Any organisation with cross border activities will have an exposure for double taxation which will impact its effective tax rate and the resources it spends on tax compliance, tax audit and tax controversy.
Over the past decade or so, OECD and the EU have become supranational institutions issuing guidance which contributes to complexity and alignment. With the recent guidance from OECD and the EU the meta trend for tax is fairness and accurate delineation. Planning without substance is frequently viewed as aggressive tax planning by policymakers. Below this meta trend businesses still have to deal with daily decisions and a growing compliance burden, which more often is penalised when not sufficient.
Best advice is to prepare the basics as well as possible when it comes to company structure, permanent establishment, intangible and capital assets ownership, financing, and pricing of intercompany transactions. Following the preparations comes monitoring and compliance, which based on experience is less cumbersome when the basics are right.
In 42TAX, we spend the time needed to identify the best solution for our clients. We have proven experience of working both with Danish based multinationals and inbound clients knowing they have different needs depending on local tax professionals and local insights.