Global Business Consultation Services
International expansion requires orchestrating entity structures, transfer pricing policies, tax treaty networks, and economic substance across dozens of jurisdictions while managing OECD BEPS compliance and Pillar Two minimum tax implications.
International expansion requires orchestrating entity structures, transfer pricing policies, tax treaty networks, and economic substance across dozens of jurisdictions while managing OECD BEPS compliance and Pillar Two minimum tax implications. Fintax Support Limited provides strategic advisory for multinational corporations and growing businesses expanding across our 12+ target regions. We design global operating models, conduct country-by-country feasibility analyses, and develop integrated compliance roadmaps covering tax, regulatory, and operational requirements worldwide.
Regulatory Framework
OECD BEPS Actions 2-15 have reshaped international tax rules including hybrid mismatch prevention, CFC rules, interest limitations, and treaty abuse prevention through the Principal Purpose Test. Economic substance requirements in UAE, Cayman, BVI, and other jurisdictions require genuine local activity. Pillar Two minimum tax rules apply to groups with global revenue exceeding EUR 750 million.
Our Business Consultation Services in Global
International Market Entry Strategy
Plan and execute cross-border expansion with clarity on jurisdiction selection, regulatory pathways, and global mobility requirements. We map market entry models — subsidiary, branch, joint venture, or distributor — against OECD treaty networks, local substance rules, and Pillar Two effective tax rate implications so your first international presence supports scalable growth without compliance surprises.
Multi-jurisdiction market comparison
Target markets evaluated against corporate tax, treaty access, customer proximity, and regulatory complexity.
Entry model selection
Subsidiary, branch, JV, and agency models compared for tax, liability, and operational control.
Global mobility planning
Cross-border hiring, secondments, and shadow payroll triggers mapped before staff deploy internationally.
Phased rollout roadmap
Sequenced entry plan covering entity setup, banking, transfer pricing, and local compliance registration.
How It Works
Market and regulatory scoping
Define target countries, customer segments, revenue model, and competitive landscape with management.
Jurisdiction and entity recommendation
Compare incorporation options, treaty benefits, substance requirements, and Pillar Two exposure across shortlisted markets.
Workforce and mobility review
Assess global mobility, shadow payroll, and equalization obligations for planned international headcount.
Phased entry roadmap delivery
Deliver market entry plan with entity setup sequence, intercompany framework, and compliance calendar.
Market and regulatory scoping
Define target countries, customer segments, revenue model, and competitive landscape with management.
Jurisdiction and entity recommendation
Compare incorporation options, treaty benefits, substance requirements, and Pillar Two exposure across shortlisted markets.
Workforce and mobility review
Assess global mobility, shadow payroll, and equalization obligations for planned international headcount.
Phased entry roadmap delivery
Deliver market entry plan with entity setup sequence, intercompany framework, and compliance calendar.
International market entry is not a single-country decision — it requires balancing corporate tax rates, double tax treaty networks, customer proximity, and multi-jurisdiction compliance obligations. OECD BEPS standards and Pillar Two minimum tax rules mean jurisdiction selection must account for effective tax rates, substance requirements, and qualified domestic minimum top-up tax adoption timelines. Global mobility adds complexity: employees working across borders trigger shadow payroll obligations, social security coordination, and tax equalization policies that vary by host and home country. Service providers deploying staff internationally must coordinate visa requirements, permanent establishment risk, and local employment law before revenue is generated. We design phased entry strategies — subsidiary, branch, or joint venture — that align transfer pricing documentation, cash pooling arrangements, and arm's length intercompany agreements from the first operating month.
Common Questions
Cross-Border Entity Structuring
Design multi-jurisdiction group structures that leverage treaty networks, participation exemptions, and holding company regimes while meeting OECD substance standards. We model parent-subsidiary, branch, and hybrid arrangements with arm's length financing, cash pooling frameworks, and documented governance so treaty benefits and transfer pricing positions withstand audit.
Multi-jurisdiction entity architecture
Parent, operating subsidiary, IP holding, and branch models designed with substance requirements mapped.
Cross-border reorganisation planning
Mergers, hive-downs, and share exchanges assessed for tax deferral and treaty relief eligibility.
Arm's length financing design
Intercompany loans, guarantees, and cash pooling arrangements structured at OECD-compliant rates.
Substance and anti-avoidance review
Board governance, local employees, and decision-making documented to withstand BEPS and CFC challenges.
How It Works
Current structure and objectives review
Map existing entities, ownership chains, revenue flows, and IP locations against group strategic goals.
Jurisdiction and entity modelling
Compare holding, operating, and IP entity options across target jurisdictions with treaty and tax analysis.
Financing and cash pooling design
Structure intercompany lending, cash pooling, and treasury arrangements at arm's length terms.
Implementation and documentation plan
Deliver restructuring roadmap with intercompany agreements, substance benchmarks, and compliance calendar.
Current structure and objectives review
Map existing entities, ownership chains, revenue flows, and IP locations against group strategic goals.
Jurisdiction and entity modelling
Compare holding, operating, and IP entity options across target jurisdictions with treaty and tax analysis.
Financing and cash pooling design
Structure intercompany lending, cash pooling, and treasury arrangements at arm's length terms.
Implementation and documentation plan
Deliver restructuring roadmap with intercompany agreements, substance benchmarks, and compliance calendar.
Cross-border entity structuring must balance tax efficiency with genuine commercial substance under OECD BEPS Action 5 and Action 6 standards. Holding companies in treaty-rich jurisdictions require local directors, employees, and decision-making authority to preserve dividend exemption and capital gains relief. Arm's length intercompany financing — including cash pooling arrangements with notional pooling or zero-balancing structures — must reflect commercially realistic interest rates and credit terms documented under OECD Transfer Pricing Guidelines 2022. CFC rules in most jurisdictions attribute profits of low-taxed foreign subsidiaries to domestic parents, while hybrid mismatch provisions deny deductions when payments create double non-taxation. Pillar Two adds a layer of effective tax rate analysis across the group structure. We design entity architectures with adequate substance, documented JV governance where joint ventures are involved, and transfer pricing policies aligned from incorporation.
Common Questions
Transfer Pricing Policy Design
Develop OECD Transfer Pricing Guidelines 2022-compliant policies that document arm's length pricing for goods, services, intangibles, and financial transactions across your group. We design method selection frameworks — CUP, TNMM, RPM, CPM, and profit split — with benchmarking studies, intercompany agreements, and Master File and Local File documentation ready for tax authority review.
Arm's length method selection
CUP, TNMM, RPM, CPM, and profit split methods matched to transaction type and available comparables.
Benchmarking and documentation
Comparable company and transaction searches supporting arm's length ranges for each intercompany flow.
Intercompany agreement framework
Distribution, service, licensing, and loan agreements drafted to reflect OECD TP policy positions.
Master File and Local File readiness
Country-by-country reporting, Master File, and Local File templates aligned to OECD BEPS Action 13.
How It Works
Intercompany transaction mapping
Identify and categorise all cross-border flows — goods, services, royalties, loans, and cost sharing.
Method selection and benchmarking
Apply OECD five-method hierarchy — CUP, resale price, cost plus, TNMM, and profit split — with comparables.
Policy and agreement drafting
Document transfer pricing policies and draft intercompany agreements reflecting arm's length terms.
Documentation package delivery
Deliver Master File, Local File templates, and annual compliance calendar for each jurisdiction.
Intercompany transaction mapping
Identify and categorise all cross-border flows — goods, services, royalties, loans, and cost sharing.
Method selection and benchmarking
Apply OECD five-method hierarchy — CUP, resale price, cost plus, TNMM, and profit split — with comparables.
Policy and agreement drafting
Document transfer pricing policies and draft intercompany agreements reflecting arm's length terms.
Documentation package delivery
Deliver Master File, Local File templates, and annual compliance calendar for each jurisdiction.
Transfer pricing policy design under OECD Transfer Pricing Guidelines 2022 requires selecting the most appropriate method for each intercompany transaction and documenting why alternatives were rejected. The Comparable Uncontrolled Price (CUP) method suits commodity or standardised product transactions with reliable market data. The Transactional Net Margin Method (TNMM) is widely applied to distribution and service arrangements where net profit indicators are more reliable than price comparisons. The Resale Price Method (RPM) and Cost Plus Method (CPM) suit routine distribution and manufacturing functions respectively. The profit split method applies when both parties contribute unique intangibles or perform integrated functions. All methods must produce results within an arm's length range supported by benchmarking studies. Financial transactions — including cash pooling, guarantees, and intercompany loans — require separate analysis under OECD Chapter X guidance. We deliver policies that satisfy BEPS Action 13 documentation standards and withstand advance pricing agreement negotiations.
Common Questions
Global Tax Optimization (Within Compliance)
Develop tax strategies that maximise efficiency within OECD BEPS, Pillar Two, and domestic anti-avoidance frameworks. We model effective tax rate outcomes across jurisdictions, identify compliant planning opportunities, and align group structure with the Pillar Two timeline — including GloBE rules, qualified domestic minimum top-up tax, and safe harbour elections.
Effective tax rate modelling
Group ETR analysed jurisdiction by jurisdiction with Pillar Two top-up tax and QDMTT impact quantified.
Pillar Two timeline alignment
IIR, UTPR, and QDMTT adoption schedules mapped to your group structure and fiscal year.
Treaty and incentive optimisation
Participation exemptions, IP regimes, and R&D incentives leveraged within substance requirements.
Anti-avoidance risk assessment
CFC, GAAR, hybrid mismatch, and principal purpose test exposure identified and mitigated.
How It Works
Group tax profile and structure review
Map entities, revenue flows, effective tax rates, and incentive utilisation across all jurisdictions.
Pillar Two and BEPS impact assessment
Quantify GloBE ETR, top-up tax exposure, and safe harbour eligibility under the Pillar Two timeline.
Compliant planning options design
Develop restructuring, repatriation, and incentive strategies respecting anti-avoidance boundaries.
Implementation and monitoring plan
Deliver tax optimisation roadmap with action timeline, documentation requirements, and annual review framework.
Group tax profile and structure review
Map entities, revenue flows, effective tax rates, and incentive utilisation across all jurisdictions.
Pillar Two and BEPS impact assessment
Quantify GloBE ETR, top-up tax exposure, and safe harbour eligibility under the Pillar Two timeline.
Compliant planning options design
Develop restructuring, repatriation, and incentive strategies respecting anti-avoidance boundaries.
Implementation and monitoring plan
Deliver tax optimisation roadmap with action timeline, documentation requirements, and annual review framework.
Global tax optimisation within compliance means identifying planning opportunities that withstand OECD BEPS scrutiny and Pillar Two minimum tax rules. The Pillar Two timeline began with qualifying jurisdictions implementing the Income Inclusion Rule for fiscal years starting on or after 31 December 2023, with the Undertaxed Profits Rule following in 2024. Groups with consolidated revenue exceeding EUR 750 million must calculate GloBE effective tax rates jurisdiction by jurisdiction and pay top-up tax where rates fall below 15%. Qualified Domestic Minimum Top-Up Tax (QDMTT) allows source jurisdictions to collect top-up tax before parent jurisdictions. Safe harbour elections — including the Transitional CbCR Safe Harbour — may reduce compliance burden in early years. Compliant planning focuses on genuine commercial arrangements with adequate substance: participation exemptions, IP box regimes, and R&D incentives remain available when properly documented. We model outcomes alongside arm's length transfer pricing positions so your global tax profile remains efficient and defensible.
Common Questions
Multi-Jurisdiction Compliance Management
Coordinate tax, payroll, and regulatory compliance across every jurisdiction where your group operates. We build compliance calendars covering corporate tax filings, transfer pricing documentation, global mobility reporting, shadow payroll obligations, and Pillar Two GloBE returns — so deadlines, registrations, and documentation requirements are managed centrally without gaps.
Centralised compliance calendar
Filing deadlines, registration renewals, and documentation due dates tracked across all jurisdictions.
Global mobility compliance
Shadow payroll, tax equalization, and social security reporting managed for cross-border assignees.
Transfer pricing documentation
Master File, Local File, and CbCR preparation coordinated with arm's length policy updates.
Pillar Two GloBE reporting
GloBE information return and top-up tax calculations integrated into annual compliance workflow.
How It Works
Jurisdiction and obligation mapping
Inventory all entities, registrations, filing requirements, and compliance deadlines by country.
Global mobility and payroll review
Document shadow payroll triggers, equalization policies, and social security obligations for mobile employees.
Compliance framework design
Build centralised calendar, responsibility matrix, and documentation standards for group-wide compliance.
Ongoing monitoring and reporting
Deliver compliance dashboard with deadline alerts, filing status tracking, and annual review process.
Jurisdiction and obligation mapping
Inventory all entities, registrations, filing requirements, and compliance deadlines by country.
Global mobility and payroll review
Document shadow payroll triggers, equalization policies, and social security obligations for mobile employees.
Compliance framework design
Build centralised calendar, responsibility matrix, and documentation standards for group-wide compliance.
Ongoing monitoring and reporting
Deliver compliance dashboard with deadline alerts, filing status tracking, and annual review process.
Multi-jurisdiction compliance management prevents the costly gaps that arise when local advisers operate in silos. Corporate tax filings, VAT returns, payroll withholding, and transfer pricing documentation each carry jurisdiction-specific deadlines and penalties. Global mobility adds shadow payroll obligations — host-country tax reporting for employees who remain on home-country payroll — and tax equalization calculations that reconcile home and host tax differences. Social security coordination requires A1 certificates, totalisation agreements, and split contribution analysis. Pillar Two introduces GloBE information returns and top-up tax filings on a separate timeline from domestic corporate tax. OECD BEPS Action 13 requires Master File and Local File updates when intercompany policies change. We centralise compliance tracking so your finance team, HR, and local advisers work from a single calendar with clear ownership and escalation paths.
Common Questions
International Joint Venture Advisory
Structure and govern international joint ventures with clear JV governance frameworks, arm's length transfer pricing between JV partners, and documented decision-making protocols. We advise on equity splits, board composition, reserved matters, exit mechanisms, and intercompany arrangements so JV partnerships operate efficiently and withstand tax authority scrutiny.
JV governance framework
Board structure, reserved matters, voting thresholds, and deadlock resolution documented from formation.
Arm's length partner transactions
Intercompany flows between JV partners priced under OECD Transfer Pricing Guidelines 2022.
Equity and contribution structuring
Cash, asset, and IP contributions valued and documented with appropriate tax treatment.
Exit and dissolution planning
Buy-sell provisions, drag-along rights, and tax-efficient exit routes mapped before signing.
How It Works
JV objectives and partner alignment
Define commercial goals, contribution expectations, governance preferences, and exit horizons with all partners.
Structure and governance design
Recommend entity form, equity split, board composition, and JV governance documentation.
Transfer pricing and intercompany review
Document arm's length terms for goods, services, and IP flows between JV entity and partners.
Implementation and ongoing governance plan
Deliver JV agreement framework, compliance calendar, and governance review schedule.
JV objectives and partner alignment
Define commercial goals, contribution expectations, governance preferences, and exit horizons with all partners.
Structure and governance design
Recommend entity form, equity split, board composition, and JV governance documentation.
Transfer pricing and intercompany review
Document arm's length terms for goods, services, and IP flows between JV entity and partners.
Implementation and ongoing governance plan
Deliver JV agreement framework, compliance calendar, and governance review schedule.
International joint ventures combine partners from different jurisdictions with distinct tax systems, governance cultures, and commercial priorities. JV governance must address board composition, reserved matters requiring supermajority approval, information rights, and deadlock resolution before operations begin. Transfer pricing between the JV entity and its partners — including supply agreements, management fees, and IP licensing — must reflect arm's length terms under OECD Transfer Pricing Guidelines 2022, with the profit split method often applicable when partners contribute complementary intangibles. Cash pooling and treasury arrangements within JV structures require separate analysis. Tax treatment of initial contributions, ongoing distributions, and exit events varies by jurisdiction and must be modelled before signing. We advise on governance frameworks that balance partner control with operational efficiency, and transfer pricing policies that satisfy both partners' tax authorities.
Common Questions
Global Financial Planning & Analysis
Build consolidated financial models and management reporting frameworks for multinational groups operating across multiple jurisdictions. We develop three-statement projections, cash pooling forecasts, and scenario analysis that reflect country-level tax rates, Pillar Two top-up tax, transfer pricing cash flows, and arm's length intercompany settlement timing.
Multi-jurisdiction three-statement models
Integrated P&L, balance sheet, and cash flow projections consolidated across group entities.
Scenario and sensitivity analysis
Base, upside, and downside cases with breakeven, runway, and group ETR metrics for board review.
Cash pooling and treasury forecasting
Intercompany cash flows, pooling balances, and arm's length interest modelled in consolidated cash forecast.
Pillar Two and TP integration
Top-up tax provisions and transfer pricing settlement timing reflected in group financial projections.
How It Works
Assumption and data gathering workshop
Define revenue drivers, headcount, capex, and country-specific tax assumptions with management input.
Model build and validation
Construct three-statement model with entity-level schedules, cash pooling logic, and documented formulas.
Consolidation and KPI dashboard
Build consolidated views with group ETR, Pillar Two top-up tax, and transfer pricing settlement metrics.
Board and investor package delivery
Deliver model, management reporting templates, and scenario analysis ready for board and lender review.
Assumption and data gathering workshop
Define revenue drivers, headcount, capex, and country-specific tax assumptions with management input.
Model build and validation
Construct three-statement model with entity-level schedules, cash pooling logic, and documented formulas.
Consolidation and KPI dashboard
Build consolidated views with group ETR, Pillar Two top-up tax, and transfer pricing settlement metrics.
Board and investor package delivery
Deliver model, management reporting templates, and scenario analysis ready for board and lender review.
Global financial planning requires models that reconcile entity-level P&L with consolidated group performance — not disconnected spreadsheets per country. Three-statement models must link revenue forecasts to intercompany pricing under arm's length transfer pricing policies, cash pooling inflows and outflows, and Pillar Two top-up tax provisions by jurisdiction. Cash pooling arrangements affect consolidated cash position through notional or physical pooling structures with arm's length interest allocation. Transfer pricing settlements — true-ups, dividend repatriation, and cost recharges — create timing differences between accounting profit and cash movement. Country-level corporate tax modelling reflects domestic rates, incentive utilisation, and GloBE effective tax rate calculations. We build FP&A frameworks that give CFOs visibility into group ETR, cash pooling efficiency, and Pillar Two exposure alongside operational KPIs.
Common Questions
Cross-Border M&A Advisory
Support international acquisitions and divestitures with due diligence, structuring, and post-deal integration planning. We analyse transfer pricing implications, Pillar Two ETR impact, cash pooling realignment, and arm's length intercompany arrangements so cross-border deals close efficiently and integrate without tax surprises.
Tax and TP due diligence
Transfer pricing exposure, pending audits, and arm's length compliance assessed in target entities.
Deal structuring optimisation
Share vs asset purchase, holding company layers, and treaty relief mapped for tax-efficient acquisition.
Post-merger integration planning
Intercompany policy harmonisation, cash pooling integration, and TP documentation updates scheduled.
Pillar Two and ETR impact
GloBE effective tax rate and top-up tax consequences of acquisition modelled before closing.
How It Works
Target scoping and due diligence
Review target transfer pricing documentation, tax audits, intercompany agreements, and compliance status.
Deal structure and tax modelling
Compare acquisition structures for withholding tax, capital gains, and Pillar Two ETR impact.
Integration planning
Design post-close transfer pricing policies, cash pooling integration, and intercompany agreement updates.
Closing support and Day 1 readiness
Deliver integration roadmap with TP documentation, compliance registrations, and governance handoff.
Target scoping and due diligence
Review target transfer pricing documentation, tax audits, intercompany agreements, and compliance status.
Deal structure and tax modelling
Compare acquisition structures for withholding tax, capital gains, and Pillar Two ETR impact.
Integration planning
Design post-close transfer pricing policies, cash pooling integration, and intercompany agreement updates.
Closing support and Day 1 readiness
Deliver integration roadmap with TP documentation, compliance registrations, and governance handoff.
Cross-border M&A transactions carry transfer pricing risk that standard financial due diligence often misses. Target entities may have undocumented intercompany flows, outdated benchmarking studies, or pending advance pricing agreement negotiations. Acquisition structure — share purchase vs asset purchase, direct vs holding company acquisition — affects withholding tax, capital gains treatment, and Pillar Two GloBE inclusion from Day 1. Post-merger integration requires harmonising transfer pricing policies under OECD Transfer Pricing Guidelines 2022, integrating cash pooling arrangements, and updating Master File and Local File documentation. JV governance structures in target entities may need restructuring. We support buyers and sellers through due diligence, structuring, and integration so arm's length positions are preserved and Pillar Two top-up tax exposure is understood before signing.
Common Questions
International Risk Management
Identify and mitigate tax, regulatory, and operational risks across your multinational footprint. We assess permanent establishment exposure, transfer pricing audit risk, global mobility compliance gaps, Pillar Two uncertainty, and geopolitical factors — delivering risk registers and mitigation plans aligned to OECD standards and arm's length documentation requirements.
Tax and TP audit risk assessment
Transfer pricing, permanent establishment, and CFC exposure scored by jurisdiction and transaction type.
Global mobility risk review
Shadow payroll, equalization, and social security non-compliance risks identified across assignee population.
Geopolitical and regulatory monitoring
Pillar Two adoption, treaty changes, and sanctions exposure tracked for affected jurisdictions.
Mitigation and documentation plan
Risk register with remediation actions, APA opportunities, and documentation upgrade priorities.
How It Works
Risk identification workshop
Map entities, transactions, mobile employees, and jurisdictions against known tax and regulatory risk categories.
Risk scoring and quantification
Score transfer pricing, PE, mobility, and Pillar Two risks by likelihood and financial impact.
Mitigation strategy design
Develop remediation plans including documentation upgrades, APAs, and governance improvements.
Risk register and monitoring delivery
Deliver centralised risk register with ownership, timelines, and quarterly review process.
Risk identification workshop
Map entities, transactions, mobile employees, and jurisdictions against known tax and regulatory risk categories.
Risk scoring and quantification
Score transfer pricing, PE, mobility, and Pillar Two risks by likelihood and financial impact.
Mitigation strategy design
Develop remediation plans including documentation upgrades, APAs, and governance improvements.
Risk register and monitoring delivery
Deliver centralised risk register with ownership, timelines, and quarterly review process.
International risk management for multinational groups spans tax audit exposure, regulatory change, and operational compliance gaps. Transfer pricing remains the highest-frequency audit trigger — jurisdictions increasingly share data through Country-by-Country Reporting and automatically exchange rulings under BEPS Action 5. Permanent establishment risk arises from cross-border sales activity, remote workers, and commissionaire arrangements. Global mobility programmes create shadow payroll and tax equalization failures when policies are not enforced consistently. Pillar Two introduces new calculation and reporting risks as jurisdictions adopt GloBE rules on different timelines. Cash pooling and financial transaction pricing under OECD Transfer Pricing Guidelines 2022 attract growing scrutiny. We build risk registers that prioritise remediation by financial exposure and audit probability, with advance pricing agreements and documentation upgrades where justified.
Common Questions
Global Digital Transformation Strategy
Align digital transformation initiatives with international tax, transfer pricing, and compliance requirements. We advise on IP centralisation, cloud and SaaS delivery models, remote workforce policies, and ERP implementation — ensuring digital operating models support arm's length profit allocation, Pillar Two ETR optimisation, and multi-jurisdiction compliance from design stage.
Digital operating model design
Centralised vs distributed digital functions mapped to transfer pricing and substance requirements.
IP and intangibles strategy
Software, data, and brand IP ownership aligned to OECD DEMPE functions and arm's length returns.
Cross-border digital delivery
SaaS, cloud, and remote service models assessed for PE risk and profit allocation.
ERP and data integration
Multi-entity ERP rollout planned with transfer pricing, cash pooling, and GloBE reporting capability.
How It Works
Current state and digital ambition review
Assess existing systems, IP ownership, remote workforce, and digital revenue model across the group.
Operating model and TP alignment
Design digital operating model with arm's length profit allocation under OECD Transfer Pricing Guidelines 2022.
Compliance and technology roadmap
Plan ERP, CbCR, GloBE, and mobility system integration with phased implementation timeline.
Implementation governance delivery
Deliver digital transformation roadmap with tax, TP, and compliance milestones aligned to technology rollout.
Current state and digital ambition review
Assess existing systems, IP ownership, remote workforce, and digital revenue model across the group.
Operating model and TP alignment
Design digital operating model with arm's length profit allocation under OECD Transfer Pricing Guidelines 2022.
Compliance and technology roadmap
Plan ERP, CbCR, GloBE, and mobility system integration with phased implementation timeline.
Implementation governance delivery
Deliver digital transformation roadmap with tax, TP, and compliance milestones aligned to technology rollout.
Global digital transformation reshapes where value is created, how services are delivered, and which entities earn profit — with direct transfer pricing and tax consequences. Centralising IP, development functions, or digital platforms requires DEMPE (Development, Enhancement, Maintenance, Protection, and Exploitation) analysis under OECD Transfer Pricing Guidelines 2022 to allocate returns arm's length across contributing entities. SaaS and cloud delivery models create permanent establishment and VAT registration triggers in customer jurisdictions. Remote and hybrid workforces expand shadow payroll and PE exposure beyond traditional assignment models. ERP implementations must support multi-entity intercompany billing, cash pooling reconciliation, and Pillar Two GloBE data collection from go-live. We integrate tax and transfer pricing planning into digital transformation roadmaps so technology investments do not create undocumented intercompany flows or compliance gaps.
Common Questions
Frequently Asked Questions
Get Started
Fill out the form below and our team will get back to you within 24 hours.
Book a Strategy Session
Share your business goals in Global — we'll prepare a tailored consultation for you.
Explore More in Global
Discover our other financial services available in this region.
Company Formation
Multi-Jurisdiction Business Incorporation
Learn More →
Accounting & Bookkeeping
Multi-Jurisdiction Bookkeeping
Learn More →
Tax Preparation
Cross-Border Tax Planning & Structuring
Learn More →
Auditing
Multi-Jurisdiction Statutory Audits
Learn More →
Odoo ERP
Multi-Subsidiary Odoo Deployment
Learn More →
Not sure which Business Consultation service you need?
Our Global team can assess your requirements and recommend the right approach. Book a free 30-minute consultation.
Need Business Consultation Support in Global?
Contact our Global team for expert assistance.
