International Tax & Transfer Pricing

Optimize cross-border operations while staying compliant

Overview

Global expansion can open new markets, revenue streams, and strategic partnerships — but it also brings layers of tax complexity. Different countries enforce unique regulations, impose withholding taxes, and interpret transfer pricing rules in distinct ways. Our International Tax & Transfer Pricing practice addresses these challenges head-on, ensuring that your cross-border operations remain not only tax-efficient but also compliant across jurisdictions.

By aligning legal structures, documenting intercompany transactions, and staying vigilant to regulatory changes (think BEPS 2.0, digital services taxes, or new treaties), we help you avoid double taxation, penalties, and disruptive audits. Moreover, a robust international tax strategy can significantly improve cash flow, allowing you to reinvest in growth and innovation across global markets.

International Tax & Transfer Pricing

What We Do

Cross-Border Structuring

Jurisdiction Selection / Permanent Establishment (PE) Analysis / Repatriation Strategies

Jurisdiction Selection

We help you decide where to incorporate holding companies, manage intellectual property, or establish sales offices — prioritizing tax efficiency and legal protection.

Permanent Establishment (PE) Analysis

We assess whether your overseas activities create a permanent establishment, affecting your local tax obligations.

Repatriation Strategies

We guide you through foreign dividend or cash repatriation scenarios, optimizing the flow of funds back home with minimal tax friction.

Benefits

Prevent unintended tax liabilities and double taxation.

Capture regional incentives and tax holidays that enhance profitability.

Safeguard assets and intellectual property from higher-risk jurisdictions.

Transfer Pricing Analysis & Documentation

Arm’s Length Benchmarking / Global Master Files & Local Files / Penalty Risk Reduction

Arm’s Length Benchmarking

We conduct comparability studies and economic analyses to ensure intercompany transactions meet the “arm’s length” principle required by OECD or local rules.

Global Master Files & Local Files

We compile comprehensive documentation—covering royalties, management fees, cost-sharing, and more — ready for audit scrutiny.

Penalty Risk Reduction

By fully aligning with transfer pricing guidelines, you minimize the chance of tax authority challenges and costly penalties.

Benefits

Avoid transfer pricing disputes that can strain resources.

Maintain credible, audit-ready documentation at all times.

Harmonize pricing practices across global entities for efficient supply chains.

Foreign Tax Credits & Treaties

Double-Taxation Relief / Documentation Requirements / Strategic Timing

Double-Taxation Relief

We analyze relevant tax treaties to leverage withholding reductions, foreign tax credits, and exemptions that lower overall tax costs.

Documentation Requirements

By collecting proof of foreign tax paid, you can rightfully claim credits in your home country, avoiding double burdens.

Strategic Timing

Sometimes it’s best to defer or accelerate profits and repatriation, depending on how treaties and local laws intersect.

Benefits

Manage global tax exposure effectively, freeing capital for reinvestment.

Eliminate paying two sets of taxes on the same profits.

Adapt repatriation timing to optimize net returns.

Global Compliance Management

Centralized Coordination / Transfer Pricing Policies & Documentation / Regulatory Vigilance

Centralized Coordination

We serve as your coordinating hub, ensuring timely and accurate filings across multiple jurisdictions — reducing the risk of missed deadlines.

Transfer Pricing Policies & Documentation

We help local affiliates understand and apply group-wide policies, making year-end filings or statutory audits smoother.

Regulatory Vigilance

With digital services taxes, BEPS 2.0, and emerging local reforms, we continuously monitor the legal landscape to update your strategy proactively.

Benefits

Avoid costly late fees or penalties from noncompliance in diverse regions.

Present a unified, coherent tax stance globally, building trust with regulators.

Keep pace with rapid tax changes, so you’re never caught off guard.

Why It Matters

When managed strategically, your international tax framework becomes a catalyst for global growth, rather than a burden. An optimized transfer pricing policy can lower costs, reduce risks, and streamline cross-border operations.

By ensuring consistent compliance and exploiting all available credits, your organization remains competitive and resilient in evolving global markets.

Ultimately, you can expand with confidence — knowing your tax position is secure, scalable, and fully aligned with your long-term objectives.

Contact us

Schedule an introduction call with Jeffrey Bowley, CPA

Get in Touch