Structuring Operations Cross-Border
We advised a Finland-based multinational in agriculture on strategic M&A and operational structuring across various continents, focusing on tax, legal prerequisites, and local best practices to minimize conflict and tax litigation risks.
Structuring Operations Cross-Border
We advised a Finland-based multinational in agriculture on strategic M&A and operational structuring across various continents, focusing on tax, legal prerequisites, and local best practices to minimize conflict and tax litigation risks.
Structuring Operations Cross-Border
We advised a Finland-based multinational in agriculture on strategic M&A and operational structuring across various continents, focusing on tax, legal prerequisites, and local best practices to minimize conflict and tax litigation risks.
The shares in Finnish parent of the group had been subject to a 100% acquisition by a US based publicly traded corporate entity. Following the acquisition, given the high potential in the Finnish Multinational’s business and the consequential increase in operational activity in several jurisdictions, a need for a comprehensive review of the existing operational structures was identified.
Overall, there were several business, legal and tax related issues that needed to be assessed in a synchronized manner in order to be able to come up with a rational and sustainable business conclusion going forward.
For this purpose, we were engaged to prepare a company by company review of group businesses and functions, personnel, agreements, and pricing of transactions. This review included, in addition to just reviewing, also drafting/amending of Group-internal agreements. In connection with this, the transaction-models used in the group structure will be identified in order to assess their feasibility both for business and transfer pricing purposes.
Furthermore, the review included, as appropriate, the assessment of CIT, Customs, VAT and Payroll issues in the jurisdictions of operations, as well as the appropriate transfer pricing requirements implemented in the Group-structure. One particular item of the review is the assessment of PE control in the jurisdictions of operations, as well as the appropriate means of establishment in any given jurisdiction.
The matter was very challenging as it involved integration of operations while implementing appropriate tax and legal measures to support the business and comply with the rules and regulations as applicable in relevant jurisdiction of establishment by the Group. As a specific feature, the advisory required thorough analysis of the US tax requirements for Group internal transactions.
Overall, this is a multi-layered matter where we had to proceed jurisdiction by jurisdiction while making sure that all the individual solutions suggested and decisions made are well-synchronized to support the Group as a whole and that they are in line with local legislation. From tax advisory perspective the case included all the above listed sub-categories of taxation with intense international flavor underlying.
The shares in Finnish parent of the group had been subject to a 100% acquisition by a US based publicly traded corporate entity. Following the acquisition, given the high potential in the Finnish Multinational’s business and the consequential increase in operational activity in several jurisdictions, a need for a comprehensive review of the existing operational structures was identified.
Overall, there were several business, legal and tax related issues that needed to be assessed in a synchronized manner in order to be able to come up with a rational and sustainable business conclusion going forward.
For this purpose, we were engaged to prepare a company by company review of group businesses and functions, personnel, agreements, and pricing of transactions. This review included, in addition to just reviewing, also drafting/amending of Group-internal agreements. In connection with this, the transaction-models used in the group structure will be identified in order to assess their feasibility both for business and transfer pricing purposes.
Furthermore, the review included, as appropriate, the assessment of CIT, Customs, VAT and Payroll issues in the jurisdictions of operations, as well as the appropriate transfer pricing requirements implemented in the Group-structure. One particular item of the review is the assessment of PE control in the jurisdictions of operations, as well as the appropriate means of establishment in any given jurisdiction.
The matter was very challenging as it involved integration of operations while implementing appropriate tax and legal measures to support the business and comply with the rules and regulations as applicable in relevant jurisdiction of establishment by the Group. As a specific feature, the advisory required thorough analysis of the US tax requirements for Group internal transactions.
Overall, this is a multi-layered matter where we had to proceed jurisdiction by jurisdiction while making sure that all the individual solutions suggested and decisions made are well-synchronized to support the Group as a whole and that they are in line with local legislation. From tax advisory perspective the case included all the above listed sub-categories of taxation with intense international flavor underlying.
The shares in Finnish parent of the group had been subject to a 100% acquisition by a US based publicly traded corporate entity. Following the acquisition, given the high potential in the Finnish Multinational’s business and the consequential increase in operational activity in several jurisdictions, a need for a comprehensive review of the existing operational structures was identified.
Overall, there were several business, legal and tax related issues that needed to be assessed in a synchronized manner in order to be able to come up with a rational and sustainable business conclusion going forward.
For this purpose, we were engaged to prepare a company by company review of group businesses and functions, personnel, agreements, and pricing of transactions. This review included, in addition to just reviewing, also drafting/amending of Group-internal agreements. In connection with this, the transaction-models used in the group structure will be identified in order to assess their feasibility both for business and transfer pricing purposes.
Furthermore, the review included, as appropriate, the assessment of CIT, Customs, VAT and Payroll issues in the jurisdictions of operations, as well as the appropriate transfer pricing requirements implemented in the Group-structure. One particular item of the review is the assessment of PE control in the jurisdictions of operations, as well as the appropriate means of establishment in any given jurisdiction.
The matter was very challenging as it involved integration of operations while implementing appropriate tax and legal measures to support the business and comply with the rules and regulations as applicable in relevant jurisdiction of establishment by the Group. As a specific feature, the advisory required thorough analysis of the US tax requirements for Group internal transactions.
Overall, this is a multi-layered matter where we had to proceed jurisdiction by jurisdiction while making sure that all the individual solutions suggested and decisions made are well-synchronized to support the Group as a whole and that they are in line with local legislation. From tax advisory perspective the case included all the above listed sub-categories of taxation with intense international flavor underlying.
Bernhardinkatu 5 A 5
00130 Helsinki, Finland
+358 40 523 2020
office@weckstromattorneys.com
© 2024 Weckström Attorneys Ltd.
Bernhardinkatu 5 A 5
00130 Helsinki, Finland
+358 40 523 2020
office@weckstromattorneys.com
© 2024 Weckström Attorneys Ltd.