Tax Structuring

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We perform full-spectrum reviews of effective tax rates, intercompany flows, and loss utilization. Includes GAAP-to-tax reconciliations, deferred tax asset validation, and exposure mapping under local and global minimum tax regimes, including OECD BEPS 2.0 and Pillar Two compliance prep.

We restructure holding companies, SPVs, and JV setups to optimize dividend repatriation, interest deductibility, and exit tax leakage. Emphasis on substance requirements, beneficial ownership clarity, and treaty eligibility across jurisdictions with conflicting economic nexus tests.

We assess indirect tax exposure across leaseback models, management contracts, and central service arrangements. Reverse charge mechanisms, exempt supply structures, and pro-rata input recovery are modeled for compliance and cashflow benefit. Filing cadence, audit triggers, and penalties are preemptively addressed.

We conduct arm’s length analysis of royalty, management fee, and procurement arrangements across group entities. Functional and risk profiling aligns with OECD TP Guidelines. Benchmarking studies, local file, and master file documentation are delivered to withstand audit scrutiny or investor due diligence.

We model the tax impact of asset vs. share deals, goodwill amortization, and earnout-triggered tax events. Structures are developed to defer gain recognition, optimize seller net proceeds, and ring-fence legacy tax liabilities post-transaction.

We build centralized dashboards to manage statutory filings across corporate tax, VAT, and withholding tax regimes. Includes return deadlines, payment due dates, and penalty risk thresholds—streamlining multi-jurisdictional compliance without over-relying on local advisors.

We advise on capital gains exemption eligibility, interest deductibility on leveraged acquisitions, and exit strategy tax neutrality for owned, leased, or hybrid asset structures. REIT conversion pathways or PropCo/OpCo splits are evaluated for income stream separation and tax deferral.

We assess employer obligations on expat packages, housing allowances, and equity-linked comp. Cross-border employee placements are structured to minimize PE risk and avoid double taxation. Shadow payroll and split-contract models are implemented where required.

We simulate investor-side tax diligence questions, flagging historical VAT errors, thin capitalization breaches, or deferred tax misstatements. Exposure quantification and voluntary disclosure strategies are executed to contain reputational and valuation risk ahead of exit.