totus tax

multinational private companies

Totus Tax Multinational Private Company (“MPC”) services focuses on the unique cross-border tax issues encountered by privately held companies. Private companies face cross-border structuring, foreign tax credit, tax treaty, and withholding tax issues. Our MPC professionals have knowledge and experience addressing these issues.

International Structuring

Companies should plan their international business structures to minimize global tax expense. Rules exist to assist companies in managing their global tax expense; however the rules are complex and challenging.

Totus Tax provides services related to:

• Planning tax efficient global structures
• Establishing holding company structures
• Controlled Foreign Companies planning
• Planning for cross border sales and mergers and acquisitions

Totus Tax recognises that business goals drive tax planning and use a forward thinking approach to achieve clients’ international tax planning goals.

Foreign Tax Credit Utilization

The foreign tax credit (“FTC”) generally eliminates double taxation on foreign earnings that are repatriated and is intended to enhance the global competitiveness of groups. Totus Tax can help international groups maximize their use of FTCs and lower tax expense by implementing FTC strategies and solutions designed to maximize the use of FTCs including:

• Expense apportionment
• Headquarters expense apportionment
• Foreign source income maximization
• Foreign title passage planning
• Foreign tax pool studies

Repatriation Planning

Multinationals usually intend to bring part or all of their foreign earnings back home. However, in certain situations Companies may wish to defer tax on those earnings, by keeping those earnings invested abroad until sometime in the future. Totus tax professionals have experience in working closely with clients to design tax effective global cash management strategies that integrate with their business strategies.

Transfer Pricing

Transfer pricing is a term used to describe all aspects of intercompany pricing arrangements between related business entities. Transactions subjected to transfer pricing scrutiny may include transfers of tangible goods, providing intercompany services, transfers of intellectual property, and financing transactions. Transfer pricing affects a multinational company’s tax planning and its financial statements. Transfer pricing has a high profile with both HMRC and foreign tax authorities as more countries pass transfer pricing legislation.

Totus Tax offers the following transfer pricing services:

• Developing economic comparables to support intercompany pricing and interest rates
• Preparing functional analyses
• Developing global transfer pricing policies
• Planning cost sharing arrangements for joint U.K. and foreign research and development of intellectual property
• Preparing transfer pricing documentation
• Applying for Advance Pricing Agreements

Inbound Tax Planning

International tax rules also affect corporations looking to do business in new jurisdictions Totus Tax assists clients with their corporate tax exposure, focusing on:

• Inbound structuring
• Branch profits tax
• Withholding taxes
• Conduit financing
• Earnings stripping
• Tax treaty planning

For more information please contact:

Parvize Assenjee
e: taxenquiries@totus.com
t: +44 20 3137 6301

Totus Tax LLP Registered office 44 Clerkenwell Close London EC1R 0AZ
Registered office no. OC359916 The Financial Services Authority does not
regulate taxation & trust advice.

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