• Business Restructuring / Inbound and Outbound Operations
  • Designing an entry strategy
  • Evaluating alternative intermediate holding company jurisdictions
  • Strategy on international tax
    • Tax Treaty Interpretation
    • Permanent Establishment (PE) exposure
    • Attribution of profits to a PE
    • Structuring of revenue / capital flows e.g. Royalty, FTS, Dividend, Interest, Capital gains etc.
  • Exit planning
  • Understanding the link between Transfer Pricing and Permanent Establishment
  • Vetting the legal documentation from an income-tax and transfer pricing perspective to be in synch with the business strategy