Major developments are currently in progress with regards to Intellectual Property (IP) tax regimes (IP-Boxes) as part of the Organisation’s for Economic Co-operation and Development (OECD) Action 5 of the Base Erosion and Profit Shifting (BEPS) Action Plan.
According to BEPS Act. 5 IP-Boxes need to implement a so-called “Nexus-Approach, meaning that there should be a direct link between R&D expenditure, generated income and tax benefits.
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We take care of the whole process, from Accessing your personal circumstances, Tax Consulting and Advisory to suit fit your needs and implementation of better suitable structures.
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Nowadays it is important to have ever increasing OECD Standards in mind to avoid possible Tax and Criminal Allegations through non-compliant and validated Corporate Structures. Speak to us to find out your Alternatives.
It is surely not forbidden to own an Offshore Company for a legitimate purpose. However, if the only purpose of your Offshore entity is Tax Avoidance or even worse Tax Evasion, you should reconsider all options.
Speak to us to find more about how to comply with national Tax rules.
Action 3 of the BEPS ACTION PLAN stresses the need to address base erosion and profit shifting using a controlled foreign company (CFC) rules. Many countries already have CFC rules, but these rules do not always counter BEPS in a comprehensive manner.
While CFC rules in principle lead to inclusions in the residence country of the ultimate parent, they also have positive spillover effects in source countries because taxpayers have no (or much less of an) incentive to shift profits into a third, low-tax jurisdiction.
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