Loyens & Loeff

Planning & Strategy

By blending our tax expertise with a thorough understanding of the business, management control and knowledge of accounting systems, we analyse transfer pricing exposures and opportunities and then advise on the best strategies. We advise amongst others on transfer pricing policies, the set-up and conversion of business models, restructurings, profit allocation to permanent establishments and can assist you in defining a strategy on country-by-country reporting.

Business model optimization & restructuring

Tax authorities seek to establish and enforce new guidelines and regulations, but it is better for your business if you are in control. You need to handle your intellectual property in the best possible way, and in-line with your business model and tax authority requirements. Managing this requires a structured approach and a tax strategy that fits in with today’s environment.

Tax structures need to be consistent with business structures, and vice versa, in order to avoid unnecessary discussions with tax authorities and minimise tax risks. An optimising and restructuring business model to align them with tax structures is, therefore, an excellent way of dealing with this important issue.

Helping your company with its changing structures and strategies, requires tailor-made solutions. We can identify (tax) structure alternatives, develop pricing documentation, review day-to-day operations in relation to your (tax) strategy, draft or review legal agreements and give hands-on assistance with the implementation of new advice, structures and strategies.

Intellectual property

You want to be able to handle your intellectual property in the best possible way, in-line with your business model and tax authority requirements. Managing this requires a structured approach and a tax strategy that fits in with today’s environment.

Tax authorities gain a clear understanding of the role of intellectual property within companies handling Country-by-Country reporting. Loyens & Loeff can advice you on ‘on-shore’ intellectual property alternatives and ways to add substance to your company’s intellectual property.

Focus is also needed for building stronger business structures; structures that are less likely to be scrutinised by tax authorities, whilst still being efficient. We can provide you with the design and implementation of intellectual property structures that best suit your business structure and that will stand up during discussions with tax authorities. Furthermore, we can assist you with documenting these transactions, in thorough transfer pricing documentation.

Profit allocation to PE’s

The permanent establishments (PE’s) of multinationals face a number of complicated issues and when talking about PE’s many different questions arise. Today’s multinationals question everything and always start with the question: is there a PE? Using an integrated approach, it is important to examine those facts that will have the most impact on profit allocation.

The focus of profit allocation is to control the PE risks, to create awareness around these risks, to avoid double taxation, to effectively manage tax costs, and to get a grip on the impact of BEPS Action 7.

Loyens & Loeff specialises in building and optimising structures for today’s rules and regulations. We focus on all of the risks involved and will assist you in organising your profit allocation in the most advanced way. Not only taking different stakeholders into account, but also bringing your profit allocation in-line with your existing tax and business structures and combining it with your existing workflows and systems.