International Tax Services
At Masson de Morfontaine, our tax professionals are equipped with strong technical knowledge and industry-specific business understanding to help corporations and individuals achieve tax efficiency while meeting the highest standards of compliance.
We are dedicated to partnering with our clients to deliver long-lasting value. Our experienced team of tax experts from around the world can help on a wide spectrum of tax service areas across different sectors:
International Tax Planning
Our deep knowledge and experience enable us to provide you with tax planning solutions throughout whole the investment cycle, including entry, financing, operation, internal reorganization, profit repatriation and exit, helping to withstand the tax challenges and maximize tax value creation opportunities.
We assist with each step of your transfer pricing strategy. Our service capabilities include related party filing, contemporaneous documentation, advance pricing arrangements, transfer pricing investigations, cost sharing arrangements, tax aligned business model optimization and transfer pricing due diligence. We are experts in OECD’s BEPS project and Country-by-Country Reporting.
Learn more about our Transfer Pricing services
Mergers & Acquisitions
Our network of professionals combines worldwide understanding and deal experience with knowledge of local tax jurisdictions. We assist businesses with cross-border M&A and other transactions. We are dedicated to be the premier provider of M&A tax services with a reputation for outstanding quality and seamless client service.
Domestic corporations encounter various tax issues when expanding overseas. Tax compliance is of paramount importance both from a reputational and cost perspective and each jurisdiction has its own complexities to consider. Besides, there is a number of opportunities to optimize cash flow and maximize value to shareholders through tax-efficient planning. Masson de Morfontaine brings together international perspectives and practical experience to provide comprehensive tax services tailored for domestic enterprises seeking to succeed in overseas markets.
Tax Dispute Resolution
It is imperative for corporations to be proactive with potential tax controversies and to be ready to respond to a local tax investigation. It is prime important to have the appropriate strategies in place to take control of the dispute resolution process. Masson de Morfontaine has tax specialists with deep technical knowledge, understanding of local practices, strong relationships with government officials and effective tax negotiation skills to provide you with top-quality tax controversy mitigations.
High Net Worth Individuals (HNWI)
We possess significant experience and resources such as immigration and real estate in order to help HNWI to make their investments in overseas countries by way of formulating and implementing efficient tax structures as well as related compliance matters.
Masson de Morfontaine comprises highly experienced professionals who have a broad knowledge of the complexities inherent in remuneration and tax compliance for both employers and employees. For both local and international clients, we can review your current policies and procedures to provide you with advice which not only reflects the current practice in your industry, but fosters efficiency and tax effectiveness of your remuneration arrangements. We have ample experience in employment structures, equity based compensation and other incentive awards, severance arrangements and tax audits.
Transfer Pricing Services
Masson de Morfontaine assists with each step of your transfer pricing strategy. Our service capabilities include related party filing, contemporaneous documentation, advance pricing arrangements, cost sharing arrangements, transfer pricing investigations, business model optimization and transfer pricing due diligence. We are experts in OECD’s base erosion and profit shifting (BEPS) project and Country-by-Country Reporting.
We can assist you with review and / or preparation of contemporaneous documentation by virtue of the tax authorities' requirements. We help multinational corporations to ease the overall compliance burdens and mitigate the potential risks of transfer pricing investigations and special adjustments due to non-compliance.
Advance pricing arrangements (APA)
We help to prepare and apply for APA and advise you prior, during and after the negotiation and agreement with the tax bureau. For instance, we can select the appropriate transfer pricing methodologies and underlying assumptions, prepare supporting documentation for the APA application, negotiate with the tax bureau and prepare annual reports during the APA implementation period.
Cost sharing arrangements (CSA)
We help to design and implement CSA, the required registration of the CSA with the tax bureau. For example, we can assess feasibility and acceptability of CSA. We can also design and / or implement an appropriate and applicable cost sharing model. While building and implementing the model, we can also intervene in discussion of the CSA with tax officials and file the formal application.
Transfer pricing investigations
We possess significant experience in assisting clients to respond to transfer pricing investigations from tax authorities. Our diverse network comprises of seasoned tax professionals with in-depth knowledge of local tax rules and economic analysis. Our professionals can discuss the appropriate response strategy options, conduct robust economic analysis, negotiate with tax officials and help enterprises obtain legal remedies, where applicable.
Business model optimization
Multinational corporations are constantly pursuing optimization of their supply chain as their operations become global. As transfer pricing has both direct and indirect tax risk implications for the whole supply chain, it is important that the tax consequences and opportunities arising from a business change in the supply chain are included as an integral part of the change process. We realize the importance of aligning transfer pricing and the selected business model of clients to deliver improved overall benefits. Our transfer pricing professionals work closely with various tax and advisory professionals in order to evaluate, formulate and implement dynamic transfer pricing strategies that are conform to clients' worldwide business goals.
Transfer pricing due diligence
When multinational corporations go for M&A, transfer pricing issues may impact the target enterprise's fair value and the acquisition price. Transfer pricing may also affect acquirer's equity and profitability after M&A. Besides, the acquirer often needs to deal with tax liability arising from the acquiree's transfer pricing arrangements.
We perform a comprehensive analysis of the target enterprise's potential transfer pricing risks and offer solutions that mitigate them and help enterprises enhance synergy subsequent to M&A. It is critical to conduct this exercise prior to the deal in view to effectively identify the potential implications of transfer pricing on the deal structure.