Structure your international flows

CAMBIO Avocat assists you with the tax issues you encounter in the context of your international activity, whether via your subsidiaryies or branches.

01

Determine transfer pricing policy

02

Analyze the risk of permanent establishment linked to your business abroad

03

Define the VAT rules applicable to your international business

04

Identify the suspensive tax and customs regimes from which you can benefit

CAMBIO Avocat works with partner law firms to assist you with your international mobility and customs issues.

Fees

Assignments involving the structuring of your international flows are invoiced on a lump-sum basis.

This gives you a clear idea of the total cost of my support.

Frequently asked questions

What is “transfer pricing”?

“Transfer pricing” refers to the prices applied to transactions carried out between companies belonging to the same group but located in different countries.

This involves 3 components:

  • Group entities must be located in different countries.
  • They must be related entities (generally more than 50% owned by another entity of the group).
  • Group entities must carry out transactions with each other.

What is a permanent establishment?

Permanent establishment is a tax concept used to determine whether an industrial or commercial activity carried out by a company abroad is taxable in the country where the company is resident or in the country where it operates.

The term “permanent establishment” refers to a fixed place of business through which a non-resident company carries out all or part of its business in another country. This may include, for example, a branch office, headquarters, an office, a factory, a workshop.

Each double taxation treaty contains a precise definition of permanent establishment, which should be referred to.

A dependent agent may also constitute a permanent establishment if the latter has the power to contract in the name and on behalf of the principal company.

Why use a lawyer to structure your international flows?

Calling on the services of a lawyer specialising in international taxation gives you the expertise you need to understand the tax implications of your international business. He or she will explain the issues relating to corporation tax and VAT, as well as customs and related issues linked to international mobility.

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