February 16, 2017

Tax Planning

Einzel’s international tax and corporate practice

Tax risk reduction in connection with the introduction of the CFC regime (controlled foreign companies’ regime) and the risks regarding automatic exchange of financial information between the tax authorities of different countries. Company and holding restructuring. Consolidation and deconsolidation of assets, reduction of taxes and financial risks when working with a variety of European and offshore jurisdictions. Offshore company liquidation, practical tax solutions for safe declaration of overseas assets of controlled companies and regulatory entities. International tax law and tax audit of business processes.

Establishment of special SPV companies with preferential or regulated assessment and taxation base in Austria and the U.S. (Nevada, Florida, Wyoming, California and New York) for trading (including trade services) and investment activities (securities trading, derivatives, holding funds) to meet the law requirements of tax legislation of the country of controlling person’s residence. Legal creation and legal relocation of profit centers to the jurisdiction with the most favorable tax regime. Accounting support and tax audit of these structures for compliance with the country’s legislative requirements, obtaining tax-ruling to reduce financial risks, interaction with the tax administration and licensing authorities.

Company formation in EU, USA and low-tax offshore jurisdictions. Management, financial and tax audit of the classic offshore companies to determine the taxable profits of controlling persons according to international standards IFRS and GAAP. Opening of bank accounts and bank compliance.

Establishment of companies and non-profit foundations for anonymous ownership of assets, development of the corporate and financial solutions for the economical control of your business.

International Tax Planning for direct and indirect taxes, international tax planning for the sale of business and for mergers and acquisitions.

Support of company’s international business (trading, services, holding of assets): tax and corporate transaction structuring, choice of optimal forms of financial settlement, legal analysis (Due Diligence), negotiations with contractors, banks and financial intermediaries, professional assessment of asset financial condition.

Attraction of foreign equity and bank financing, as well as reserve and reverse lending facilities (in conjunction with Einzel’s financial partners rated USA Top 10 financial companies).

Creation of holding companies and securitization of corporate instruments (which can issue and allot bonds, shares of different classes, hybrid securities, exchange and OTC repos and other instruments of intra-group financing). Development of dividend and bonus policy for beneficial owners and top managers. Tax and legal assistance with the company’s controlled transactions and transfer pricing deals. Corporate and tax solutions for financial management of assets and investments of temporary available funds. Reduction and hedging of currency exchange risks for certain type of businesses (derivatives market, foreign currency options and futures contracts). Corporate tax solutions for reinvesting the business profits in a subsidiary or affiliated companies.