United States · International Tax
Restructuring a US group's global tax position
The challenge. A US technology manufacturer expanding into Asia faced overlapping tax exposure, uncertain transfer pricing and the risk of double taxation on intercompany royalties across four jurisdictions.
Our approach. We mapped the group's value chain, reviewed applicable tax treaties and redesigned its intercompany agreements. We prepared transfer pricing documentation aligned with OECD guidelines and IRS requirements.
The outcome. The client adopted a defensible, treaty-based structure, secured withholding tax relief on cross-border payments and entered audits with complete documentation and a clear compliance calendar.
