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At Grant Thornton, we work with you to understand your needs then implement custom solutions to help manage your business across jurisdictions. Combining our extensive technical tax knowledge with the latest technology, our professionals can work with you to develop your international tax strategy from ideation to implementation. Keeping the focus on key stakeholder outcomes and operational efficiencies, our collaboration helps to secure your tax position globally.
Systems that allow a tax deduction of expenses in computing taxable income must provide for rules for allocating such expenses between classes of income. Such classes may be taxable versus non-taxable, or may relate to computations of credits for taxes of other systems . A system which does not provide such rules is subject to manipulation by potential taxpayers. U.S. rules provide for allocation of an expense to a class of income if the expense directly relates to such class, and apportionment of an expense related to multiple classes.
In light of today’s dynamic global economic environment and recent legislative changes, assessing a multinational’s global business model may no longer be an optional exercise. Deloitte’s Value Chain Alignment teams provide high quality, customized tax and business model transformation services. We particularly specialize in the areas of global supply chain and intellectual property, seeking to align business objectives with tax minimization.
Most residency systems have avoided rules which permit deferring income from outside its borders without shifting it to a subsidiary enterprise due to the potential for manipulation of such rules. Where owners of an enterprise are taxed separately from the enterprise, portable income may be shifted from a taxpayer to a subsidiary enterprise to accomplish deferral or elimination of tax. Such systems tend to have rules to limit such deferral through controlled foreign corporations. Several different approaches have been used by countries for their anti-deferral rules.
In so doing, we play a critical role in building a better working world for our people, for our clients and for our communities. Effectively apply economic/financial knowledge to deliver to our clients quality transfer pricing advice through the tax life cycle . Perform transfer pricing analysis reflecting the international business operations of the client.
Specific rules are provided for certain categories of more fungible expenses, such as interest. By their nature, rules for allocation and apportionment of expenses may become complex.
While the opportunities are boundless in these new territories, many businesses can be caught off guard by the complex tax legislation in the various jurisdictions they operate. Failure to understand and comply with your reporting requirements can result in hefty penalties and may threaten your financial position. A measure capable of affecting cross-border trade must be applied in a nondiscriminatory manner. Under prior CJEU case law, the French DST’s discriminatory features—such as its global revenue thresholds—which cause the tax to be imposed mostly on foreign companies might have been sufficient to establish that the DST violates these fundamental freedoms. However, recent CJEU decisions appear to take a more lenient approach to these kinds of discriminatory features, such that it is unclear whether the French DST would be found to violate the fundamental freedoms today.
EY is a global leader in assurance, consulting, strategy and transactions, and tax services. The insights and quality services we deliver help build trust and confidence in the capital markets and in economies the world over. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders.
Complex calculations, combined with compound legal structures and intercompany transaction flows, have created an international tax environment that can be difficult. Many tax departments are struggling with these challenges during a time when high-quality international tax personnel are becoming increasingly hard to find, attract, and retain. What’s more, our affiliation with PrimeGlobal, an international association of 350+ independent accounting firms, allows us to unlock the door to a vast set of relationships, benefits, and services in close to 100 countries around the world.
Our goal is to help multinationals integrate their operational and tax planning in a scalable and sustainable way to enable business leaders make more effective decisions on an after-tax basis. As companies expand globally, their global tax and treasury strategies need to become more integrated, flexible and sustainable. Deloitte’s International Strategic Tax Review helps companies understand the drivers of their effective tax rate , assess risks, and better align tax management with future business model developments. Deloitte assists with foreign tax credits, income repatriation,
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