How we can help | KPMG | QM

How we can help

How we can help

We are working with our clients to analyse and verify their operating models.

We are working with our clients to analyse and verify their operating models.

It will take a number of years for any changes to be implemented in full.

 In the meantime, we are working with our clients to analyse and verify their operating models. It is advisable to review structures on a periodic basis and perform some form of tax ‘health check’, which arguably every structure should already be doing.

In anticipation of the new tax climate, such checks may include:

  • Review of existing and proposed businesses through the lens of BEPS to determine if they are fit for purpose;
  • Put in place or review transfer pricing policies and documentation to ensure they are robust, for example, for expense allocations and intra-group financing;
  • Perform a risk versus reward analysis to determine if appropriate substance levels exist;
  • Review financing arrangements and levels of interest deductions, to include intra-group versus third party debt levels;
  • Consider existing operating structures in the light of the new definition of Permanent Establishment.

 

 

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