International Tax Law and Structural Advisory

• Analysis of tax risks for multinational enterprises
• Planning in line with double taxation treaties
• Strategic guidance on parent company, subsidiary, and branch structuring
• Monitoring and reporting global compliance obligations
• Analysis of obligations and development of compliance strategies under AEOI/CRS
• Advisory for companies operating in multiple jurisdictions and management of relations with tax authorities
• Analysis of controlled foreign corporations (CFCs) and hybrid structures
• Design of global profit distribution models and tax-efficient dividend policies
• Tax planning for foreign participations and management expense allocations
• Management of withholding tax and VAT obligations in cross-border service provision