Tax & Accounting

We build a position that survives examination: genuine substance (office, staff, decision-making), the correct choice of tax treaties, and transfer-pricing documentation with no gaps. We do not propose aggressive schemes without substance — they invite reassessment.

Substance is a company's real economic presence in a jurisdiction: staff, premises, and management decisions taken locally. Without it, tax authorities and banks treat the company as artificial, which leads to treaty benefits being denied and accounts being frozen. We model the required level of substance before any restructuring.

If there are transactions between related parties within the group (IP licensing, intra-group services, financing), then yes — the applicability threshold in most jurisdictions is lower than commonly assumed. We prepare a master file and local documentation so intra-group dealings cannot be challenged.

Bookkeeping, preparation of mandatory filings, calculation and submission of taxes (CIT, VAT/GST where applicable) and maintenance of corporate compliance. The scope is tailored to the structure — from a single company to a multi-jurisdictional group.

No. Claiming treaty benefits requires a certificate of tax residency and passing the principal purpose test (PPT) — the company must have a genuine commercial reason to exist, not merely a tax one. That is why we design the treaty position and build substance together.