Expatriate tax services

The international relocation of executives and key employees is a common feature of today’s business world. Such relocations involve moving between countries with differing immigration, social security, work permit and taxation laws. To minimise inconvenience and to also benefit from tax concessions, expatriate executives and employees need timely advice on the consequences of these differences. They need tax professionals who can provide a combination of local attention and global capabilities. HLB’s skilled team of tax professionals can provide you with the necessary proactive advice and support. Our specialist tax services professionals work together to plan for and provide a wide range of opportunities for both expatriate and inpatriate individuals.

Our approach

• Pre-departure taxation consultation

One of the team members meet with the expatriate individual prior to departure from the home country to explain taxation consequences of departure. Opportunities for tax planning in the home country may also be identified. In addition, details of the expatriate’s situation can be gathered for forwarding to the HLB member firm in the expatriate country.

• Post- arrival taxation consultation

A member of the HLB International representative firm in the host country contacts the expatriate before or on arrival in the host country. Again, the purpose of the meeting is to identify any tax planning opportunities in the host country, including structuring of the expatriate’s remuneration to benefit from any host country tax concessions.

• Tax equalization and tax protection calculations

Many employers offer either tax equalization or tax protection plans to employees relocating internationally. We can calculate the tax equalisation or tax protection adjustments required under such plans. We can also assist employers in the design and implementation of these plans.

• Property and investment planning

Moving between countries can have tax consequences for an individual’s property and investments such as deemed capital gains tax consequences. With prior consultation these consequences can be identified and timely planned in order to reduce or avoid their impact.

• Estate planning and treaty interpretation

A consequence of relocating internationally is that an individual may become subject to the estate duty laws of the host country. Again, planning before the individual’s arrival in the host country can reduce or avoid the exposure to possible estate duty in the host country. A number of countries have entered into estate and gift tax treaties on which, if applicable, we can advise.

• Trusts and investment holding structures

Trusts and similar entities are usually subject to special tax provisions. We can advise on the effect of these provisions for individuals who benefit from or control such entities and who are moving between countries. Advice can also be given on the establishment of trusts or investment holding structures for individuals relocating internationally.

• Pension plan entitlements

Executives and employees working in a host country may be required to accrue pension plan benefits in the host country. Similarly, there may be consequences for the individual’s home country pension plan benefits. Member firm experts can advise on the consequences of accruing host country pension plan benefits and any consequences for the home country pension plan benefits.

• Preparation of income tax returns

Our tax experts can prepare home and host country income tax returns for expatriates, having regard to their particular circumstances.

• Immigration and work permits

Host country immigration and work permit applications often require specialized advice. This can be provided either by the local firm or by specialist practitioners from within the HLB network.

Indirect tax compliance for e-commerce businesses

In 2017, 1.66 billion people made online purchases and e-retail sales amounted $2.3 trillion world-wide. Projections show this amount will grow up to $ 4.48 billion by 2021. It’s clear that companies around the world are increasingly seizing the opportunities of the internet to sell their goods to new consumer bases in markets far beyond their home countries. But with new opportunities also come new challenges. As an online seller, it is important you meet your indirect tax obligations as part of the sales process. When using fulfilment by Amazon (FBA) an obligation to register for indirect tax locally can be created. HLB has developed a cutting-edge solution called amavat® to help you guide through this process.

Using amavat®, we offer indirect tax compliance services in many countries. Through our global network of tax experts, we offer one point of contact in each country for online sellers with multiple indirect tax registration. Our goal is to limit the commercial impact of distance selling regulations on your business, while ensuring you remain fully compliant.

Indirect Tax Services

In today’s globalized world more goods and services are crossing international borders than ever before, due to an increasing international customer base or complex supply chain. As a result, you may be facing indirect tax obligations in multiple countries. In some cases, even in the countries your customers are based in. A lack of visibility and control around indirect tax compliance can cause late filings, late payments of VAT/GST, late registration and incorrect postings on returns, causing increased cost of compliance and the risk of financial penalties. HLB’s global team of indirect tax experts can help you stay on top of your indirect tax obligations and  comply with regulations across the jurisdiction you do business in.

What we offer

HLB’s Indirect Tax services team consists of tax experts across the many countries we operate in. Whether your project is international, regional or domestic, we match the right people in the required jurisdiction, to make-up the best team for your business needs. We provide tailored indirect tax services including:

• Identifying where transactions are taxed
• Provide indirect tax advice on your everyday operations
• Registration of local indirect tax in countries where taxable transactions are undertaken
• Preparation and filing of indirect tax returns
• Advisory services against authorities including the filing of lawsuits
• Refunds of applications for non‐registered entrepreneurs
• Training of staff

Transfer Pricing

Transfer pricing is considered the most important international tax issue facing business operations of companies operating across borders. However, the laws surrounding transfer pricing are becoming ever-more complex and the tax affairs of multinational companies are facing increasing scrutiny from media and the public. To minimise risk and to make sure you take the right approach to compliance, you need expert advice. Our HLB Transfer Pricing professionals invest their time in getting to know your business needs. We can help you create strategic advantage by using transfer pricing as a core management tool. Our experienced professionals go beyond simply avoiding the threat of double taxation. We help you by dealing with the various taxing authorities so that you can focus on your business objectives.

Are you prepared for a transfer tax audit?

A recent survey of multinational companies found there is a 50% chance of having to defend profits in a transfer pricing examination anywhere in the world. In cases involving adjustments, nearly half the firms reported that transfer pricing adjustments resulted in double taxation.

Transfer pricing is one of the most disputable arenas of international tax. If your firm faced a transfer tax audit, how well would you be able to defend your profits to authorities? Instead, let us help you make transfer pricing part of your global strategic planning. Taking a proactive approach to transfer pricing can minimise your company’s worldwide taxes, coordinate your global business strategy and improve profitability.

Transfer Pricing is a dynamic issue. For example, the strict US-initiated transfer pricing model is quickly spreading to other countries world-wide and adding to the strain multinational companies face. An integrated global documentation approach to transfer pricing can help companies successfully compete while minimising the risk of double taxation.

How we can help

The Transfer Pricing experts within the HLB network will work with you to develop a transfer pricing strategy suited to your multinational company. Your objectives will depend upon your firm’s overall structure and international tax planning position. For example, if you have significant offshore low-tax manufacturing operations, you may prefer to maximise the amount of income earned by these operations. Or if most of your company’s transactions are between high-tax jurisdictions, it may be more important to minimise the chance of double taxation. Additionally, your HLB team will prepare the documentation necessary to prevent any transfer pricing penalties in the event of an adjustment upon audit.

Your HLB team will assist in defining your strategy, helping you evaluate the many factors affecting your transfer pricing policy – including the dispute resolution forum you prefer. You may choose to resolve potential disputes by obtaining an Advance Pricing Agreement (“APA”), in which case your approach should be tailored to the Tax Authorities’ current APA process. Or if your company expects to resolve transfer pricing disputes through competent authority, your analysis should focus on methods most likely to be acceptable to both sides.

Taking a team approach

Optimising your company’s transfer pricing strategy calls for a team approach, with your accounting, finance and sales departments working with HLB experts in international taxation and finance. This analytical process includes:

• Clarifying the transaction to be analysed and confirming that their structure and risk allocations serve your firm’s transfer pricing objectives.
• Preparing functional profit and loss statements for all legal entities involved in the transaction being analysed.
• Analysing potential transfer pricing methods to determine which are best for your company’s circumstances.
• Conducting a thorough comparables search both internally and externally
• Reviewing pricing methodologies to select the best method and developing support for the chosen methodology.
• Devising a documentation approach for avoiding penalties.
• Considering the advisability of applying for an APA or a mini-APA.
• Evaluating whether any additional work is needed to defend the transfer pricing methods used in foreign countries.