Taxation of banking
We give advice on the tax treatment of worldwide operations involving derivatives and other financial instruments. Our goal is to optimize the global tax rate of financial entities and identify from a tax perspective the most efficient banking group operating model.
We deal with any tax issue of banks and entities operating in the financial service sector related to the internationalization of their banking operations and cross-border transactions.
We will provide clients with insight over all the reporting requirement for SMEs and big entities in the light of CRS, DAC6 and FACTA requirements for both the financial and non-financial sectors.
We determine the arm's lenght interrest rate and terms and conditions for any intra-group loan.
For secondary loan transfers we will give advice on the standard agreement's schedule clauses (included tax clauses) and conditions.
We help structuring the securitisation process in order to achieve tax neutrality; our task is to enable all parties to reduce any financial risk for investors structuring the securitisation structure in order to minimize for investor any risk of default from the Special Purpose Vehicle (SPV). We help customer to deal with rating agencies in order to ensure the highest investment rate for the securitisation entities; we can ensure compliance to the EU “Prospectus Directive” and any VAT issue related to the securitisation flows.
we define the proper tax representations on the ISDA agreement schedule and we help structuring the transaction flow in order to eliminate any unexpected tax issue related to the derivative contracts like forwards, futures, options and swaps.
Our advisor can deal with what according to the current trend is one of the most sensitive topic of disputes with tax authorities. The OECD has lately issued also a discussion draft on the methodology multinational financial entities should follow while pricing the following financial transactions:
We enable our clients to be tax compliant while achieving their effective liquidity management through intra-group physical and notional pooling agreements involving entities located in different jurisdictions.
In order to determine the arm's length reward for both cash pooling participants and cash pooling leader (the master account holder), we perform our calculation in line with the latest OECD recommendations.
Tax risk management
We are able to identify, evaluate and make you manage any tax risk involving your MNE group structuring, bank losses and non-performing loans giving advice about implementation of any corporate governance process required by latest developments of international taxation of the banking sector.
Valuation of bank losses
We help you to ascribe a notional monetary value to financial losses and then we can help you to plan a most tax efficient way to utilize those losses within the group.