Avoidance Directive made interest limitation, controlled foreign company and exit tax rules mandatory across the EU from 2019 and 2020, its amending directive added hybrid mismatch rules, and the Pillar Two directive implements the 15% minimum tax for groups with revenue of EUR 750 million or more. Outside the EU, countries such as the UAE and Singapore have adopted their own domestic minimum top-up taxes, while the United States has negotiated a side-by-side arrangement.
For a founder or CFO, the useful questions are practical: which taxes will each entity pay and register for, what will be withheld when cash moves, which deductions are capped, whether low-taxed profits will be pulled back into the parent's tax net, and whether the group is close to the minimum tax threshold. The modules below explain each layer, with examples from India, the UAE, Saudi Arabia, Singapore, the UK, the US, Germany and France. Rates and dates are claims with sources; where we could not confirm a point on an official page, it is flagged as a gap.
Corporate tax residence
A company's tax residence decides which country may tax its worldwide profits and which treaties it can use. Most countries combine a test based on where a company is incorporated with a test based on where it is actually run, so a company formed in one country but managed from another can be resident in both. Treaties resolve that conflict with a tie-breaker, and since 2017 the OECD Model leaves the answer to negotiation between tax authorities rather than an automatic rule.
Sources for this topic · 9
- HM Revenue & Customs (GOV.UK) — International Manual INTM120040: The incorporation ruleChecked against an official source · checked 2026-10-18 · 1 statement
- HM Revenue & Customs (GOV.UK) — International Manual INTM120060: The case law rule: central management and controlChecked against an official source · checked 2026-10-18 · 1 statement
- HM Revenue & Customs (GOV.UK) — International Manual INTM120070: Treaty non-resident companiesChecked against an official source · checked 2026-10-18 · 2 statements
- HM Revenue & Customs (GOV.UK) — International Manual INTM120080: Treaty tie-breakers and self-assessmentChecked against an official source · checked 2026-10-18 · 1 statement
- HM Revenue & Customs (GOV.UK) — International Manual INTM120085: Standard treaty tie-breakersChecked against an official source · checked 2026-10-18 · 1 statement
- OECD — Model Tax Convention on Income and on Capital: Condensed Version 2017Checked against an official source · checked 2026-10-18 · 1 statement
- Income Tax Department, Government of India (CBDT) — UAE: Synthesised text of the India-UAE DTAA as modified by the MLIChecked against an official source · checked 2026-10-18 · 1 statement
- Income Tax Department, Government of India (CBDT) — Income-tax Act, 2025Checked against an official source · checked 2026-10-18 · 1 statement
- Income Tax Department, Government of India (CBDT) — CircularsChecked against an official source · checked 2026-10-18 · 2 statements
Questions on this topic
11 statements on corporate tax residence, 4 not yet checked against a source
Permanent establishment
A permanent establishment (PE) is the point at which a foreign company's activity in a country becomes taxable there. Under OECD-based treaties it arises through a fixed place of business, a dependent agent, or, where the treaty says so, a construction or service presence that lasts beyond a set period. Once a PE exists, the host country can tax the profits attributable to it as if it were a separate business.
Sources for this topic · 6
- HM Revenue & Customs (GOV.UK) — International Manual INTM264300: Domestic and treaty law: permanent establishment definitionChecked against an official source · checked 2026-10-18 · 5 statements
- HM Revenue & Customs (GOV.UK) — International Manual INTM264510: Dependent agent permanent establishment: agent acting on behalf of a non-resident enterpriseChecked against an official source · checked 2026-10-18 · 1 statement
- HM Revenue & Customs (GOV.UK) — International Manual INTM264530: Dependent agent permanent establishment: agent of independent statusChecked against an official source · checked 2026-10-18 · 1 statement
- HM Revenue & Customs (GOV.UK) — International Manual INTM264800: Domestic and treaty law: building site or construction or installation projectChecked against an official source · checked 2026-10-18 · 3 statements
- Income Tax Department, Government of India (CBDT) — UAE: Synthesised text of the India-UAE DTAA as modified by the MLIChecked against an official source · checked 2026-10-18 · 4 statements
- HM Revenue & Customs (GOV.UK) — International Manual INTM267160: Treaty provisions - Article 7 - interaction with domestic provisionsChecked against an official source · checked 2026-10-18 · 2 statements
Questions on this topic
16 statements on permanent establishment
Withholding tax and treaty rates
Withholding tax is collected by the payer when dividends, interest, royalties or service fees go to a non-resident. Domestic law sets the default rate; a treaty can cap it, but only if the recipient is resident in the treaty partner, is the beneficial owner, can prove both, and passes the treaty's anti-abuse rules. India's domestic rates are high and its treaty network is wide, so the gap is often material.
Sources for this topic · 10
- Income Tax Department, Government of India (CBDT) — FAQs on Interplay and Transition from the Income Tax Act, 1961 to the Income Tax Act, 2025Checked against an official source · checked 2026-10-18 · 3 statements
- Income Tax Department, Government of India (CBDT) — Income-tax Act, 2025 - Section 207: Tax on dividends, royalty and fees for technical service in case of foreign companiesChecked against an official source · checked 2026-10-18 · 1 statement
- Income Tax Department, Government of India (CBDT) — Tax Rates - DTAA v. Income-tax ActChecked against an official source · checked 2026-10-18 · 9 statements
- Income Tax Department, Government of India (CBDT) — UAE: Synthesised text of the India-UAE DTAA as modified by the MLIChecked against an official source · checked 2026-10-18 · 3 statements
- Taxmanagementindia.com (reproduction of treaty text) — DTAA - Comprehensive Agreement Singapore, Article 10 DividendsChecked against a secondary source · checked 2026-10-18 · 1 statement
- Internal Revenue Service (IRS) — NRA withholdingChecked against an official source · checked 2026-10-18 · 2 statements
- Internal Revenue Service (IRS) — United States income tax treaties - A to ZChecked against an official source · checked 2026-10-18 · 2 statements
- HM Revenue & Customs (GOV.UK) — Double Taxation Treaty Passport schemeChecked against an official source · checked 2026-10-18 · 1 statement
- Income Tax Department, Government of India (CBDT) — Income-tax Act, 2025Checked against an official source · checked 2026-10-18 · 1 statement
- OECD — Model Tax Convention on Income and on Capital: Condensed Version 2017Checked against an official source · checked 2026-10-18 · 1 statement
Questions on this topic
24 statements on withholding tax and treaty rates, 2 not yet checked against a source
Treaty access and anti-abuse rules
Having a treaty is not the same as being entitled to use it. Since the BEPS project most treaties carry a principal purpose test through the Multilateral Instrument (MLI), and US treaties rely on limitation on benefits rules; both deny benefits to arrangements set up mainly to obtain them. Real substance in the claimed country is what supports a claim.
Sources for this topic · 5
- Income Tax Department, Government of India (CBDT) — UAE: Synthesised text of the India-UAE DTAA as modified by the MLIChecked against an official source · checked 2026-10-18 · 5 statements
- HM Revenue & Customs (GOV.UK) — Multilateral Instrument and the 1997 Singapore-UK Double Taxation Agreement (synthesised text, in force)Checked against an official source · checked 2026-10-18 · 3 statements
- OECD — Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPSChecked against an official source · checked 2026-10-18 · 5 statements
- Income Tax Department, Government of India (CBDT) — UAE: Comprehensive AgreementsChecked against an official source · checked 2026-10-18 · 1 statement
- Internal Revenue Service (IRS) — United States income tax treaties - A to ZChecked against an official source · checked 2026-10-18 · 1 statement
Questions on this topic
15 statements on treaty access and anti-abuse rules, 5 not yet checked against a source
Transfer pricing
Transfer pricing rules require transactions between companies in the same group to be priced as if the parties were independent. Most tax authorities follow the OECD Transfer Pricing Guidelines, and large groups face a three-tier documentation standard: master file, local file and country-by-country report. Management fees and intra-group services are a frequent audit target because the payer must show a real benefit and an arm's length charge.
Sources for this topic · 7
- OECD — OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2022Checked against an official source · checked 2026-10-18 · 2 statements
- HM Revenue & Customs (GOV.UK) — International Manual INTM450010: Transfer pricing records: overviewChecked against an official source · checked 2026-10-18 · 3 statements
- HM Revenue & Customs (GOV.UK) — International Manual INTM450020: Transfer pricing records: who is in scope?Checked against an official source · checked 2026-10-18 · 1 statement
- Internal Revenue Service (IRS) — Country-by-country reportingChecked against an official source · checked 2026-10-18 · 1 statement
- Income Tax Department, Government of India (CBDT) — Transfer PricingChecked against an official source · checked 2026-10-18 · 8 statements
- Income Tax Department, Government of India (CBDT) — Annual Advance Pricing Agreement Report FY 2025-26Checked against an official source · checked 2026-10-18 · 3 statements
- OECD — Base erosion and profit shifting (BEPS)Checked against an official source · checked 2026-10-18 · 1 statement
Questions on this topic
19 statements on transfer pricing, 5 not yet checked against a source
VAT and GST on cross-border goods and services
VAT and GST are charged where a supply is treated as taking place, not where the supplier is based. For most business-to-business services the place of supply is the customer's country and the customer self-accounts under the reverse charge, but non-resident suppliers can still have to register, especially for consumer sales and goods held locally. Rates and invoicing rules differ sharply between markets, and real-time e-invoicing is spreading from Saudi Arabia and India to the EU, France, Germany and the UAE.
Sources for this topic · 15
- European Union (EUR-Lex) — Council Directive 2006/112/EC on the common system of value added tax (consolidated version 1 January 2024)Checked against an official source · checked 2026-10-18 · 2 statements
- European Commission (Your Europe) — Cross-border VATChecked against an official source · checked 2026-10-18 · 2 statements
- European Commission, Taxation and Customs Union — VAT ratesChecked against an official source · checked 2026-10-18 · 1 statement
- Bundesministerium der Justiz (gesetze-im-internet.de) — Umsatzsteuergesetz (UStG) § 12 SteuersätzeChecked against an official source · checked 2026-10-18 · 1 statement
- Bundesministerium der Justiz (gesetze-im-internet.de) — Umsatzsteuergesetz (UStG) § 27 Allgemeine ÜbergangsvorschriftenChecked against an official source · checked 2026-10-18 · 1 statement
- Ministère de l'Économie (economie.gouv.fr) — Facturation électronique entre entreprisesChecked against an official source · checked 2026-10-18 · 1 statement
- HM Revenue & Customs (GOV.UK) — VAT ratesChecked against an official source · checked 2026-10-18 · 1 statement
- HM Revenue & Customs (GOV.UK) — Register for VAT: when to registerChecked against an official source · checked 2026-10-18 · 2 statements
- HM Revenue & Customs (GOV.UK) — VAT place of supply of services (VAT Notice 741A)Checked against an official source · checked 2026-10-18 · 1 statement
- European Union (EUR-Lex) — Council Directive (EU) 2025/516 of 11 March 2025 amending Directive 2006/112/EC as regards VAT rules for the digital ageChecked against an official source · checked 2026-10-18 · 1 statement
- PwC Worldwide Tax Summaries — Saudi Arabia: Corporate - Other taxesChecked against a secondary source · checked 2026-10-18 · 1 statement
- Zakat, Tax and Customs Authority (ZATCA) — What is E-invoicingChecked against an official source · checked 2026-10-18 · 1 statement
- Baker McKenzie — United Arab Emirates: New e-invoicing rulesChecked against a secondary source · checked 2026-10-18 · 1 statement
- PwC Worldwide Tax Summaries — United Arab Emirates: Corporate - Other taxesChecked against a secondary source · checked 2026-10-18 · 2 statements
- PwC Worldwide Tax Summaries — India: Corporate - Other taxesChecked against a secondary source · checked 2026-10-18 · 5 statements
Questions on this topic
23 statements on vat and gst on cross-border goods and services
Controlled foreign companies and economic substance
Controlled foreign company (CFC) rules let a parent's country tax low-taxed profits of foreign subsidiaries before they are paid up as dividends. EU Member States must apply them under the Anti-Tax Avoidance Directive, and the United States has its own long-standing regimes. Substance (people, premises and decision-making where profits are booked) is what keeps a structure outside CFC rules and inside treaty and free-zone benefits.
Sources for this topic · 3
- European Union (EUR-Lex) — Council Directive (EU) 2016/1164 of 12 July 2016 laying down rules against tax avoidance practices that directly affect the functioning of the internal marketChecked against an official source · checked 2026-10-18 · 4 statements
- UAE Ministry of Finance — Ministry of Finance Announces Amendment to Cabinet Decision on Economic Substance RequirementsChecked against an official source · checked 2026-10-18 · 1 statement
- PwC Worldwide Tax Summaries — United Arab Emirates: Corporate - Taxes on corporate incomeChecked against a secondary source · checked 2026-10-18 · 1 statement
Questions on this topic
6 statements on controlled foreign companies and economic substance
Global minimum tax (Pillar Two)
Pillar Two sets a 15% minimum effective tax rate, country by country, for groups with consolidated revenue of EUR 750 million or more. Low-taxed profit is topped up first by the local country through a qualified domestic minimum top-up tax, then by the parent's country through the income inclusion rule, and as a backstop by other countries through the undertaxed profits rule. Implementation differs across markets, and a side-by-side package agreed in January 2026 gives US-parented groups relief from the income inclusion and undertaxed profits rules from 2026.
Sources for this topic · 7
- European Union (EUR-Lex) — Council Directive (EU) 2022/2523 of 14 December 2022 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the UnionChecked against an official source · checked 2026-10-18 · 3 statements
- Bundesministerium der Justiz (gesetze-im-internet.de) — Mindeststeuergesetz (MinStG) § 1Checked against an official source · checked 2026-10-18 · 1 statement
- Bundesministerium der Justiz (gesetze-im-internet.de) — Mindeststeuergesetz (MinStG) § 101 AnwendungsvorschriftenChecked against an official source · checked 2026-10-18 · 1 statement
- Grant Thornton — OECD side-by-side Pillar 2 packageChecked against a secondary source · checked 2026-10-18 · 3 statements
- UAE Ministry of Finance — Ministry of Finance announces issuance of a Cabinet Decision on the introduction of Top-up Tax for Multinational EnterprisesChecked against an official source · checked 2026-10-18 · 1 statement
- PwC Worldwide Tax Summaries — United Arab Emirates: Corporate - Taxes on corporate incomeChecked against a secondary source · checked 2026-10-18 · 1 statement
- PwC Worldwide Tax Summaries — Singapore: Corporate - Taxes on corporate incomeChecked against a secondary source · checked 2026-10-18 · 2 statements
Questions on this topic
12 statements on global minimum tax (pillar two)
Financing, profit repatriation and exit
How a group funds a subsidiary and how cash comes back are tax decisions as much as treasury ones. Interest can reduce the subsidiary's taxable profit but is capped, commonly at 30% of EBITDA; dividends, interest, royalties and service fees each attract different withholding taxes and deductibility tests. Exit and share sales raise their own charges, including exit taxes when assets or residence move.
Sources for this topic · 2
- European Union (EUR-Lex) — Council Directive (EU) 2016/1164 of 12 July 2016 laying down rules against tax avoidance practices that directly affect the functioning of the internal marketChecked against an official source · checked 2026-10-18 · 3 statements
- PwC Worldwide Tax Summaries — Saudi Arabia: Corporate - Withholding taxesChecked against a secondary source · checked 2026-10-18 · 2 statements
Questions on this topic
5 statements on financing, profit repatriation and exit
Choosing the structure: branch, subsidiary and holding company
The first structural choice in a new market is usually between a branch, which is part of the foreign company and taxed as a permanent establishment, and a local subsidiary, which is a separate taxpayer. Holding company location then depends on treaty network, participation exemptions, substance and minimum tax exposure. Hybrid mismatch rules now neutralise structures that exploit differences between countries, and a day-one registration plan avoids penalties.
Sources for this topic · 5
- European Union (EUR-Lex) — Council Directive (EU) 2017/952 of 29 May 2017 amending Directive (EU) 2016/1164 as regards hybrid mismatches with third countriesChecked against an official source · checked 2026-10-18 · 3 statements
- PwC Worldwide Tax Summaries — India: Corporate - Taxes on corporate incomeChecked against a secondary source · checked 2026-10-18 · 1 statement
- PwC Worldwide Tax Summaries — Saudi Arabia: Corporate - Taxes on corporate incomeChecked against a secondary source · checked 2026-10-18 · 1 statement
- PwC Worldwide Tax Summaries — United Arab Emirates: Corporate - Taxes on corporate incomeChecked against a secondary source · checked 2026-10-18 · 1 statement
- PwC Worldwide Tax Summaries — Singapore: Corporate - Taxes on corporate incomeChecked against a secondary source · checked 2026-10-18 · 1 statement
Questions on this topic
7 statements on choosing the structure: branch, subsidiary and holding company
Worked example, from official sources
Dividends from an Indian subsidiary: UAE parent compared with Singapore parent
How much Indian tax applies when an Indian company pays a dividend to its foreign parent, and does it matter whether the parent is in the UAE or Singapore?
Assumptions
- The dividend is paid or credited on or after 1 April 2026, so India's Income-tax Act, 2025 governs withholding.
- The parent is a company resident in the UAE or Singapore, is the beneficial owner of the dividend and holds a valid tax residency certificate.
- The parent holds at least 25% of the Indian company's shares unless the row says otherwise.
- A dividend of INR 100 is used for illustration; Indian surcharge and cess on the domestic rate are not modelled.
| Route | Rule | Maximum Indian rate | Indian tax on INR 100 (illustrative) | Official source |
|---|---|---|---|---|
| No treaty relief | Income-tax Act, 2025, section 207 | 20% (before surcharge and cess) | INR 20 | Income Tax Department, section 207 |
| UAE parent | India-UAE DTAA, Article 10(2) | 10% | INR 10 | India-UAE DTAA synthesised text and treaty text, incometaxindia.gov.in |
| Singapore parent holding 25% or more | India-Singapore DTAA, Article 10(2)(a) | 10% | INR 10 | Income Tax Department, Tax Rates - DTAA v. Income-tax Act |
| Singapore parent holding less than 25% | India-Singapore DTAA, Article 10(2)(b) | 15% | INR 15 | Income Tax Department, Tax Rates - DTAA v. Income-tax Act |
Step by step
- Identify the governing law. A dividend paid or credited on or after 1 April 2026 falls under the withholding provisions of the Income-tax Act, 2025.56
- Start from the domestic rate. Section 207 of the 2025 Act taxes dividends received by a foreign company at 20%, before any surcharge and cess.1
- Apply the treaty cap if it is more beneficial. India applies the treaty rate where it is lower than the domestic rate and the recipient qualifies.7
- UAE parent: Article 10(2) of the India-UAE treaty caps Indian tax at 10% of the gross dividend where the recipient is the beneficial owner, with no minimum shareholding.2
- Singapore parent: Article 10(2) of the India-Singapore treaty caps Indian tax at 10% where the beneficial owner is a company holding at least 25% of the shares, and at 15% in all other cases.34
- Check the anti-abuse layer. For India-UAE, the MLI principal purpose test replaced the treaty's limitation of benefits article, with effect in India for withholding from 1 April 2020. For India-Singapore, MLI coverage and any treaty-specific limitation of benefits clause must be confirmed.89
Conditions that apply
- The parent must be the beneficial owner of the dividend; both treaties use this condition in Article 10(2).24
- The parent must provide a tax residency certificate and the prescribed information to claim treaty relief in India.10
- The arrangement must pass the principal purpose test where the MLI applies (confirmed for India-UAE).8
- The remitting bank will normally require an accountant's certificate stating the treaty article and rate applied.11
Result on these facts
On these facts both treaties cap Indian tax at 10%, half the 20% domestic rate. The Singapore route needs a shareholding of at least 25% to reach 10% and otherwise gives 15%; the UAE route gives 10% regardless of shareholding size. The choice between the two locations therefore turns on other factors, such as substance, tax on the dividend in the parent's country and onward distributions, rather than on the Indian rate alone.
Rates must be confirmed for the actual payment date against the authentic treaty text, any protocol, both countries' MLI positions and Indian law then in force, including surcharge and cess on the domestic rate. The India-Singapore treaty text was read from a secondary reproduction; the rates match the Income Tax Department's official comparison table.
Sources for the worked example
Each statement is numbered to the source it was checked against. We use official sources where we can, and each statement says whether it was checked against an official or a secondary source. Sources last checked on 18 October 2026. None of it has been professionally reviewed yet: it is research checked against official and secondary sources by WONE Global, not legal or tax advice.
Under section 207 of the Income-tax Act, 2025, dividends received by a foreign company are taxed at 20%, other than dividends from a unit in an International Financial Services Centre, which are taxed at 10%. Rate before any surcharge and health and education cess, which were not confirmed.
Surcharge and cess are not stated on this page.
Under Article 10(2) of the India-UAE DTAA, tax in the source state on dividends paid to a beneficial owner resident in the other state may not exceed 10% of the gross amount. Applies in either direction; no MLI modification to Article 10 shown in the synthesised text.
The Income Tax Department lists the India-Singapore treaty dividend rate as 10% where the recipient company holds at least 25% of the shares and 15% otherwise. India-Singapore DTAA Article 10.
Article 10(2) of the India-Singapore DTAA caps source-state tax at 10% of the gross dividend if the beneficial owner is a company owning at least 25% of the shares of the paying company, and 15% in all other cases. Beneficial owner condition applies.
Secondary reproduction of the treaty text; the official India-Singapore synthesised text on incometaxindia.gov.in could not yet be checked. The rates match the department's official comparison table.
The Income-tax Act, 2025 replaces the Income-tax Act, 1961 with effect from 1 April 2026, and 'tax year' replaces 'previous year' for income earned from that date. Income earned in FY 2025-26 remains under the 1961 Act.
Any sum paid or credited on or after 1 April 2026 is governed by the corresponding withholding provisions of the Income-tax Act, 2025; sums paid or credited on or before 31 March 2026 remain under the 1961 Act. Indian tax deduction at source (TDS).
India taxes a non-resident's dividends, interest, royalties and fees for technical services under the Income-tax Act or the applicable treaty, whichever is more beneficial to the non-resident. Requires the non-resident to be entitled to the treaty (residence, beneficial ownership, documentation, anti-abuse rules).
The page states it reflects the Income-tax Act, 1961 as amended by the Finance Act, 2026; its 'last reviewed' date is blank.
In the India-UAE DTAA, the MLI principal purpose test replaces Article 29 (Limitation of Benefits): a benefit is denied where it is reasonable to conclude that obtaining it was one of the principal purposes of an arrangement, unless granting it accords with the object and purpose of the treaty. MLI Article 7(1) as applied to the India-UAE DTAA.
For the India-UAE DTAA, the MLI applies to withholding taxes in India where the taxable event occurs on or after 1 April 2020, and in the UAE on or after 1 January 2020. Withholding taxes only; other taxes have separate dates.
India requires a non-resident to obtain a tax residency certificate from its country of residence to claim treaty relief, together with prescribed additional information (Form 10F under the 1961 rules). Income-tax Act, 1961 section 90(4)-(5) and rules; 2025 Act and Income-tax Rules, 2026 equivalents apply from 1 April 2026.
Point reflects the Income-tax Act, 1961 and its CBDT guidance. The Income-tax Act, 2025 replaced the 1961 Act from 1 April 2026 and renumbered provisions; the corresponding 2025 Act section and any CBDT guidance re-issued under it could not yet be checked.
For remittances from India, the accountant's certificate in Form 15CB certifies, among other things, the applicable DTAA provisions and the TDS rate. Remittance procedures follow the law in force on the remittance date.
WONE Global Intelligence
Ask about tax & international structuring
Ask in your own words. Answers come from WONE Global's checked records, with every source shown, and end with the named Partner who can act. Go deeper on any point, or build a decision file.
Scope
What the service covers
- 01Review the proposed cross-border structure
- 02Identify direct and indirect tax exposures
- 03Consider withholding, treaty and transfer-pricing issues
- 04Coordinate implementation across the relevant jurisdictions
Key questions
What we will work through with you
- What needs to be decided before tax & international structuring work starts?
- Who is professionally responsible in each country?
- Which other work, such as tax or employment, must happen at the same time?
- What information and decisions are needed from the business?
You don’t need the answers before you talk to us. Working through them is the first thing we do together.
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WONE Global Partners
The professionals admitted for Tax & International Structuring
Each is responsible for this service in their own jurisdiction, under their own professional rules.
Vienna · Austria
Douala · Cameroon
Bogotá · ColombiaWONE Global Partner · Colombia
Katherin Diaz Velilla
Complete profile
International tax attorney and strategic advisor with 12+ years across Colombia's DIAN, Ministry of Finance, Senate, Presidency, and EY. Co-founder of V&V Asociados. Specializes in cross-border tax structuring, transfer…
Quito · EcuadorWONE Global Partner · Ecuador
Mauro Tejada Ramon
Professional with 20 years of experience in Tax Administration, performing functions in the managerial and tax administration fields. Experience related to the fiscal field in the main sectors of the economy: Banking, c…
Munich · GermanyWONE Global Partner · Germany
Ulrike Berner, MBA
Ulrike Berner has been Managing Director and shareholder of BSP since 2021, leading the strategic direction, client relationships, and business development of the firm. She has extensive experience working with firms an…
Kowloon · Hong KongWONE Global Partner · Hong Kong
Yvonne Chow
Ms. Chow, our director, graduated from Smith College (US), and obtained her master's degree in Religion from Yale University. She is an associate member of Hong Kong Institute of Certified Public Accountants and Institu…
New Delhi · IndiaWONE Global Partner · India
Sandeep Gupta
Galway · Ireland
Rome · Italy
Mombasa · KenyaWONE Global Partner · Kenya
Farheen Khandwalla
Panamá · PanamaWONE Global Partner · Panama
Ebrahim Asvat K.
Ebrahim Asvat K. is a founding partner of Patton, Moreno & Asvat. His practice focuses on corporate law, asset and tax planning, mergers and acquisitions, and offshore business structures. He holds an LL.M. from Harvard…
Kigali · RwandaWONE Global Partner · Rwanda
Lilianne Gasango
Riyadh · Saudi ArabiaWONE Global Partner · Saudi Arabia
Abdullah Yousef Alhussaini
Abdullah Yousef Al-Hussaini (License No. 992) is a seasoned accounting and auditing professional with a career spanning leading roles at Ernst & Young (EY) and one of Saudi Arabia’s largest insurance companies, includin…
Zürich · Switzerland
Dubai · United Arab EmiratesWONE Global Partner · United Arab Emirates
Priju Dominic
Armed with two decades of rich experience spanning across diverse industries and verticals, I have garnered the trust and admiration of many valued relationships. Audit & Assurance, Consulting, Risk Advisory and Tax pra…
Ho Chi Minh City · VietnamWONE Global Partner · Vietnam
Chau Kim Hien
Lusaka · ZambiaWONE Global Partner · Zambia
Gerald Zimba
Who does what
Clear responsibility at every step
WONE Global is not a law, tax or audit firm. Each firm is independent and regulated where it practises.
- WONE GlobalWorks out what you need, finds the right firm, checks it can act and coordinates work that crosses borders.
- The named firmGives the advice and does the work under its own licence and insurance, and invoices you for it.
- YouAgree the scope and fees directly with the firm before any work starts, and can choose another firm at any time.
Cases
What clients bring to this service
The cases this service leads or joins, in the words clients use. Each sets out what is at stake, how WONE Global handles it and who handles it in each market.
Urgent We've received a tax notice from another country. Do we have to pay?Tax assessments, disputes & managementUrgent We sell online to customers abroad. Do we have to register for their VAT or GST?Tax assessments, disputes & managementUrgent Tax was deducted abroad and again at home. Can we get it back?Payments, FX, digital assets & treasuryUrgent The tax authority wants our transfer pricing documentation. We don't have any.International tax planning & transfer pricingWhat tax filings do we have to make in each country, and when?Tax assessments, disputes & managementHow should we price and invoice customers abroad so we actually get paid?Contracts, commercial disputes & collectionsAt what point do our sales abroad mean we need a local company?International tax planning & transfer pricingShould we reorganise how our regional business is run?International tax planning & transfer pricingCan we centralise finance, HR or IT in one country?International tax planning & transfer pricingHow do we move cash between our companies in different countries?Payments, FX, digital assets & treasury
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