Tax support and tax planning
We will work out where your profit gets taxed before the structure is fixed: what each country may reach, what a treaty actually gives you, and what has to be true in fact.
Employment abroad
Работа за границей
183 days
183 дня
Signatories
Подписали конвенцию
107 jurisdictions
107 юрисдикций
When you need tax planning
You are about to sign a structure
The holding company, the licence and the contracts are drafted. Once they are signed, the tax outcome follows from them, and moving it later means moving the documents.
Your team moved to another country
The people who make decisions now sit somewhere else. Where they work can create a taxable presence for the company, and a letter is one way to find that out.
The same profit is taxed twice
Two countries both say the income is theirs. Relief exists, and it is claimed under conditions that have to be met while the year is still open.
You are opening a second market
A new market brings its own questions: whether a presence appears, what is withheld from payments to you, and whether a company is needed there at all.
Nobody can explain the current setup
The structure grew by adding a company whenever one was needed. What each of them is for was never written down, and the reasoning lives in people’s heads.
An investor asked about the structure
A buyer wants the tax history explained. What you are able to say is limited by what was documented at the time, and that part is already fixed.
What tax planning decides
Planning happens before a position exists. Once the year is closed, the choice has already been made, and what is left is defending it.
Filing what the closed year produced, and standing behind it when the authority asks, is corporate tax support. Choosing a preferential regime and testing what qualifies is tax incentives and ip-box. This page is the decision that comes before either of them.
What you get
- A written tax position
- The reasoning behind each choice
- A calendar of things to elect
- Evidence gathered while current
- One story for every reader
What we decide with you
- Where each stream of profit arises: who decides, who performs, and what the paperwork commits you to.
- Who inside the group owns the rights to the product, and what it charges itself to use them.
- Where the people who make decisions will sit, and what that creates for the company.
- Which elections and registrations have to be made in advance, because they cannot be made backwards.
What a treaty can do
A treaty between two countries decides which of them may tax what, and can lower or remove a charge the other would make. It binds only the two that signed it.
The model text treaties are built on leaves pay for work done abroad to the home country only where three things hold together: the stay is no more than 183 days in any twelve-month period, the employer paying is not resident there, and no taxable presence there bears the cost. A model is not law anywhere by itself: it works through the treaties two countries actually signed.
Treaties also move under you. A convention signed by 107 jurisdictions rewrites the treaties between those of them that ratified it, and one thing it writes in is that a benefit is refused where obtaining it was one of the principal purposes of the arrangement, unless granting it fits what the provision was there for.
Formats of work
A decision before you sign
We will take one planned step — a new company, a market, a move of the rights — and set out what it does to where the tax falls, before anything is signed.
A review of the structure
We will read the structure you have, say what each company is doing for tax purposes, and mark every place where the documents and the facts disagree.
A position written down
We will write the reasoning for a treatment you intend to rely on, with the evidence behind it, so it can be handed to whoever asks later.
Alongside the filing year
We will stay with the structure through the year, so elections are made in time and a change in the business reaches the position while that is still possible.
Sources: the model text treaties follow leaves pay for work done abroad to the home country only where the stay is no more than 183 days in any twelve-month period, the employer paying is not resident there and no taxable presence bears the cost. The convention rewriting existing treaties had 107 signatories, 93 having deposited ratification, at 18 June 2026.
Stages of work
Reading the structure as it is — 3–5 working days.
We start from what exists: the companies, who owns them, the agreements between them, where the people work and which returns are already filed. Positions taken in earlier years come first: a plan that contradicts them adds a second problem.
Mapping where the profit arises today.
We will follow every sizeable stream from the first conversation to the payment, so the answer rests on who did what and where, under whichever agreement governs it.
A customer abroad settles nothing by itself.
Testing the plan against the facts.
We will take the structure you have in mind and ask what has to be true for it to hold: who decides, who performs, who employs and what each company is paid for.
Where the facts cannot be arranged that way, the plan is what changes: an arrangement existing only on paper is the one a treaty benefit is refused for.
Choosing between the routes, with numbers.
You will see each route priced: the tax it leaves in each country, what it costs to run every year, and what must be registered or elected first.
Writing the position and its evidence.
We will write down the treatment, the reasoning and what supports it, in the form it would be handed over in, and you approve it knowing what it rests on.
Carrying it into the filing year.
The position goes to whoever prepares the return, with the dates by which something has to be elected, registered or told to an authority.
Preparing and defending that return is corporate tax support. Whatever else we handle around taxes and books is gathered in the Tax & Accounting area.
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