02.19
Tax Advisory & Compliance
POSSIBLE IMPLICATIONS ON THE ABILITY OF ACOMPANY TO ENJOY TREATY BENEFITS, TRANSFER PRICING AND CRS/FATCA

Representative Work

At the request of a client, an international financing company with more than Euro 108.000.000,00 million of assets, Kinanis LLC made a holistic review on the company’s activities and structure analyzing the 2017 and 2018 level of substance and providing opinion on possible implications on the ability of the company to enjoy treaty benefits, transfer pricing and CRS/FATCA and advice on possible future steps.

In order to demonstrate as to the company’s ability to enjoy treaty benefits, Kinanis LLC explicitly analyzed court cases taken place in Russia relevant to the company’s case and taxpayers’ eligibility to enjoy treaty benefits.