Cross border groups now carry a heavier tax burden than at any point in a generation. A global minimum tax, sharper transfer pricing scrutiny and faster moving disputes mean the cost of a weak position has risen. We give you a clear, defensible answer, owned by one senior specialist from first call to final filing.
Effective tax rate modelling, safe harbour analysis, top up tax calculations and GloBE Information Return readiness across every jurisdiction you operate in.
Policy design, documentation, benchmarking and the defence of intercompany pricing through audit and dispute.
Holding structures, financing, repatriation and substance, built to hold up under both commercial and regulatory pressure.
Diligence, structuring and post deal integration, with a clear view of the tax that survives completion.
Enquiries, audits and litigation managed from first contact to resolution, by someone who has sat on both sides of the table.
Claims and reliefs prepared to a standard that welcomes scrutiny rather than fearing it.
Pillar Two is now in force across many jurisdictions, and the first GloBE Information Returns for the 2024 year fall due in the middle of 2026. Compliance depends on data that most groups have never had to assemble before, drawn from tax, finance, legal and systems at once. The groups that prepare early avoid both a top up tax surprise and a last quarter scramble.
Pillar Two is the OECD global minimum tax. It generally applies to multinational groups with consolidated revenue of EUR 750 million or more, requiring a minimum effective tax rate of 15 percent in every jurisdiction and a GloBE Information Return. We assess scope, model exposure and prepare the filing.
For many calendar year groups the first returns covering the 2024 fiscal year fall due in the middle of 2026. The data demands are significant, so we begin readiness well ahead of the deadline.
Yes. We design defensible policies and documentation, and we lead the response when a tax authority opens an enquiry, through to settlement or litigation.
A senior specialist with at least fifteen years of experience. The person who wins the work does the work. You will not be handed to a junior team after the first meeting.