Benefits of structuring:
- Decrease in the tax burden
- No problems with transfer pricing
- Effective sharing of profits
- Cost confirmation for tax purposes
- Effective cost allocation within the group
What can we suggest?
Goal – to decrease an effective tax rate.
Result – effective structure without questions from tax authorities.
3 steps to achieve a goal:
- Analysis of the current model of intragroup cost allocation (i.e. strategies, policies, contracts etc.)
- Improving of the current model using all possible structures
- Full support for implementation of the selected model (drafting of necessary supporting documents)