THYOR

Tax Advisory

International Tax Advisory

Cross-border tax architecture for ownership, operations, investment and cash flows involving the United States and other jurisdictions.

When this helps

Recognisable situations.

  1. 01

    A business enters a new country

    Entity, permanent-establishment, withholding and repatriation issues must be framed before activity begins.

  2. 02

    Ownership spans jurisdictions

    Entity classification and reporting obligations interact across the structure.

  3. 03

    Functions or assets move across borders

    Tax consequences must be assessed alongside operating substance.

  4. 04

    A transaction involves foreign parties

    Structure and diligence affect price, cash and post-closing obligations.

Scope

The service is configured to the facts and decision.

Exposure mapping

  • Entities, owners and jurisdictions
  • Income and cash flows
  • Permanent-establishment risk
  • Reporting obligations

Structure

  • Holding and operating alternatives
  • Financing and repatriation
  • Withholding analysis
  • Implementation sequencing

Coordination

  • Local adviser workplans
  • Information standards
  • Compliance calendar
  • Ongoing review

Engagement path

Five stages, one accountable thread.

  1. 01

    Define the decision

    Clarify the decision, constraints, stakeholders and evidence required.

  2. 02

    Build the fact base

    Reconcile the financial, tax, operational and contractual information that drives the issue.

  3. 03

    Develop options

    Model viable paths, explicit trade-offs and downside cases.

  4. 04

    Execute the work

    Produce the agreed analysis, operating cadence and decision materials with senior ownership.

  5. 05

    Embed and hand over

    Document the method, train the responsible team and retain an escalation path where needed.

Typical deliverables

Defined before work begins.

  • Cross-border exposure map
  • Structure options memorandum
  • Tax-flow model
  • Jurisdiction workplan
  • Compliance calendar
  • Implementation issue log

Questions

Common engagement questions.

Does Thyor advise outside the United States?

Thyor leads the integrated analysis and coordinates established local specialists where local law or filing authority is required.

Is transfer pricing included?

The economic and operating facts can be analysed; formal local documentation may be coordinated with specialist providers.

Next step

Discuss international tax advisory.

Share the situation, timing and decision. A senior adviser will respond directly and confidentially.

Discuss a Situation