Companies and private clients are faced with several tax regimes in case of inbound or outbound actitivies. On the one hand cross-border actitivies have the risk of dobule taxation but on the other hand those activites have the chance to flexibility in taxation.
In International Taxation our office is focussed on designing tax optimized inbound and outbound investments. We prapare tax opinions and adjust binding rulings with the tax authorities.
We advise in the area of International Taxation especially:
Use and interpretation of Double Taxation Treaties
CFC tax rules and Foreign Tax Act
Moving out taxation
Moving in taxation
Change of residence or seat of business
Tax optimisation of cross-border transaction
Taxation of inound and outbound investments
Taxation of domestic and international parent and subsidiary companies
Taxation of international permanent establishments