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Navigate complex cross-border tax rules with clarity and confidence.

We support you in managing treaty positions, global risks, and evolving international tax reforms.

Cross-Border Tax Risk Assessment

Cross-border tax rules determine where a company is taxed, when it creates taxable presence, and how profits are allocated. Companies need risk assessments during expansion, restructuring, supply-chain changes, and when entering new markets.

What we do:
  • Assess PE risks, tax residency, nexus, and cross-border structuring implications.
  • Analyse compliance with domestic laws, treaties, and OECD guidance.
  • Provide recommendations for risk mitigation and operational alignment.
Our experience:
  • Permanent establishment, withholding tax and tax residency risk assessment.
  • Supporting expansions into Europe, the US, India, and Asia.

Tax Treaty & Withholding Tax (WHT) Advisory

Companies rely on treaties to reduce excessive withholding taxes on dividends, royalties, interest, and services. WHT advisory is needed for cross-border payments, new contracts, repatriation planning, and audit defence.

What we do:
  • Determine treaty eligibility, documentation needs, and applicable relief.
  • Advise on WHT optimisation, refunds, and compliance with domestic rules and MLI changes.
  • Support classification, characterisation, and taxability of payments.
Our Experience:
  • Advising global groups on WHT positions across Europe, India, the US, Canada, the Middle East, and Asia-Pacific.
  • Setting up in-house withholding tax tools and processes for groups with global operations, including establishing dedicated WHT teams and supporting commercial and sales teams with practical guidance.

Global Compliance, BEPS & Tax Controversy Support

Businesses face evolving global tax reforms, including BEPS, Pillar Two, and substance requirements. Companies need support when responding to regulatory changes, handling audits, preparing for Pillar Two filings, or during restructuring.

What We Do
  • Provide BEPS compliance reviews, Pillar Two readiness assessments, and global minimum tax advisory.
  • Support audit responses and documentation alignment.
  • Assist with governance frameworks and cross-border reporting obligations.
Our Experience
  • Experience in preparation and managing TP or WHT disputes in both in-house and consulting roles.

FAQs – Quick Reads

Policy development, compliance reviews, treaty analysis, risk mitigation, and practical automation solutions for WHT compliance.