The Hall & Wilcox International tax team combines practical experience with technical expertise to assist inbound and outbound multinational corporations and funds with their global tax planning, structuring, reporting, risk management and deal execution.
Our practice is built on the foundations of commercial and technical expertise, as well as an active involvement in the sector.
Our capability in this area includes:
- Transactions – advisory and tax due diligence services in respect of mergers, acquisitions, divestments, joint ventures and equity investments.
- Structuring – implementing and reviewing structures to achieve tax efficiencies, mitigate risks and align tax objectives with business strategies.
- Compliance & Health Checks – ensuring that the complex array of compliance and reporting requirements are met, and reviewing and revalidating adopted tax positions.
- Advisory – advising on a broad range of matters including transfer pricing, thin capitalisation, base erosion and profit shifting (BEPS), Multinational Anti-Avoidance Law (MAAL), Controlled Foreign Company (CFC) rules, Diverted Profits Tax (DPT), General Anti-Avoidance Rules (GAAR) and promoter penalty laws.
Our team also closely follow legislative and regulatory developments and are quick to communicate how this may impact its clients.
- Advising an offshore purchaser on the acquisition of an Australian retailer and manufacturer.
- Advising a large Australian corporate entity on the Australian tax implications of cross-border transactions including royalties on intellectual property, withholding tax and dividends.
- Advising a multinational group whether a Permanent Establishment exists in Australia.
- Advising clients on the application of the MAAL.
- Advising on transfer pricing issues and preparing transfer pricing documentation.
- Advising on the application of tax consolidation to corporate groups that include foreign entities.
- Advising a large multinational fund manager on the income tax issues for the fund manager and investors in capital protected products.
- Advising on the tax issues arising from the reorganisation of the Australian operations of a German diversified group relocating its manufacturing operations offshore.
- Reviewing and advising on the income tax issues associated with the financing strategies of a large multinational retailer and its associates.