The Challenge

A mid-sized manufacturing group operated across Asia and Europe, with profits being taxed in multiple jurisdictions. Key issues included:

  • Double Taxation Exposure: Revenues were taxed both in the operating countries and in the home jurisdiction due to weak treaty utilisation.
  • Permanent Establishment Risk: Overseas distribution arrangements unintentionally created taxable presence in certain markets.
  • Excessive Repatriation Costs: Profit repatriation attracted withholding taxes, eroding group profitability.
  • Compliance Complexity: Multiple tax filings across borders increased costs and created risks of penalties.

Our Solution

1Financial designed and implemented a comprehensive tax restructuring strategy:

The Outcome

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