Identification of risks related to new regulatory requirements

Tax authorities across the globe are increasing their efforts in combating abuse of preferential tax treatment for international transactions. Requirements for countering such abuse are implemented both nationally and internationally, which reduces the efficiency and applicability of traditional mechanisms of and approaches to tax planning.

In light of changes in legislation and practices, it is crucial to timely identify and mitigate tax risks that may affect businesses, including that of challenging applicability of the tax benefits provided for by double taxation treaties, etc.

Deloitte's International Tax team provides a wide range of services to its clients, including:

• Diagnostics of the existing organizational structure of a business for tax risks based on effective legislation, international treaties, OECD best practices, BEPS Action Plan, legislative initiatives on “deoffshorization”, international information-sharing initiatives, CRS/FATCA practice, European anti-money laundering initiatives, DAC6 impact assessment etc.
• Recommendations on how to ensure the required presence (“substance”) of a company in a foreign jurisdiction, both in terms of compliance with local legislation and risk mitigation of failure to apply preferential tax rates of withholding tax on the relevant income
• Recommendations on improvement of international tax model
• Assistance with preparation of the defence files (beneficial owner and/or principle purpose tests)