International tax planning & transfer pricing

1. Our related-party pricing is being challenged Full situation page →
2. We need transfer pricing documentation for a new market Full situation page →
3. Our overseas sales model could create taxable presence Usually cross-border Full situation page →
4. We are relocating an intellectual property holding structure Full situation page →
5. We want to reorganise an international holding company Usually cross-border Full situation page →
6. Global minimum-tax rules may affect our group Bring this to WONE Global →
7. We need treaty analysis before paying foreign dividends Usually cross-border Full situation page →
8. A cross-border merger has complex tax consequences Usually cross-border Bring this to WONE Global →
9. Our business is migrating tax residency Bring this to WONE Global →
10. An executive's relocation has created double taxation Full situation page →
11. We need advance pricing or tax ruling support Bring this to WONE Global →
12. A restructuring may trigger exit taxes Bring this to WONE Global →
13. An international financing structure faces interest-limitation rules Usually cross-border Bring this to WONE Global →
14. Our group wants to align tax policy with actual operations Bring this to WONE Global →
15. A foreign investment requires tax-efficient but compliant structuring Usually cross-border Bring this to WONE Global →
16. We need to understand controlled foreign corporation exposure Usually cross-border Bring this to WONE Global →

• Cross-border tax residenceExecutives or entities may be treated as resident in different jurisdictions
• Permanent establishment riskEmployees or agents abroad may create local taxable presence
• Transfer pricing scrutinyConnected companies trade under different documentation and valuation expectations
• Incompatible reporting rulesGroup reporting and local filing use different accounting bases
• Beneficial ownership & trustsTrust and corporate transparency rules differ across residence and asset locations

1. Usually leadsTax and structuring17 markets with a named lead→
2. Often involvedSetting up and running a company4 markets with a named lead→
3. Often involvedAccounting and annual filings8 markets with a named lead→

Editorial examples of situations that arise, not a list of WONE Global clients or matters. The specialist area is a way to find your situation, not a separate practice group.