Major corporates rely on our market leading advice when planning their group structure, locating their assets and functions, managing their supply chains and dealing with transfer pricing issues.
When considering the optimal location for a top holding company or intra-group holding company, you will benefit from our vast experience in setting up complex holding structures in the framework of public or private M&A transactions or restructurings. The same goes for the use of partnership structures and cost-sharing agreements. We will provide fully integrated, global tax advice covering all relevant jurisdictions (and not simply a compilation of local tax advice), and will also provide assistance on other relevant areas of law such as company law and regulatory aspects.
You will also benefit from our long-standing practice of advising clients on the optimal locations for treasury and finance centres, and associated transfer pricing issues including in relation to intra-group financing and guarantees. Our excellent relationships with local tax authorities will help us to obtain advance clearances where appropriate.
When it comes to choosing the best location for your R&D investments and intellectual property, we can provide you with the expertise required, advise you on the most appropriate structure, provide you with full documentation of the chosen structure and request clearances from the relevant tax authorities where appropriate.
We can also guide you through a detailed tax analysis of the way your business is organised, from procurement to sales, in order to ensure that it is efficient from a tax perspective. If a restructuring of business processes would be useful, we will ensure it is safely implemented and documented, and where possible and of value we will assist you in obtaining advance clearance from the relevant tax authorities.
We have broad experience in advising clients on transfer pricing issues in the context of international tax planning, including but not limited to drafting the required transfer pricing documentation, assisting clients in transfer pricing audits and handling transfer pricing litigation. In relation to the collection of comparable transfer pricing data, we generally work closely together with your advisor of choice or outsource this to an external specialist firm.
Our recent experience includes advising:
- ArcelorMittal, on the tax aspects of its conversion to a central entrepreneur structure for the Flat Carbon Europe Segment;
- Philip Morris International, on the tax aspects of the implementation of a Swiss central entrepreneur structure;
- Johnson & Johnson, on the location of its intellectual property;
- Rabobank, on the establishment of treasury centres in Belgium
