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The challenge

The solution

The outcome

Requirements

• Define business objectives and cross-border expansion plan
• Identify all countries/jurisdictions involved and applicable tax regimes
• Map legal entity structure, ownership chain, and intercompany relationships
• Assess tax residency, permanent establishment, and source rules
• Review corporate income tax, withholding tax, VAT/GST, customs, payroll, and local levies
• Analyze double tax treaties and treaty relief opportunities
• Evaluate transfer pricing policies, intercompany agreements, and documentation requirements
• Plan for profit allocation, IP ownership, and financing structures
• Identify available incentives, exemptions, credits, and special regimes
• Model total tax burden under current and proposed structures
• Assess anti-avoidance rules, CFC, BEPS, and substance requirements
• Set up compliance calendar for registrations, filings, payments, and reporting
• Implement tax governance, controls, and data collection processes
• Coordinate with legal, finance, treasury, and operations teams
• Review currency, repatriation, and cash tax management
• Monitor legislative changes and perform periodic strategy reviews
• Obtain local expert advice where needed and document positions taken

Best practices

• 1. Define clear cross-border tax objectives and risk tolerance before sourcing services.
• 2. Verify provider expertise in the specific jurisdictions where you operate.
• 3. Assess experience with VAT/GST, transfer pricing, withholding tax, and permanent establishment issues.
• 4. Require a strong understanding of your industry, supply chain, and operating model.
• 5. Confirm access to qualified local advisors or in-country tax networks.
• 6. Evaluate the provider’s ability to handle multi-country compliance and reporting deadlines.
• 7. Ensure they use robust tax technology, data controls, and workflow management.
• 8. Request documented methodology for tax positions, filings, and advisory recommendations.
• 9. Check for strong governance, confidentiality, and data security practices.
• 10. Review the provider’s track record on audits, disputes, and tax authority inquiries.
• 11. Establish clear service-level agreements, deliverables, and escalation procedures.
• 12. Validate fee structure transparency and identify all potential hidden costs.
• 13. Confirm the ability to integrate with finance, legal, and ERP systems.
• 14. Demand regular updates on changing tax laws, treaties, and regulatory developments.
• 15. Measure performance through KPIs, periodic reviews, and continuous improvement plans.