Corporate tax support
We will choose and defend the tax positions your company files under: the return and the computation, which country may tax what, prices inside the group, and the evidence.
Global minimum tax
Глобальный минимум
15%
15%
Group threshold
Порог для группы
750 million euro
750 млн евро
When you need corporate tax support
The first return is coming
The company has traded for a year, and nobody has yet decided how its income is classified. The first return sets positions that repeat every year after it.
You invoice across borders
Contracts are signed in one place, the work is done in another and customers are somewhere else again. Which country may tax which part stops being obvious.
Companies in the group bill each other
One company charges another for services, licences or finance. If nobody wrote down why the price is what it is, the price gets decided later by someone else.
A letter arrived from the tax authority
A question came with a deadline attached. What you can answer is limited by what the file already contains, and the response window is short.
Someone files, but nobody decides
The return goes out every year and the positions inside it were never chosen by anyone. That works until the first time it is examined.
What corporate tax support covers
A tax position is an argument about facts, and it is strongest when the legal analysis and the transaction evidence describe the same operations. The return is where that argument gets written down.
This is the running compliance, and it works from closed books: keeping them closed is accounting support. Choosing a regime to lower the rate is a separate question and belongs with incentive regimes.
What you get
- A return you can defend
- Every position written down
- Prices inside the group documented
- Deadlines met without a scramble
- One answer to the authority
What we file and defend
- The return and the computation, reconciled to the accounts line by line.
- Which country may tax each profit stream, read from contracts, people and delivery records rather than the customer’s address.
- Deductions, losses and adjustments, each with its reasoning kept alongside.
- Pricing between companies in the group, and the file that supports it.
- Correspondence with the authority: questions, assessments and objection deadlines.
What stays on your side
- Signing: the return goes in under your signature, or a power of attorney you give us.
- The commercial facts: who does the work, where, and what the contract says.
- Payment of the tax itself, on the dates the country sets.
- Books and statements: they come from accounting support, a separate service.
Where the group is large
Where a country has brought in the global minimum tax, a group above its threshold has an extra layer of rules on top of each country’s own. They reach multinational groups of that size only: a company whose group is below the threshold is outside them entirely. We will tell you which side you are on, because the answer changes what has to be collected during the year.
Formats of work
Annual return and computation
We will prepare the return and the computation from the closed accounts and take them through to filing. One main activity, one set of positions.
Review before filing
Your accountant prepares, and we will test the material positions and the evidence behind them before anything is submitted. For teams that already file themselves.
Group pricing file
We will document what companies in the group charge each other and why that price holds. For groups trading with themselves.
Questions and assessments
We will answer the authority, keep every response inside its deadline and manage the objection window. For a company already under enquiry.
Sources: the Global Anti-Base Erosion Model Rules of the OECD set a minimum rate of 15% and reach multinational groups with consolidated annual revenue of 750 million euro or more in at least two of the four preceding years; below that, a group is outside them. They take effect through each country’s own law, which also sets the rate, the filing date and what has to be registered.
Stages of work
Each year repeats this from the top, and your format sets where we join it.
Establishing where you stand — 3–5 working days.
We will identify the periods and returns already filed, prior positions, losses carried forward and open correspondence.
We will check separately which registrations the positions in the return depend on, and flag any that are missing before the first filing rests on them.
Reconciling the accounts to the computation.
We will tie the statements, the trial balance and the tax computation together so that every difference between accounting and taxable profit has a reason recorded.
A computation that cannot be traced back to the accounts has to be explained later, when the explanation is harder to assemble.
Mapping where the profit is earned.
We will trace each material revenue stream through negotiation, contracting, performance and payment, so that where a country taxes by where profit arises, the position rests on what was done and by whom.
A customer abroad, a foreign bank or a remote director do not settle this, and different profit streams can need different answers.
Pricing inside the group.
Where companies under one owner charge each other, the price has to be one independent parties could have agreed, and the file has to say why.
We will build that file while the transactions are current, because the people, emails and decisions behind the price are still there.
Preparing the filing position.
We will draft the return entries, adjustments, supplementary forms and written explanations from the evidence and put them in front of you before filing.
You approve the material positions knowingly, each with what supports it and what the exposure is if it is challenged.
Assessments, questions and deadlines.
We will log acknowledgements, assessments and payment dates, and answer every question out of the file we already hold.
Objection periods are short, and an objection does not pause payment by itself, so the two are tracked separately.
Carrying it into next year.
We will carry this year’s positions forward, together with anything an examination changed, so the next return opens from a settled starting point.
The rest of our tax and reporting work is in the Tax & Accounting area.
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