Services · Tax
Corporate tax
Tax planning built into how your group is structured, financed and run, with provisions, returns and documentation that hold up under review.
Tax decided alongside the business plan
Corporate tax problems often begin as commercial decisions made without tax in the room: a subsidiary set up in the wrong country, an intercompany loan with no agreement behind it, or a reorganisation that triggers a charge nobody modelled. Unwinding them later takes time and can create tax of its own.
We work with your board and finance team while decisions are still open, so the structure, financing and intercompany arrangements of your group are chosen with their tax consequences understood. We then keep the compliance that follows in order: provisions in your accounts, returns in each country, and the documentation behind every position you take.
Advice is set out in writing with the facts and assumptions it relies on, and a partner reviews it before it reaches you.
What we cover
Strategy and compliance for companies and groups, scoped to the entities you own and the countries you operate in.
Group structuring
Where holding companies, subsidiaries and branches should sit; how the group is financed between debt and equity; withholding tax on dividends, interest and royalties; and the treaty access, substance and permanent establishment risk that come with each option.
Transfer pricing
Intercompany policies for services, goods, financing and intangibles, set on the arm's length principle and supported by functional analyses, benchmarking and intercompany agreements, with master and local files where a country requires them.
Tax provisioning
Current and deferred tax calculated for interim and annual accounts under IAS 12, ASC 740 or the framework your company applies: temporary differences scheduled, deferred tax assets tested for recoverability, and the tax note drafted with its reconciliation to accounting profit.
Corporate returns
Income tax returns and computations for each company in the group, tied back to the accounts and supported by working papers. See US tax returns for US filings.
Tax risk reviews
A structured look at your positions across income tax, withholding and indirect taxes: where the exposures sit, how well each position is documented, and which uncertain income tax treatments should be reflected in your accounts under IFRIC 23.
Transactions and reorganisations
Tax input on acquisitions, disposals, mergers and internal reorganisations, from the choice between buying shares or assets to the integration of entities afterwards. For due diligence and deal support, see transaction advisory.
Companies we work with
Businesses where a tax decision in one entity or country affects the rest of the group.
- Groups with subsidiaries or branches in more than one country
- US subsidiaries of foreign groups with intercompany charges to support
- Founder-owned groups preparing for investment, a sale or a reorganisation
- Finance teams that need tax provisions ready for the auditors at each reporting date
- Groups built by acquisition whose structure has never been reviewed as a whole
How an engagement runs
Advice and compliance in one cycle, so the numbers at the year end reflect the plan made at the start.
Map the group
Entities, ownership, intercompany flows, filing positions and open tax years, drawn into a single structure chart.
Agree priorities
We set out the exposures and opportunities we found, and agree in writing which to address and in what order.
Plan and document
Structuring options compared on their tax effect, with policies, agreements and supporting files in place before anyone asks for them.
Provisions, returns and review
Provisions for each reporting date, returns for each company, and a yearly review of the structure against how the business has changed.
Key facts
- Deliverables
- Structure papers, intercompany policies and files, tax provisions and returns
- Frameworks
- IAS 12 and IFRIC 23 under IFRS, IFRS for SMEs, and ASC 740 under US GAAP
- Review
- A partner reviews every computation and memorandum before release
- Coordination
- Working with your auditors, legal counsel and advisers in other countries
For a group selling into several US states, our sales and use tax service covers nexus reviews, state registrations and returns.
Questions
Can you work alongside our existing tax advisers?
Yes. A group often keeps local advisers to file in each country and asks us to coordinate: setting group policy, preparing the provision, and making sure every jurisdiction works from the same facts and the same intercompany figures.
When should we involve you in a transaction?
As early as possible, ideally before heads of terms are agreed. Choices such as whether to buy shares or assets, and which company makes the acquisition, are difficult to change once a deal is signed.
Does every group need transfer pricing documentation?
Tax authorities generally expect cross-border transactions between related companies to be on arm's length terms and supported by evidence. Whether a formal master file or local file is required depends on each country's thresholds and rules, so we confirm the position entity by entity.
Can you prepare our tax provision for the audit?
Yes. We prepare the current and deferred tax computations, the tax note and its supporting schedules, and answer the audit team's questions on them until the accounts are signed.
Speak with a partner
Every enquiry is read by a partner and answered within one business day. Meetings are held at our offices, at yours, or by video.