Global Tax Preparation Services
International tax compliance spans corporate tax returns in multiple jurisdictions, OECD transfer pricing documentation, double taxation treaty relief claims, and CRS/FATCA reporting obligations.
International tax compliance spans corporate tax returns in multiple jurisdictions, OECD transfer pricing documentation, double taxation treaty relief claims, and CRS/FATCA reporting obligations. Fintax Support Limited prepares tax returns across our 12+ regions, compiles Master File and Local File transfer pricing documentation under OECD guidelines, and manages foreign tax credit claims. We coordinate global tax compliance calendars, file CbCR reports, and represent clients during cross-border tax audits and mutual agreement procedures.
Regulatory Framework
OECD transfer pricing guidelines require arm's length pricing for all intercompany transactions with contemporaneous documentation. The MLI (Multilateral Instrument) modifies bilateral treaties to implement BEPS minimum standards. Pillar Two applies a 15% global minimum effective tax rate for groups exceeding EUR 750 million in revenue. CRS requires reporting of financial accounts held by non-residents.
Our Tax Preparation Services in Global
Cross-Border Tax Planning & Structuring
Design tax-efficient cross-border structures that align with OECD Model Convention principles, BEPS Actions 1–15 minimum standards, and Pillar Two GloBE 15% minimum effective tax rules. We model holding companies, IP licensing chains, and regional headquarters across 12+ jurisdictions — balancing treaty benefits, CFC exposure, and permanent establishment risk while meeting economic substance requirements in each operating country.
OECD-aligned structuring
Entity and transaction flows designed against OECD Model Convention, BEPS minimum standards, and MLI treaty modifications.
Pillar Two GloBE modelling
15% global minimum effective tax rate impact modelled by jurisdiction for groups exceeding EUR 750 million in consolidated revenue.
Treaty network analysis
Withholding tax, PE, and CFC outcomes mapped across bilateral treaty networks covering 1,500+ agreements worldwide.
BEPS compliance integration
Structures tested against BEPS Actions 2–15 including hybrid mismatch, interest limitation, and principal purpose test rules.
How It Works
Current structure and objective review
Map existing entities, intercompany flows, treaty positions, and business objectives across all operating jurisdictions.
Cross-border scenario modelling
Model alternative structures against effective tax rates, GloBE top-up tax, CFC attribution, and PE exposure under OECD Art 5.
Structure design and documentation
Draft optimal entity architecture with transfer pricing policies, substance requirements, and implementation timeline.
Implementation and ongoing monitoring
Coordinate incorporations, tax registrations, and compliance setup with annual structure reviews as BEPS and Pillar Two rules evolve.
Current structure and objective review
Map existing entities, intercompany flows, treaty positions, and business objectives across all operating jurisdictions.
Cross-border scenario modelling
Model alternative structures against effective tax rates, GloBE top-up tax, CFC attribution, and PE exposure under OECD Art 5.
Structure design and documentation
Draft optimal entity architecture with transfer pricing policies, substance requirements, and implementation timeline.
Implementation and ongoing monitoring
Coordinate incorporations, tax registrations, and compliance setup with annual structure reviews as BEPS and Pillar Two rules evolve.
Cross-border tax planning must navigate the post-BEPS landscape where OECD Actions 1–15 have reshaped hybrid mismatch rules, interest deductibility caps, CFC attribution, and treaty abuse prevention through the Principal Purpose Test under the Multilateral Instrument. The OECD Model Convention provides the framework for allocating taxing rights on business profits, dividends, interest, royalties, and capital gains — but Pillar Two GloBE rules now impose a 15% global minimum effective tax rate on multinational groups with consolidated revenue exceeding EUR 750 million, triggering top-up tax in low-rate jurisdictions regardless of treaty planning. We design structures that respect arm's length transfer pricing, satisfy economic substance requirements in UAE, Cayman, BVI, and other no- or low-tax centres, and anticipate CFC rules in residence countries that attribute undistributed foreign profits to parent shareholders. Permanent establishment risk under OECD Model Convention Article 5 is assessed for every cross-border activity — sales agents, service delivery, and digital operations can create unexpected PE exposure. Our planning integrates CRS and FATCA reporting obligations, foreign tax credit availability, and MAP-eligible treaty positions to deliver defensible, OECD-compliant structures.
Common Questions
Expatriate Tax Return Preparation
Prepare expatriate tax returns across home and host countries with correct treaty relief, foreign earned income exclusions, and shadow payroll reporting. We file US Form 1040 with Form 2555 FEIE claims, UK SA100 self-assessment for non-domiciled residents, and host-country returns in UAE, Saudi Arabia, Europe, and other jurisdictions — coordinating FBAR, FATCA, and CRS disclosures for overseas financial accounts.
Multi-country return prep
Home and host country individual returns prepared with treaty relief, foreign tax credits, and correct residency determinations.
Treaty tie-breaker analysis
Tax residency resolved under OECD Model Convention tie-breaker rules when individuals are dual-resident in two jurisdictions.
FBAR & FATCA compliance
FinCEN Form 114 FBAR filed when foreign account aggregate exceeds $10,000; FATCA Form 8938 disclosures coordinated.
Equalization & shadow payroll
Tax equalization calculations and shadow payroll reporting for employer-assigned expatriates under company policy.
How It Works
Assignment and residency review
Confirm tax residency status, treaty tie-breaker position, assignment dates, and employer equalization policy terms.
Income and account data collection
Gather worldwide income statements, foreign tax paid certificates, and foreign financial account details for FBAR/FATCA thresholds.
Return preparation across jurisdictions
Prepare home and host country returns with treaty relief claims, foreign tax credits, and Form 2555 or equivalent exclusions.
Filing and employer reporting
E-file returns in each jurisdiction, submit FBAR by April 15, and deliver equalization settlement reports to the employer.
Assignment and residency review
Confirm tax residency status, treaty tie-breaker position, assignment dates, and employer equalization policy terms.
Income and account data collection
Gather worldwide income statements, foreign tax paid certificates, and foreign financial account details for FBAR/FATCA thresholds.
Return preparation across jurisdictions
Prepare home and host country returns with treaty relief claims, foreign tax credits, and Form 2555 or equivalent exclusions.
Filing and employer reporting
E-file returns in each jurisdiction, submit FBAR by April 15, and deliver equalization settlement reports to the employer.
Expatriate tax compliance requires filing individual returns in both the home country and the host country unless a tax treaty eliminates dual filing through residency tie-breaker rules under OECD Model Convention Article 4. US citizens and green card holders must file Form 1040 reporting worldwide income regardless of residence, with Form 2555 claiming the foreign earned income exclusion (up to approximately $126,500 for 2024) or Form 1116 claiming foreign tax credits for host-country tax paid. FinCEN Form 114 (FBAR) is required when the aggregate value of foreign financial accounts exceeds $10,000 at any point during the calendar year — failure to file carries civil penalties up to $12,921 per violation and potential criminal exposure. FATCA Form 8938 applies additional reporting thresholds for specified foreign financial assets held by US taxpayers abroad. CRS requires 100+ jurisdictions to automatically exchange financial account information of non-residents, meaning host-country tax authorities receive data on expatriate accounts held locally. We coordinate shadow payroll reporting for employer-assigned expatriates, calculate tax equalization settlements under company policy, and apply treaty relief under Articles 15 (employment income), 22 (other income), and 23 (elimination of double taxation) to minimise global tax liability.
Common Questions
Multi-Jurisdiction Tax Compliance
Coordinate corporate and individual tax compliance across 12+ jurisdictions with unified compliance calendars, CbCR filing, and consistent reporting standards. We prepare tax returns in each operating country, reconcile group effective tax rates against Pillar Two GloBE 15% thresholds, and manage BEPS Action 13 Country-by-Country Reports for groups exceeding EUR 750 million in consolidated revenue.
12+ jurisdiction coverage
Corporate and individual returns prepared across UAE, UK, US, Europe, Australia, Canada, and other operating regions.
Global compliance calendar
Centralised deadline tracking for returns, CbCR, CRS/FATCA, and transfer pricing documentation across all entities.
ETR & GloBE reconciliation
Effective tax rate reconciled by jurisdiction against Pillar Two 15% minimum rate and group tax provision.
CbCR & BEPS reporting
Country-by-Country Reports prepared under BEPS Action 13 for groups meeting the EUR 750 million revenue threshold.
How It Works
Entity register and calendar setup
Map all group entities to tax jurisdictions, filing obligations, and deadlines — building a master compliance calendar.
Data collection and local computation
Gather statutory accounts, transfer pricing allocations, and local adjustments for tax computation in each jurisdiction.
Return preparation and group reconciliation
Prepare jurisdiction-specific returns, reconcile to group IFRS accounts, and compile CbCR and GloBE data.
Filing, payment, and audit support
File returns electronically in each country, coordinate tax payments, and support cross-border tax audits and MAP cases.
Entity register and calendar setup
Map all group entities to tax jurisdictions, filing obligations, and deadlines — building a master compliance calendar.
Data collection and local computation
Gather statutory accounts, transfer pricing allocations, and local adjustments for tax computation in each jurisdiction.
Return preparation and group reconciliation
Prepare jurisdiction-specific returns, reconcile to group IFRS accounts, and compile CbCR and GloBE data.
Filing, payment, and audit support
File returns electronically in each country, coordinate tax payments, and support cross-border tax audits and MAP cases.
Multi-jurisdiction tax compliance requires filing separate tax returns in every country where a group entity is tax-resident — there is no single global tax return. We coordinate corporate income tax, withholding tax, payroll tax, and indirect tax filings across our 12+ regions while maintaining a centralised compliance calendar that tracks deadlines ranging from 3 months to 12 months after fiscal year-end depending on the jurisdiction. BEPS Action 13 mandates Country-by-Country Reporting for multinational groups with consolidated revenue exceeding EUR 750 million, requiring jurisdictional breakdowns of revenue, profit, tax paid, employees, and tangible assets — data that feeds Pillar Two GloBE calculations and tax authority risk assessment. Pillar Two imposes a 15% global minimum effective tax rate through the Income Inclusion Rule and Undertaxed Profits Rule, requiring groups to calculate effective tax rates by jurisdiction and pay top-up tax where rates fall below 15%. CRS reporting obligations in 100+ jurisdictions and FATCA requirements for US persons add a layer of financial account disclosure that must align with entity classification and tax residency positions. We reconcile group effective tax rates, manage foreign tax credit pools across jurisdictions, and represent clients during cross-border audits and mutual agreement procedures under OECD Model Convention Article 25.
Common Questions
Transfer Pricing Documentation & Defence
Prepare OECD-compliant Master File, Local File, and Country-by-Country Reports under BEPS Action 13 — and defend transfer pricing positions during tax audits and mutual agreement procedures. We document arm's length pricing for intercompany transactions including goods, services, royalties, and financing, with economic analysis supporting profit allocation across jurisdictions subject to Pillar Two GloBE 15% scrutiny.
Three-tier OECD documentation
Master File, Local File, and CbCR prepared under BEPS Action 13 OECD Transfer Pricing Guidelines.
Arm's length benchmarking
Comparable uncontrolled price, TNMM, and profit split methods applied with database benchmarking studies.
Audit defence & MAP support
Transfer pricing positions defended during audits with MAP applications under OECD Model Convention Article 25.
BEPS Actions 8–10 alignment
Intangible transfers, risk allocation, and low-value-adding services documented per BEPS Actions 8–10.
How It Works
Intercompany transaction mapping
Identify and classify all intercompany flows — goods, services, royalties, loans, and cost allocations — by entity and jurisdiction.
Functional analysis and method selection
Conduct functional and risk analysis per OECD guidelines; select appropriate transfer pricing method for each transaction category.
Documentation preparation
Prepare Master File, Local Files, and CbCR with benchmarking studies, economic analysis, and contemporaneous documentation.
Audit defence and MAP coordination
Represent clients during transfer pricing audits; initiate MAP under Article 25 when double taxation arises from TP adjustments.
Intercompany transaction mapping
Identify and classify all intercompany flows — goods, services, royalties, loans, and cost allocations — by entity and jurisdiction.
Functional analysis and method selection
Conduct functional and risk analysis per OECD guidelines; select appropriate transfer pricing method for each transaction category.
Documentation preparation
Prepare Master File, Local Files, and CbCR with benchmarking studies, economic analysis, and contemporaneous documentation.
Audit defence and MAP coordination
Represent clients during transfer pricing audits; initiate MAP under Article 25 when double taxation arises from TP adjustments.
OECD Transfer Pricing Guidelines require all intercompany transactions to be priced at arm's length — the price unrelated parties would charge in comparable circumstances. BEPS Action 13 mandates a three-tier documentation approach: the Master File provides a group overview of business operations and transfer pricing policies; the Local File documents entity-specific transactions with detailed functional analysis and benchmarking; and the Country-by-Country Report provides jurisdictional data for tax authority risk assessment. BEPS Actions 8–10 refined guidance on intangibles, risk allocation, and low-value-adding intra-group services, requiring groups to align profit allocation with value creation rather than contractual form. Documentation must be contemporaneous — prepared before or at the time of filing the tax return — to avoid penalty exposure during audits. Tax authorities in 100+ CRS jurisdictions exchange CbCR data and increasingly challenge transfer pricing through joint audits and automatic exchange of rulings under BEPS Action 5. When a transfer pricing adjustment in one country creates double taxation, the OECD Model Convention Article 25 mutual agreement procedure allows competent authorities to negotiate relief — we initiate and support MAP cases across bilateral treaty networks. Pillar Two GloBE rules add further scrutiny, as transfer pricing directly affects effective tax rates by jurisdiction and top-up tax calculations under the 15% minimum rate.
Common Questions
Double Taxation Treaty Advisory & Claims
Analyse bilateral tax treaty networks based on the OECD Model Convention to secure reduced withholding tax rates, eliminate double taxation, and resolve residency conflicts. We prepare treaty relief claims for dividends, interest, and royalties across 1,500+ treaties, initiate mutual agreement procedures under Article 25, and navigate MLI modifications implementing BEPS Action 6 treaty abuse prevention.
Treaty network mapping
Withholding tax rates and relief mechanisms mapped across 1,500+ bilateral treaties based on OECD Model Convention.
Relief claim preparation
Treaty relief applications and certificates of residence prepared for dividends, interest, royalties, and capital gains.
MAP & arbitration support
Mutual agreement procedures initiated under Article 25; BEPS Action 14 arbitration accessed where available.
PPT & LOB analysis
Principal Purpose Test and limitation on benefits clauses analysed under MLI and bilateral treaty protocols.
How It Works
Treaty entitlement analysis
Determine residency, beneficial ownership, and LOB/PPT eligibility for each cross-border payment and transaction.
Relief claim documentation
Prepare certificates of tax residence, treaty claim forms, and supporting documentation for source-country filing.
Withholding tax recovery
File refund claims for excess withholding tax charged at domestic rates instead of treaty-reduced rates.
MAP initiation where needed
Initiate competent authority MAP under Article 25 when treaty relief is denied or double taxation persists after audit adjustments.
Treaty entitlement analysis
Determine residency, beneficial ownership, and LOB/PPT eligibility for each cross-border payment and transaction.
Relief claim documentation
Prepare certificates of tax residence, treaty claim forms, and supporting documentation for source-country filing.
Withholding tax recovery
File refund claims for excess withholding tax charged at domestic rates instead of treaty-reduced rates.
MAP initiation where needed
Initiate competent authority MAP under Article 25 when treaty relief is denied or double taxation persists after audit adjustments.
The global network of 3,000+ bilateral tax treaties — largely based on the OECD Model Convention — reduces withholding taxes on cross-border dividends, interest, and royalties and prevents double taxation through the exemption or credit method under Articles 23A and 23B. BEPS Action 6 introduced the Principal Purpose Test through the Multilateral Instrument, modifying 1,500+ treaties to deny benefits where obtaining treaty relief was a principal purpose of an arrangement. Limitation on Benefits clauses in US and other treaties add further eligibility requirements based on ownership, base erosion payments, and derivative benefits. Treaty relief claims require certificates of tax residence, beneficial ownership declarations, and often pre-filing rulings in source countries — we prepare and file these across all relevant jurisdictions. When treaty relief is denied or a transfer pricing adjustment in one country creates double taxation, OECD Model Convention Article 25 provides for mutual agreement procedures between competent authorities, with BEPS Action 14 improving dispute resolution timelines and mandatory binding arbitration in many treaties. Residency tie-breaker rules under Article 4 resolve dual-residency situations for individuals and, under the 2017 Model Convention update, for dual-resident entities. We map treaty networks across your operating countries, model withholding tax savings, and represent clients throughout MAP proceedings until double taxation is eliminated.
Common Questions
FBAR, FATCA & CRS Reporting
Manage US FBAR (FinCEN Form 114), FATCA (Form 8938), and CRS reporting obligations across 100+ participating jurisdictions. We classify entities and accounts correctly, prepare FBAR filings when foreign account aggregates exceed $10,000, coordinate FATCA FFI registration and reporting, and ensure CRS due diligence and automatic exchange of information compliance for financial institutions and account holders.
FBAR $10K threshold compliance
FinCEN Form 114 prepared when foreign financial account aggregate exceeds $10,000 at any point during the calendar year.
CRS 100+ jurisdiction coverage
CRS due diligence, reporting, and entity classification managed across 100+ automatic exchange jurisdictions.
FATCA entity classification
FFI registration, GIIN acquisition, and Form 8966 reporting for foreign financial institutions under FATCA.
Penalty risk mitigation
Non-filing and misclassification penalties assessed and mitigated through voluntary disclosure and corrective filing.
How It Works
Account inventory and classification
Identify all foreign financial accounts and classify entities as FFIs, NFFEs, or exempt institutions under FATCA and CRS.
Due diligence and data collection
Conduct CRS due diligence procedures — self-certification, indicia review, and account holder identification.
Report preparation and filing
Prepare FBAR, Form 8938, FATCA Form 8966, and CRS XML reports for submission to FinCEN, IRS, and local tax authorities.
Ongoing monitoring and amendments
Monitor account changes, file annual reports, and amend prior filings through voluntary disclosure programmes where needed.
Account inventory and classification
Identify all foreign financial accounts and classify entities as FFIs, NFFEs, or exempt institutions under FATCA and CRS.
Due diligence and data collection
Conduct CRS due diligence procedures — self-certification, indicia review, and account holder identification.
Report preparation and filing
Prepare FBAR, Form 8938, FATCA Form 8966, and CRS XML reports for submission to FinCEN, IRS, and local tax authorities.
Ongoing monitoring and amendments
Monitor account changes, file annual reports, and amend prior filings through voluntary disclosure programmes where needed.
Cross-border financial account reporting spans three overlapping regimes. FBAR (FinCEN Form 114) requires US persons — citizens, residents, and entities — to report foreign financial accounts when the aggregate value exceeds $10,000 at any point during the calendar year, with civil penalties up to $12,921 per non-willful violation and higher penalties for willful non-compliance. FATCA (Foreign Account Tax Compliance Act) requires foreign financial institutions to register with the IRS, obtain a GIIN, and report US account holders directly to the IRS through Form 8966 — while US taxpayers file Form 8938 reporting specified foreign financial assets above threshold amounts ($50,000–$600,000 depending on filing status and residence). CRS (Common Reporting Standard) extends automatic exchange of financial account information to 100+ jurisdictions, requiring financial institutions to identify reportable account holders through due diligence procedures and submit annual CRS reports to local tax authorities for exchange with account holders' countries of residence. Entity classification — distinguishing financial institutions from active and passive non-financial entities — determines reporting obligations for corporate groups, trusts, and investment structures. We manage the full compliance cycle across all three regimes, coordinate with custodians and banks for accurate data, and support voluntary disclosure for prior-year non-compliance to mitigate penalty exposure.
Common Questions
Permanent Establishment Risk Assessment
Assess permanent establishment (PE) exposure under OECD Model Convention Article 5 for cross-border business activities including sales agents, service delivery, construction projects, and digital operations. We analyse fixed place of business, dependent agent, and service PE tests across bilateral treaties, prepare PE tax returns where exposure is confirmed, and coordinate MAP relief when double taxation arises from PE attribution.
OECD Art 5 PE analysis
Fixed place of business, dependent agent, and service PE tests applied under OECD Model Convention Article 5.
Profit attribution modelling
Arm's length profit allocation to PE under OECD Authorized Approach and relevant bilateral treaty protocols.
BEPS Action 7 compliance
Commissionnaire, specific activity exemptions, and anti-fragmentation rules assessed under BEPS Action 7.
MAP for PE disputes
Mutual agreement procedures initiated under Article 25 when source and residence countries disagree on PE existence.
How It Works
Activity mapping and nexus review
Map cross-border activities — sales, services, construction, digital — against PE tests in each relevant bilateral treaty.
PE risk assessment report
Assess fixed place, dependent agent, and service PE risks with BEPS Action 7 anti-avoidance provisions applied.
PE return preparation or restructuring
File PE tax returns with profit attribution where exposure is confirmed, or restructure operations to eliminate PE risk.
Audit defence and MAP support
Defend PE positions during tax audits; initiate MAP under Article 25 when competing PE claims create double taxation.
Activity mapping and nexus review
Map cross-border activities — sales, services, construction, digital — against PE tests in each relevant bilateral treaty.
PE risk assessment report
Assess fixed place, dependent agent, and service PE risks with BEPS Action 7 anti-avoidance provisions applied.
PE return preparation or restructuring
File PE tax returns with profit attribution where exposure is confirmed, or restructure operations to eliminate PE risk.
Audit defence and MAP support
Defend PE positions during tax audits; initiate MAP under Article 25 when competing PE claims create double taxation.
Permanent establishment under OECD Model Convention Article 5 determines whether a non-resident enterprise is taxable in a source country on business profits attributable to a fixed place of business, dependent agent, or — under many post-BEPS treaties — services performed in that country for more than 183 days. BEPS Action 7 significantly narrowed specific activity exemptions (preparatory and auxiliary activities) and expanded dependent agent PE to cover persons who habitually conclude contracts or habitually play the principal role leading to contracts. Construction PE typically arises when a building site or project exceeds 6–12 months depending on the treaty. Digital business models create PE risk through local servers, dependent agents, and increasingly through significant economic presence tests introduced by BEPS Action 1 in some jurisdictions. When PE is established, profits must be attributed on an arm's length basis under OECD Authorized Approach or the relevant bilateral treaty protocol — requiring functional analysis, asset allocation, and risk assessment specific to the PE. PE tax returns must be filed in the source country, often triggering VAT registration, payroll obligations, and transfer pricing documentation for attributed profits. Competing PE claims between source and residence countries create double taxation resolved through MAP under Article 25. We assess PE risk before market entry, monitor ongoing cross-border activities, and restructure operations — such as converting dependent agents to independent distributors — to manage exposure within treaty parameters.
Common Questions
International Assignment Tax Planning
Plan the tax implications of international employee assignments before deployment — covering home and host country obligations, treaty relief under OECD Model Convention Articles 15 and 23, tax equalization policy design, and shadow payroll setup. We model total assignment cost including social security totalisation agreements, FBAR/FATCA reporting for expatriate accounts, and Pillar Two implications for employer entity structures.
Pre-assignment tax modelling
Home and host country tax cost modelled before deployment using treaty relief and equalization scenarios.
Equalization policy design
Tax equalization and tax protection policies structured with hypothetical tax calculations and settlement mechanics.
Shadow payroll setup
Host-country shadow payroll established for reporting assignment compensation without local entity employment.
Social security coordination
Totalisation agreements applied to avoid dual social security contributions during international assignments.
How It Works
Assignment brief and policy review
Review assignment terms, employer tax policy (equalization or protection), and home/host country tax regimes.
Pre-assignment tax cost estimate
Model total assignment tax cost including hypothetical home tax, host tax, treaty relief, and social security obligations.
Compliance infrastructure setup
Establish shadow payroll, withholding registrations, and FBAR/FATCA reporting processes for the assignment period.
Annual equalization and repatriation
Calculate annual equalization settlements, file home and host returns, and plan tax-efficient repatriation at assignment end.
Assignment brief and policy review
Review assignment terms, employer tax policy (equalization or protection), and home/host country tax regimes.
Pre-assignment tax cost estimate
Model total assignment tax cost including hypothetical home tax, host tax, treaty relief, and social security obligations.
Compliance infrastructure setup
Establish shadow payroll, withholding registrations, and FBAR/FATCA reporting processes for the assignment period.
Annual equalization and repatriation
Calculate annual equalization settlements, file home and host returns, and plan tax-efficient repatriation at assignment end.
International assignment tax planning must address the interaction of home country continuing tax obligations, host country source taxation, and treaty relief under OECD Model Convention Article 15 (employment income) and Article 23 (elimination of double taxation). US assignees remain subject to worldwide taxation on Form 1040 regardless of host country, while UK assignees may retain UK tax obligations depending on domicile and residency status. Treaty tie-breaker rules under Article 4 determine which country has primary taxing rights when the assignee qualifies as resident in both jurisdictions. Tax equalization policies ensure the employee pays approximately the same tax as if they had remained at home, with the employer bearing excess host-country tax — requiring hypothetical tax calculations, shadow payroll reporting in the host country, and annual settlement processes. Social security totalisation agreements between 30+ country pairs prevent dual social security contributions during assignments typically up to 5 years. FBAR reporting applies when the assignee's foreign account aggregate exceeds $10,000, and CRS in 100+ jurisdictions automatically exchanges financial account data with the home country tax authority. We model assignment costs before deployment, design equalization policies, set up compliance infrastructure, and manage ongoing filing through repatriation — integrating with Pillar Two considerations where the employer group exceeds EUR 750 million in consolidated revenue.
Common Questions
Foreign Tax Credit Optimization
Optimise foreign tax credit (FTC) claims and exemption method relief under OECD Model Convention Article 23 to eliminate double taxation on cross-border income. We manage FTC pools across US Form 1116, UK credit claims, and other jurisdiction-specific credit systems — coordinating with treaty networks, CFC inclusions, and Pillar Two GloBE top-up tax to maximise credit utilisation and minimise stranded foreign tax.
FTC basket optimisation
Foreign tax credits allocated across US Form 1116 baskets and equivalent jurisdiction-specific credit categories.
Treaty credit vs exemption
Credit and exemption method relief analysed under OECD Model Convention Articles 23A and 23B per income type.
Stranded credit recovery
Excess foreign tax credits carried forward and applied against future foreign-source income within limitation periods.
CFC & GloBE integration
FTC claims coordinated with CFC inclusions and Pillar Two GloBE foreign tax credit adjustments.
How It Works
Foreign tax paid analysis
Identify all foreign taxes paid or accrued by category — general, passive, GILTI, Section 951A — across jurisdictions.
Credit limitation computation
Calculate FTC limitation by basket under US Section 904 and equivalent rules in other residence countries.
Optimisation and carryforward planning
Optimise credit allocation across baskets, apply high-tax kick-out rules, and plan carryforward utilisation within 10-year windows.
Return filing and audit defence
File FTC claims on Form 1116 and equivalent forms; defend credit positions during audits and MAP proceedings.
Foreign tax paid analysis
Identify all foreign taxes paid or accrued by category — general, passive, GILTI, Section 951A — across jurisdictions.
Credit limitation computation
Calculate FTC limitation by basket under US Section 904 and equivalent rules in other residence countries.
Optimisation and carryforward planning
Optimise credit allocation across baskets, apply high-tax kick-out rules, and plan carryforward utilisation within 10-year windows.
Return filing and audit defence
File FTC claims on Form 1116 and equivalent forms; defend credit positions during audits and MAP proceedings.
Foreign tax credit optimisation prevents double taxation when the same income is taxed in both the source country and the residence country. The OECD Model Convention Article 23 provides two methods: the exemption method (Article 23A) excludes foreign-source income from residence-country taxation, and the credit method (Article 23B) allows residence-country tax to be reduced by foreign tax paid. US taxpayers claim credits on Form 1116 within separate baskets — general category, passive category, GILTI, and Section 951A — each with its own limitation computed under IRC Section 904 as foreign tax paid divided by foreign-source taxable income multiplied by US tax liability. Excess credits carry forward 10 years and back 1 year, but basket limitations often strand credits when foreign tax rates exceed the US effective rate on that income category. UK residents claim credit relief under TIOPA 2010 with similar limitation mechanics. CFC inclusions under BEPS Action 3 add complexity — foreign tax paid at the subsidiary level may or may not be creditable against CFC inclusion income depending on jurisdiction-specific CFC rules and US GILTI high-tax exclusion thresholds. Pillar Two GloBE rules introduce a Qualified Domestic Minimum Top-up Tax and GloBE-specific foreign tax credit adjustments that interact with traditional FTC systems. We model credit utilisation across multi-year horizons, restructure income flows to maximise creditable foreign tax, and coordinate with treaty exemption claims where the credit method produces stranded credits.
Common Questions
Controlled Foreign Corporation (CFC) Analysis
Analyse CFC attribution rules under BEPS Action 3 and jurisdiction-specific legislation — including US Subpart F and GILTI, UK CFC charge, EU ATAD CFC rules, and Australian CFC regime — to determine when undistributed foreign subsidiary profits are taxed in the parent company's residence country. We model CFC inclusion income, foreign tax credit interactions, and Pillar Two GloBE overlap for groups with subsidiaries in low-tax jurisdictions.
Multi-jurisdiction CFC rules
US Subpart F/GILTI, UK CFC charge, EU ATAD, and other national CFC regimes analysed for group subsidiaries.
Inclusion income modelling
CFC attribution computed with foreign base company income, GILTI tested income, and high-tax exclusions applied.
BEPS Action 3 alignment
CFC structures tested against BEPS Action 3 strengthened CFC rules and Pillar Two GloBE interaction.
Planning & restructuring
Substance enhancements and profit repatriation strategies designed to manage CFC exposure within legal parameters.
How It Works
Subsidiary and control mapping
Identify all foreign subsidiaries, ownership percentages, and control tests under each relevant CFC regime.
CFC status and income classification
Determine CFC status per jurisdiction; classify income as Subpart F, GILTI, passive, or active under each regime's rules.
Inclusion computation and FTC planning
Calculate CFC inclusion amounts, apply high-tax exclusions and GILTI deductions, and plan foreign tax credit utilisation.
Restructuring and ongoing monitoring
Recommend substance enhancements or restructuring to manage CFC exposure; monitor rule changes and Pillar Two overlap.
Subsidiary and control mapping
Identify all foreign subsidiaries, ownership percentages, and control tests under each relevant CFC regime.
CFC status and income classification
Determine CFC status per jurisdiction; classify income as Subpart F, GILTI, passive, or active under each regime's rules.
Inclusion computation and FTC planning
Calculate CFC inclusion amounts, apply high-tax exclusions and GILTI deductions, and plan foreign tax credit utilisation.
Restructuring and ongoing monitoring
Recommend substance enhancements or restructuring to manage CFC exposure; monitor rule changes and Pillar Two overlap.
Controlled Foreign Corporation rules attribute undistributed profits of foreign subsidiaries to parent company shareholders or parent entities in the residence country — preventing indefinite deferral of tax on income earned in low-tax jurisdictions. BEPS Action 3 strengthened CFC rules globally, requiring jurisdictions to tax CFC income unless substantive economic activity generates the profits. US CFC rules under Subpart F attribute foreign base company income (passive income, related-party sales and services) to US shareholders, while GILTI (Global Intangible Low-Taxed Income) under IRC Section 951A taxes tested income exceeding a 10% return on qualified business asset investment at an effective rate of 10.5–13.125%, with a high-tax exclusion available when foreign effective rates exceed 90% of the US corporate rate. UK CFC rules under TIOPA 2010 attribute profits of low-taxed foreign subsidiaries unless gateway exemptions apply for genuine commercial arrangements. EU ATAD requires member states to implement CFC rules attributing non-distributed income of low-taxed foreign subsidiaries where the CFC entity lacks substantive economic activity. CFC inclusions interact with foreign tax credit systems — foreign tax paid at the subsidiary level may offset CFC inclusion tax in the parent jurisdiction, subject to basket limitations and GILTI-specific credit restrictions. Pillar Two GloBE rules partially overlap with CFC regimes, as both target low-taxed foreign profits, but GloBE applies at the 15% minimum rate for groups exceeding EUR 750 million while CFC rules apply at lower revenue thresholds. We model CFC exposure across all relevant parent jurisdictions, optimise substance and profit allocation, and coordinate CFC planning with Pillar Two GloBE calculations.
Common Questions
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