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WONE / AREA OF EXPERTISE · ENTER & OPERATE · 02
WORK.
Tax & International Structuring
Cross-border tax architecture, permanent establishment risk, transfer pricing and treaty qualification.
WONE AREA OF EXPERTISE · Tax & International Structuring
HOW THIS EXPERTISE CONNECTS
See where this expertise matters, what it connects to and who may be relevant.
This expertise rarely stands alone. The right answer often depends on the market, the business situation and other specialist needs around it.
AREA OF EXPERTISE
Tax & International Structuring
MARKETS
21
PEOPLE
41
MOMENTS
8
CONNECTED
7
SIGNALS
0
WHEN THIS BECOMES MATERIAL
Leadership triggers, not professional jargon.
Specific business conditions and inflection points that make Tax & International Structuring essential to resolve.
01
Entity ownership, IP holding or holding jurisdictions span multiple tax authorities.
02
Cross-border intercompany charges, royalties, management fees or debt financing commence.
03
Senior leadership, key sales directors or remote teams spend substantial days in an overseas jurisdiction, triggering permanent establishment exposure.
04
The enterprise approaches OECD Pillar Two €750m consolidated revenue thresholds.
Market Entry
Cross-Border Transaction
New Operating Model
Regulatory Oversight
Dispute & Enforcement
FIRST LEADERSHIP DECISIONS
What needs to be decided before work begins?
Specific operational, contractual and structural questions that shape scope, liabilities and timing.
01
What corporate and ownership structure is being proposed?
Direct foreign subsidiary vs branch office vs regional holding entity alters withholding tax rates and repatriation mechanisms.
INPUTS NEEDED
- Ultimate beneficial owners
- Intended capital funding mix
- Projected profit repatriation timetable
02
Where will value, senior personnel and operational decision-making sit?
Substance rules require real board control and commercial activity in the entity jurisdiction to defend treaty benefits and prevent anti-deferral taxation.
INPUTS NEEDED
- Board composition and physical meeting locations
- Local executive headcount
- Office leasing contracts
03
What cross-border flows will occur between group entities?
Intercompany supply, service agreements and shared service allocations must comply with arm's length transfer pricing standards.
INPUTS NEEDED
- Intercompany service catalog
- Benchmarking studies
- Draft Master and Local files
04
What changes if the target market becomes an operating hub rather than a sales destination?
Hub status unlocks regional tax concessions (e.g. Singapore DEI, UAE Qualifying Free Zone) but imposes substance and local expenditure floors.
INPUTS NEEDED
- Local operational expenditure forecast
- Third-party commercial contracts
- Local payroll commitments
WHAT THE WORK MAY INVOLVE
Key execution workstreams across Tax & International Structuring.
The exact scope depends on the target jurisdiction, commercial timetable and business model.
01
Review the proposed cross-border structure
The local professional defines the evidence, scope and deliverables for this specific workstream, taking account of the markets and transaction involved.
02
Identify direct and indirect tax exposures
The local professional defines the evidence, scope and deliverables for this specific workstream, taking account of the markets and transaction involved.
03
Consider withholding, treaty and transfer-pricing issues
The local professional defines the evidence, scope and deliverables for this specific workstream, taking account of the markets and transaction involved.
04
Coordinate implementation across the relevant jurisdictions
The local professional defines the evidence, scope and deliverables for this specific workstream, taking account of the markets and transaction involved.
WHAT OFTEN NEEDS TO MOVE WITH THIS
This expertise rarely stands alone.
Coordinated across interconnected multidisciplinary practice areas. Each connection explains why adjacent disciplines become material to the mandate.
01
Legal & Contracting
Moves with this because: Intercompany agreements must be legally enforceable and match the economic characterisation in transfer pricing files.
02
Corporate & Entity Services
Moves with this because: Corporate form dictates legal ownership, statutory substance obligations, registry filings and local governance.
03
Employment, Payroll & Mobility
Moves with this because: Cross-border employee movement and executive presence directly risk creating corporate Permanent Establishment.
04
Finance & Treasury
Moves with this because: Cash pooling, intercompany debt pricing and currency repatriation must align with thin capitalisation and transfer pricing rules.
05
Transactions & Deals
Moves with this because: Frequently appears with the primary capability
06
Government & Regulatory Affairs
Moves with this because: Frequently appears with the primary capability
HOW THIS CHANGES BY MARKET
The discipline is global. Professional responsibility is local.
See how Tax & International Structuring applies in key jurisdictions based on reviewed Market 360 evidence.
Singapore
VERIFIED
Decision difference: 17% headline tax; 0% capital gains; Section 13O/13U fund incentives; Pillar Two DTT active.
Reviewed Sep 2026
United Arab Emirates
VERIFIED
Decision difference: 9% federal corporate tax; 0% on Qualifying Free Zone Income; documentation for QFZP required.
Reviewed Sep 2026
India
VERIFIED
Decision difference: 22% Section 115BAA corporate tax; rigorous Section 92 transfer pricing scrutiny; mandatory 15CA/15CB certificates.
Reviewed Sep 2026
United Kingdom
VERIFIED
Decision difference: 25% Corporation Tax; Patent Box (10% IP profits); multinational top-up tax; strict diverted profits tax rules.
Reviewed Sep 2026SEE HOW THIS CHANGES BY MARKET
Where do you need Tax & International Structuring?
Choose the market and see how this area of expertise applies there.
MARKET × AREA OF EXPERTISE
Open Tax & International Structuring in the market where the work sits.
01
Kenya
Kenya is covered by WONE for cross-border business discovery, with links to relevant expertise, professionals, industries and market intelligence.
↗ 02Saudi Arabia
A fast-changing market shaped by investment, localisation, infrastructure, regulation and new-sector growth.
↗ 03Italy
Italy is covered by WONE for cross-border business discovery, with links to relevant expertise, professionals, industries and market intelligence.
↗ 04Vietnam
Vietnam is covered by WONE for cross-border business discovery, with links to relevant expertise, professionals, industries and market intelligence.
↗ 05Canada
Canada is covered by WONE for cross-border business discovery, with links to relevant expertise, professionals, industries and market intelligence.
↗ 06Argentina
Argentina is covered by WONE for cross-border business discovery, with links to relevant expertise, professionals, industries and market intelligence.
↗ 07Austria
Austria is covered by WONE for cross-border business discovery, with links to relevant expertise, professionals, industries and market intelligence.
↗ 08United States
A large federal market where state, sector and regulatory differences can materially change cross-border execution.
↗ 09Portugal
Portugal is covered by WONE for cross-border business discovery, with links to relevant expertise, professionals, industries and market intelligence.
↗ 10Colombia
Colombia is covered by WONE for cross-border business discovery, with links to relevant expertise, professionals, industries and market intelligence.
↗ 11South Africa
South Africa is covered by WONE for cross-border business discovery, with links to relevant expertise, professionals, industries and market intelligence.
↗ 12Ireland
Ireland is covered by WONE for cross-border business discovery, with links to relevant expertise, professionals, industries and market intelligence.
↗ 13Greece
Greece is covered by WONE for cross-border business discovery, with links to relevant expertise, professionals, industries and market intelligence.
↗ 14Rwanda
Rwanda is covered by WONE for cross-border business discovery, with links to relevant expertise, professionals, industries and market intelligence.
↗ 15Ecuador
Ecuador is covered by WONE for cross-border business discovery, with links to relevant expertise, professionals, industries and market intelligence.
↗ 16Switzerland
Switzerland is covered by WONE for cross-border business discovery, with links to relevant expertise, professionals, industries and market intelligence.
↗EXACT PROFESSIONAL COVERAGE
41 ELIGIBLE PROFESSIONALS · SHOWING 8
The current capability is verified and explicitly displayed on each card.
Abdul Bagha
Managing Partner
Innovus Risk and Advisory LLP
Exact: Tax & International Structuring
Relevant because: Kenya
OPEN PROFILE →
Abdullah Yousef Alhussaini
Founding Partner
Abdullah Yousef Alhussaini Chartered Accountant
Exact: Tax & International Structuring
Relevant because: Saudi Arabia
OPEN PROFILE →
Alessandro Dagnino
Managing Partner
Lexia Avvocati
Exact: Tax & International Structuring
Relevant because: Italy
OPEN PROFILE →
Andres Fernando Uria Palma
Managing Partner
INTEGRAL PRO S.R.L.
Exact: Tax & International Structuring
Relevant because: Bolivia
OPEN PROFILE →
Chau Kim Hien
CEO
Vina TPT Company Limited
Exact: Tax & International Structuring
Relevant because: Vietnam
OPEN PROFILE →
Chris T.H. Heo
Partner
Faber LLP
Exact: Tax & International Structuring
Relevant because: Canada
OPEN PROFILE →
Daiana Roselli
Senior Manager / Associate
Estudio Canil
Exact: Tax & International Structuring
Relevant because: Argentina
OPEN PROFILE →
Dan Faber
Partner
Faber LLP
Exact: Tax & International Structuring
Relevant because: Canada
OPEN PROFILE →WHEN THIS AREA OF EXPERTISE APPEARS
Business situations that require Tax & International Structuring.
BUSINESS MOMENT 070
Move ownership to a new holding company
Move ownership to a new holding company can involve several connected decisions across markets. WONE helps identify the relevant workstreams, local responsibilities and the sequence in which they need to move.
BUSINESS MOMENT 071
Merge or simplify group entities
Merge or simplify group entities can involve several connected decisions across markets. WONE helps identify the relevant workstreams, local responsibilities and the sequence in which they need to move.
BUSINESS MOMENT 072
Transfer assets between jurisdictions
Transfer assets between jurisdictions can involve several connected decisions across markets. WONE helps identify the relevant workstreams, local responsibilities and the sequence in which they need to move.
BUSINESS MOMENT 073
Move contracts to another group company
Move contracts to another group company can involve several connected decisions across markets. WONE helps identify the relevant workstreams, local responsibilities and the sequence in which they need to move.
BUSINESS MOMENT 074
Change the regional headquarters
Change the regional headquarters can involve several connected decisions across markets. WONE helps identify the relevant workstreams, local responsibilities and the sequence in which they need to move.
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