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)
- 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
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