Transfer Pricing for Small Teams: The Rules Don’t Care That You’re Lean
Small teams do cross-border work like multinationals. Transfer pricing rules still apply, especially for IP, management fees, and services. Use a TP-lite toolkit: functional analysis, simple pricing method, agreements, and invoice trails before an audit builds the story for you.
Treaties Don’t Save You If Beneficial Ownership Is Weak
Treaty rates are not automatic. If beneficial ownership looks thin, authorities can deny relief using anti-abuse rules, conduit indicators, or PPT logic. Build ownership and control evidence that survives challenge, and use the BO strength ladder.
Latest Articles
Second Citizenship ≠ Second Tax Plan (Here’s What Actually Changes)
A new passport can improve access, mobility, and optionality. But tax outcomes still follow residency, source rules, and reporting regimes. For US citizens, taxation can follow citizenship. Here is what changes, what does not, and how banks read it.
Withholding Taxes: The Silent Killer of Cross-Border Returns
Cross-border returns often die by a thousand cuts: withholding tax, missing forms, rejected treaty claims, and slow reclaims. Model gross-to-net by income type, treaty position, and documentation. Use the WHT engine and the Modeling Sheet.
Transfer Pricing for Small Teams: The Rules Don’t Care That You’re Lean
Small teams do cross-border work like multinationals. Transfer pricing rules still apply, especially for IP, management fees, and services. Use a TP-lite toolkit: functional analysis, simple pricing method, agreements, and invoice trails before an audit builds the story for you.
Treaties Don’t Save You If Beneficial Ownership Is Weak
Treaty rates are not automatic. If beneficial ownership looks thin, authorities can deny relief using anti-abuse rules, conduit indicators, or PPT logic. Build ownership and control evidence that survives challenge, and use the BO strength ladder.
Entity Choice Is Now a Governance Decision, Not a Tax Trick
Entity choice used to be a rate conversation. Now it is governance, control evidence, investor acceptability, and bankability. If management and decisions happen in one place but paperwork lives in another, your structure becomes fragile. Here is the scorecard.
Permanent Establishment: When “Remote” Creates Local Taxable Presence
Remote work and roaming teams can create a taxable presence without a local entity. A sales rep closing deals, a founder deciding strategy while traveling, or long-term contractors can trigger PE. Here is a red-flag matrix and mitigation playbook.
Substance Isn’t an Office. It’s Decision-Making, People, and Paper Trails
“Substance” is not a coworking desk and a mailbox. Authorities and banks look for who decides, where decisions happen, and whether records prove it. Here is a practical governance and documentation system that stands up to scrutiny.Latest Articles
Second Citizenship ≠ Second Tax Plan (Here’s What Actually Changes)
A new passport can improve access, mobility, and optionality. But tax outcomes still follow residency, source rules, and reporting regimes. For US citizens, taxation can follow citizenship. Here is what changes, what does not, and how banks read it.
Withholding Taxes: The Silent Killer of Cross-Border Returns
Cross-border returns often die by a thousand cuts: withholding tax, missing forms, rejected treaty claims, and slow reclaims. Model gross-to-net by income type, treaty position, and documentation. Use the WHT engine and the Modeling Sheet.
Transfer Pricing for Small Teams: The Rules Don’t Care That You’re Lean
Small teams do cross-border work like multinationals. Transfer pricing rules still apply, especially for IP, management fees, and services. Use a TP-lite toolkit: functional analysis, simple pricing method, agreements, and invoice trails before an audit builds the story for you.
Treaties Don’t Save You If Beneficial Ownership Is Weak
Treaty rates are not automatic. If beneficial ownership looks thin, authorities can deny relief using anti-abuse rules, conduit indicators, or PPT logic. Build ownership and control evidence that survives challenge, and use the BO strength ladder.
Entity Choice Is Now a Governance Decision, Not a Tax Trick
Entity choice used to be a rate conversation. Now it is governance, control evidence, investor acceptability, and bankability. If management and decisions happen in one place but paperwork lives in another, your structure becomes fragile. Here is the scorecard.
Permanent Establishment: When “Remote” Creates Local Taxable Presence
Remote work and roaming teams can create a taxable presence without a local entity. A sales rep closing deals, a founder deciding strategy while traveling, or long-term contractors can trigger PE. Here is a red-flag matrix and mitigation playbook.
