OECD BEPS
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
