Business Advisory: Tax Structuring and Transfer Pricing

Restructuring a client's tax requirements due to a change in management control 

Challenge 

The establishment of a new “TopCo” holding company and headquarters led to the concurrent change in location of management control of several intermediary companies. The organisation required a compliant tax set-up while ensuring the tax migration for all companies, of both old and new tax residency countries, fulfilled regulations.

Solution

We oversaw the application for exemptions on relocation. This enabled us to identify more optimal tax holding structures following the relocations, and allowed us to develop and implement a robust transfer pricing policy for the new TopCo.

Results 

Our recommendations and execution led to an 8% reduction in the overall tax rate of the whole group.