Services and management fees
Cross-border fees require function and risk analysis, benefit tests, contracts, invoices and evidence that services were actually performed.
International tax
International structures need payment logic, substance and documentation that fit together.
Management fees, loans, IP, services, distributions, withholding taxes and substance costs are often assessed together by banks, advisers and tax authorities.
Core issues
Loans and interest
Intra-group loans need commercial terms, repayment capacity, source of funds, withholding-tax review and bank-facing explanation.
People, place and decision route
Substance is not a slogan. Decision makers, premises, contracts, accounting and board records must support the structure.
Group-level visibility
Larger groups need to know whether minimum-tax, CbCR or local reporting questions affect the structure.
Review questions
- Which payments are planned between entities and jurisdictions?
- Which entity performs which function and bears which risk?
- Is there a written agreement, invoice logic and evidence of actual performance?
- Do withholding tax, treaty access, beneficial ownership or anti-abuse rules matter?
- Can the same structure be explained to banks, tax advisers and financial authorities?
Practical output
Payment and function chart
Overview of entities, roles, contracts, payments, tax touchpoints and documentation needs.
Withholding and substance matrix
Identification of high-risk payments and missing evidence before implementation.
Local-professional roadmap
Allocation of tax, legal and accounting work to the relevant jurisdictions and admitted professionals.