International Tax

We assess where an entity's management and key decisions take place and how the relevant residence rules may apply. The work reviews governance arrangements and supporting evidence, including potential dual-residence questions; incorporation alone may not settle the analysis.

We examine where board and shareholder decisions are genuinely made - meeting locations, who attends, where the agenda is set and where strategic matters are decided - and map that against the residence tests that matter for your entities. Where practice creates risk, we recommend governance changes and the evidence trail that should exist going forward.

You receive: A residence assessment with governance findings, risk analysis and an evidence-maintenance protocol.

We review offices, personnel, projects, agents and contracting practices to assess potential taxable presence under relevant domestic rules and treaties. Where exposure is identified, we assess the implications for registration, profit attribution and the way activities are organised.

We collect the operational facts - travel patterns, home-office arrangements, project durations, who negotiates and signs, what stock or equipment sits where - and test them against fixed-place, agency and project thresholds in the relevant rules and treaty. Where a taxable presence likely exists, we quantify the attributable profit and the registration consequences; where it can be legitimately managed, we set out the operational changes required.

You receive: A PE risk assessment by country and activity, with attribution analysis and recommended operating protocols.

We assess cross-border payments such as interest, royalties, service fees and dividends against the relevant source-country rules and treaty provisions. The work considers eligibility, documentation and contractual tax clauses; it does not assume the same treatment in every country.

We take each payment flow and determine its character, the domestic withholding treatment, the treaty rate potentially available and the documentation needed to claim it - residence certificates, beneficial-ownership support, contract wording. The output is a payment matrix your finance team can apply at the moment of remittance, not a theory that arrives after the transfer.

You receive: A withholding-tax matrix by payment type and country, with the documentation checklist for each flow.

We review the facts needed to support treaty access and help prepare the relevant residence certificate application information. The assessment considers applicable eligibility and anti-abuse conditions. Obtaining a certificate does not by itself guarantee every treaty benefit.

We assess whether your entity genuinely meets the residence and anti-abuse conditions the treaty imposes - including purpose and substance tests - before any application is made, then assemble the application file and supporting evidence. Where eligibility is doubtful, we say so and explain what would need to change, because a certificate obtained on weak facts creates risk rather than relief.

You receive: An eligibility assessment and a complete residence-certificate application file.

We examine the nature of overseas tax, supporting evidence and relevant relief mechanisms. The analysis identifies whether and how double taxation may be addressed, including limitations, timing differences and any further local-country advice needed.

We verify what the foreign amount actually is - a creditable income tax, a withholding that treaty relief should have reduced, or a cost with no relief route - and then work through the mechanism, limits and evidence for claiming relief. Where over-withholding has occurred, we assess the reclaim route in the source country and coordinate local support to pursue it.

You receive: A double-taxation analysis with the relief calculation, evidence file and any reclaim recommendation.

We assess the implications of reorganising ownership, transferring businesses, relocating functions or changing group funding. The work considers transaction taxes, continuing obligations, treaty issues and interaction with Transfer Pricing rather than examining the structure in isolation.

For each restructuring step we identify the consequences in every affected country - exit charges, transaction taxes, treaty access changes, compliance obligations that survive the change - and sequence the steps so avoidable costs are avoided. The Transfer Pricing consequences of moved functions and assets are handled inside the same plan rather than discovered later.

You receive: A multi-jurisdiction step plan with tax consequences per step and a coordinated implementation checklist.

We review proposed debt and equity arrangements and routes for returning funds to investors. The assessment considers deductibility, withholding, treaty treatment, commercial terms and relevant anti-avoidance rules, with a documented comparison of practical options.

We model the realistic routes for moving funds - dividends, interest, royalties, capital reductions, loan repayments - with the tax cost, timing, documentation and restrictions of each, and stress-test intended interest deductions against limitation and anti-avoidance rules before the funding is booked. The recommendation shows its assumptions so it can be revisited when facts change.

You receive: A funding and repatriation options paper with modelled outcomes and a documented recommendation.

We review selected cross-border tax exposures in an acquisition, disposal or investment. Findings identify significant assumptions and information gaps and can inform deal discussions, further specialist work and post-transaction priorities.

Working from the data room and management interviews, we probe the target's cross-border pressure points - permanent establishment exposure, withholding compliance, treaty positions, transfer pricing documentation and open authority matters - and translate findings into deal terms: price adjustments, warranties, indemnities and the fix-list for day one of ownership.

You receive: A due-diligence report with quantified findings, deal-protection recommendations and a post-completion action plan.

We assess how a proposed ownership or operating change may interact with a group's global minimum tax position. Detailed scope assessment, modelling and reporting readiness are provided under Global Tax & Emerging Regulations, avoiding duplicate or inconsistent workstreams.

Before a transaction signs, we check whether it changes the group's minimum-tax picture - bringing entities into scope, moving jurisdictional effective rates, disturbing safe-harbour eligibility or shifting reporting responsibility - so the deal model reflects the real post-tax outcome and the detailed compliance work can be scoped without duplication.

You receive: A transaction-level minimum-tax impact note feeding the deal model and the wider compliance workstream.