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Tax Implication of Cross Border Financing & Other Strategies

Tax implication of Cross Border Financing & Strategies to repatriate profits in the most tax-efficient manner



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Tax implication of Cross Border Financing & other strategies


Common inbound investment structures

- Taxation of Branch vs. Subsidiary

- Walkthrough of a Branch Tax Return and Schedule 20


Cross Border Financing

- Shareholder loans - 15(2)

- Pertinent loan or indebtedness (PLOI)

- Imputed interest on Interest free or low interest loans - 17(1)

- Thin-capitalization

- Back-to-Back Loan Rules

- Upstream Loan

- Foreign Affiliate Dumping



Strategies to repatriate profits

- Transfer Pricing Strategies

- Dividend and Withholding taxes

- Inter-company charges for the management fee, royalties, and similar payments

- Return of Capital

- Repayment of Existing debt

- New loans and issues to consider



Course Walkthrough

  • Tax Implication of Cross Border Financing & Other Strategies

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