We provide consultancy services in order to evaluate your group companies’ global operations in the light of OECD BEPS Action Plans.

  • Digital Economy
  • Intra Group Financing
  • Permanent Establishments
  • Transfer Pricing and IP Optimization
  • Hybrid mismatches
  • Controlled foreign company income
  • Limitation of benefit and principal purpose test
  • Analysis of risk and capital allocations within the group related to transfer pricing
  • Appeals to arbitration on international tax issues