International Structures

International Structures often find their origins through international tax advisers who have long been aware of the opportunities, which exist for improving overall tax efficiency by using the special low tax regimes, offered by high tax countries seeking to encourage international business. However, successful implementation of such structures is dependent on a wide variety of issues, often relating to matters such as anti-avoidance provisions, double tax avoidance, controlled foreign company, management, control tests and provisions, transfer pricing, thin capitalization, participation exemptions, capital gains tax and a myriad of other ever-changing tax regulations. More recently, the weapons contained in the armory of the tax collectors have been supplemented by exchange of information treaties and provisions. In fact, almost all countries offer tax regulations of one kind or another to encourage inward investment. Corporate Financial Solutions is experienced in many international structures.