At 42Tax we do fire fighting and fire prevention, but if you want to geek out over what that could look like, this list is your friend
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Our two main areas of interest are International Tax and Transfer Pricing.
Below you can find examples of what that can look like in practice.
And why are there only 42 examples on the list? Well ... you guessed it.
1/ Determining their Danish withholding tax position for private equity including tax qualification of foreign entities (opaque or transparent), qualifying the beneficial owners, hybrid financial instruments and entities, etc.
2/ Danish withholding tax position for foreign groups with Danish subsidiaries
3/ Cross-border business restructurings including but not limited to transfer of IP, customer lists and inventory, etc. to affiliate companies abroad and the DAC6 reporting
4/ Danish permanent establishment assessments including assessments related Denmark’s Exclusive Economic Zone
5/ Foreign permanent establishment assessments.
6/ Determining their Danish CFC position including detailed qualifications of income and cost streams.
7/ Global, European and Danish post-acquisition integration, restructuring and Legal Entity Rationalizations.
8/ New Market Entry approaches and dos and donts.
9/ Assessment of the tax impacts of cross-border structuring including but not limited to mergers and carve-outs.
10/ Nordic hub establishments.
11/ Establishment of shared service centers abroad.
12/ Qualifications and calculations under the interest deduction limitation rules.
13/ Assessment of hybrid mismatch positions (financial instruments, hybrid entities and permanent establishments).
14/ Assessment of the possibility of utilization of final tax losses abroad.
15/ Assessment of how potential restructurings, divestments, etc. impact the recapture balance in international joint taxation.
16/ Change in transfer pricing set-up and assessment of potential DAC6-reporting requirements.
17/ Assessment of whether operational companies with a platform access are comprised by the digital platform reporting rules (DAC7).
18/ Assessment of the tax impact of treasury functions repatriation strategies.
19/ Debt refinancing (internal and external).
20/ Setting up an appropriate tax operating model.
21/ The preparation of full transfer pricing documentation package including master file, local file and economic analysis.
22/ The preparation of database analysis for goods and services transactions to determine or justify the use of arm’s length pricing.
23/ The preparation of economic analysis for royalty rates used in license transactions, including internal CUP analysis or database analysis.
24/ The preparation of interest rate analysis to determine or justify the use of arm’s length pricing of current credit facilities, term loans and more specialised loans.
25/ The preparation of guarantee fee analysis to determine or justify the use of arm’s length pricing of financial or performance guarantees.
26/ The preparation of advanced profit split analysis when more parties contribute unique and valuable intangible assets or significant functions, or the transactions are highly integrated and cannot reliably be analysed on an isolated basis, or the risk is significant and cannot reliably be analysed on an isolated basis.
27/ Setting up and implementing an operational methodology for allocating shared services to benefitting related parties.
28/ Country-by-Country Reporting, which includes both notification procedures for the subsidiaries and compilation and submission of data for the reporting entity.
29/ Tax and transfer pricing audits, including the initial steps of information gathering and submission and preparing a strategy.
30/ Obtaining relief from double taxation procedures including EU arbitration, double tax treaty arbitration and general mutual agreement procedures. Including information gathering and preparing a strategy.
31/ The preparation of a risk assessment for management reporting in connection with tax audit, relief from double taxation procedures, and litigation procedures.
32/ Filing and finalising Advance Pricing Arrangements (APA). With an APA the taxpayer obtains certainty for specified transactions for a specified period of time. This involves preparing a strategy for the APA, negotiations and other discussions with the tax authorities, information gathering and preparing of the application and replies to follow-up questions.
33/ Valuation of business transfers, sale of intangible assets and other assets and preparing of a defense file as an addendum to the regular transfer pricing documentation.
34/ Assessment of penalties for non-compliance, e.g., transfer pricing documentation not submitted within the deadline or found insufficient, including an assessment of gross negligence and dialog with the tax authorities.
35/ Strategic advice on new intercompany transactions or realignment of existing intercompany transactions, including value chain assessment, control over risk, functional profiles, and significant people functions.
36/ Value chain analysis including the identification of people, functions, assets and risks, and how system profit expectedly should be attributed to the group entities by identifying and assessing the value drivers.
37/ Assessment of the disclosure obligation for controlled transactions. Companies may have to disclose controlled transactions on their tax return, even when it is not obvious that they are a part of a group, e.g., common shareholders as a bigger group. We have experience with determining when a company should disclose, when they are a part of complex legal structures or have common shareholders.
38/ Advice on the attribution of profits to permanent establishments. Special rules apply to the attribution of profit, debt, and equity to a branch.
39/ Supporting companies with information requests, gathering and preparing information, and communication with the tax authorities, during tax and transfer pricing audits.
40/ Assistance with preparation of a complaint for the Danish Tax Tribunal, which involves presentation of facts, analysis and conclusions, meetings with the case officers, and representation before the Tribunal.
41/ Second opinon on complex technical issues, strategic important transactions, and fact poor transactions, for management or for potential buyers.
42/ Transfering price indexing with regards to the valuation of towels in intergalactic space travel. Yes, it's a Douglas Adams joke, we know, but if you got to the end of this list, you are probably ripe for a little humor. :-)