Over the past few years, international corporate tax has undergone more development than it had for many past decades. The entire framework has significantly changed under the pressure of national legislation and a new multilateral approach aimed at facing the challenges of technology, tax avoidance, and globalization.

Our International Corporate Tax team will advise on the impact of these developments on your business and on your risk management strategy, so as to ensure a proper future alignment of corporate structures and economic flows. Whether it be the assessment of a project PE in view of the MLI implementation, or the definition of the debt allocation policy based on the ATAD regulations, or the potential double taxation deriving from CFC legislation, our advisory derives from a proper focus on your business rationale and from a constant attention to the global scenario.

Our services include:

• Assessment of permanent establishments, with special expertise on international construction and project consulting
• Support in the definition of the economic model of permanent establishments under the AOA
• CFC legislation and dividend flow optimization
• Application and interpretation of double taxation agreements
• Avoidance of final double taxation through mutual agreement and arbitration procedures
• Reporting obligations regarding cross-border structuring (DAC6)
• Business restructuring, company migrations

The WTS Global International Corporate Tax Service Line is the best complement to our Italian office: it brings together tax experts from more than 100 countries who have extensive knowledge in handling cross-border projects and many industries, and benefits from the research work of our European Tax Law Center.

Please feel free to contact us to discuss the implications of recent and forthcoming global measures on your business.