tax structuring - pkf · pkf’s highly experienced tax structuring group not only considers all...

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Page 1: tax structuring - PKF · PKF’s highly experienced tax structuring group not only considers all the angles from a local, regional, and global perspective, but also tailors the tax

tax structuring

Page 2: tax structuring - PKF · PKF’s highly experienced tax structuring group not only considers all the angles from a local, regional, and global perspective, but also tailors the tax

PKF is a global family of legally independent firms bound together by a shared commitment to quality, integrity and the creation of clarity in a complex regulatory environment.

With offices in over 350 locations, we operate in more than 150 countries across our 5 regions, and specialise in providing high quality audit, accounting, tax, and business advisory services to international and domestic organisations in all our markets.

who are we?

where we operate

350+ locations

150+ countries

5 regions

Page 3: tax structuring - PKF · PKF’s highly experienced tax structuring group not only considers all the angles from a local, regional, and global perspective, but also tailors the tax

right peopleright sizeright solutions

Page 4: tax structuring - PKF · PKF’s highly experienced tax structuring group not only considers all the angles from a local, regional, and global perspective, but also tailors the tax

how can we help you?

A new tax structuring landscape is rapidly forming as more and more countries adopt the OECD’s recommendations following the issue of the final BEPS reports. With changes proposed to ‘hybrid’ tax arrangements, tax treaties, and the deductibility of intercompany payments, the substance and motive of structures face increasing scrutiny. PKF’s tax professionals are experts in this area and can help your company review its existing structures, and plan new structures, to ensure they align with the changes and are BEPS proof. As a global service provider, PKF provides a full suite of tax structuring and cross-border tax services, which include the following:

Tax structuring

PKF provides a complete, BEPS-resistant strategy for cross-border acquisitions, disposals, and reorganisations, which covers:

• Structuring your initial investment in a tax-efficient manner;

• Tax-efficient options to extract the income (profits) of your investment throughout its lifetime; and,

• A tax efficient exit strategy to minimise or eliminate any capital gains tax implications and provide a tax efficient route for the remittance of residual funds

PKF’s recommendations seek to minimise local taxable profits, cross-border taxes such as withholding

taxes and ensures that taxes are minimised by claiming relief under applicable tax treaties.

PKF tax structuring specialists are highly experienced in dealing with different tax systems and revenue authorities’ and using their global and local expertise to reduce the tax impact on foreign operations and minimise your global effective tax rate.

We can help in other areas

Whilst undertaking tax structuring work we are often asked to provide additional services, such as:

• The tax efficient management of intellectual property;

• Tax due diligence and tax compliance review exercises;

• International tax advice: We provide tax advice on cross-border transactions, permanent establishment issues, on the establishment of overseas operations / joint ventures, financing, overseas mergers and demergers, business changes (expansion, sale or acquisition) and advice on the tax implications of entering into or exiting from a foreign market, including the foreign regulatory aspects and local practices;

• Foreign tax compliance: PKF will efficiently take care of all your foreign tax compliance obligations including filing tax returns, dealing with tax assessments and responding to all tax authority enquiries.

Page 5: tax structuring - PKF · PKF’s highly experienced tax structuring group not only considers all the angles from a local, regional, and global perspective, but also tailors the tax

why do you need us?

PKF’s highly experienced tax structuring group not only considers all the angles from a local, regional, and global perspective, but also tailors the tax efficient planning with your key commercial considerations in mind. It is this attention to detail and listening to our clients that often separates PKF from its competitors, in addition to our five values below:

A fresh approach

PKF tax professionals have a fresh approach that defines us:

• We have the passion to make a difference;

• We strive to improve and strengthen the tax positions of our clients; and,

• We have a passion for doing things properly.

Our tax people all share the same values and ambitions and combine decades of tax experience with a straightforward, no-nonsense approach.

A global service provider

No matter where your operations are, or where they are going to be, PKF as a global service provider offers a ‘one shop’ service for multinational companies and organisations. By using PKF it gives you the reassurance of dealing with just one trusted adviser for all your needs, which, in turn, provides more control, better communication, lower costs, and streamlined reporting.

We are up-to-date with best practice

PKF’s tax structuring professionals are up to date with the proposed changes of the OECD’s BEPS Plan and are able to provide options to reduce the risk of BEPS on your existing structures and ensure new structures are BEPS resistant. In this way the tax positions are likely to be preserved much longer and not subject to short-term challenges.

Right people, right locations

PKF invests in its people to ensure that passion, quality, integrity, and clarity are the cornerstones of what we do. Our highly experienced tax structuring team has the wealth and depth of local knowledge and experience at each location and local, regional and global tax structuring expertise. At PKF it’s all about teamwork and we are proud to have the right people in the right places across the world.

We’ve got it covered

Whatever cross-border or local transactions are envisaged, PKF can advise on the most tax efficient approach. PKF provides full, comprehensive advice which could, for example, reduce your organisation’s effective tax rate. Other services include recovery of overpaid tax, meeting regulatory tax compliance obligations in all countries (providing assistance with the completion and submission of tax returns) and mitigating risk. With PKF’s breadth of services and extensive resources, our clients have it all covered. have it all covered.

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Page 6: tax structuring - PKF · PKF’s highly experienced tax structuring group not only considers all the angles from a local, regional, and global perspective, but also tailors the tax

who should you contact?

Africa

Theo VermaakRegional Director AfricaDirect dial: +44 20 3691 2521Email: [email protected]

Asia Pacific

Amy HuiRegional Director Asia PacificDirect dial: +44 20 3691 2539Email: [email protected]

Europe, Middle East and India

Oliver Grosse-BrauckmannRegional Director Europe, Middle East and IndiaDirect dial: +44 20 3691 2523Email: [email protected]

Latin America

Sergio VillagarciaRegional Director AmericasDirect dial: +44 20 3691 2527Email: [email protected]

North America

Carolyn Morgan Regional Director North America Direct dial: +44 20 3691 2540Email: [email protected]

right people right size right solutions

PKF International Limited administers a family of legally independent firms and does not accept any responsibility or liability for the actions or inactions of any individual member or correspondent firm or firms.

PKF International Limited, 12 Groveland Court, London, EC4M 9EH, United Kingdom Telephone: +44 20 3691 2500

[email protected]

www.pkf.com/taxstructuring

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