They further pay particular attention to mitigating tax leakages and risks, while at the same time are careful about negative public exposure from tax planning.

The expansion and mobility of economic activities around the globe have created both opportunities and issues for the players in the global economy.

Multinational companies require global tax planning to effectively adapt to the local operating environment by complying with domestic tax laws, reporting requirements and statutory filings, and monitoring ongoing legislative developments.

Apart from local specifics, multinationals are facing a range of challenges on the global scene. The EU and the OECD authorities have launched a number of new initiatives focused on aggressive tax planning providing frameworks and instruments to effectively combat tax avoidance and evasion. 

Following such a line, Bulgaria has already started introducing legislative amendments towards increased exchange of tax information and restriction of capital flight to the so-called tax havens. 

KPMG’s International Tax practice professionals help companies manage the complexities of multiple tax systems and supranational regulations around the world. 

In cooperation with our colleagues from other KPMG member firms, we provide advice on many key international tax issues, including international holding company structures, hybrid instruments and entities, new ventures, structuring cross-border transactions and contract manufacturing arrangements, commissionaire structures, and compliance with tax and trade regulations.

Tax services in the international corporate tax area include: 

Developing international holding structures

• Developing tailored strategies to manage the effective tax rate 
• Advising on where intellectual property should be located   
• Analysing how global supply chains should be configured to achieve cash flow benefits  
• Assisting in compliance and planning processes in relation to international trade and customs issues  
• Helping investors to select jurisdictions to benefit from exemptions from capital gains tax

Cross-border structured finance planning

• Advising businesses how to arrange the financing of their foreign     operations tax-efficiently   
• Providing advice on structuring the offshore investment vehicles through which to make investments   
• Analysing alternative approaches to achieve interest deductions for tax purposes

Foreign tax credit planning

• Helping companies use available foreign tax credits effectively
• Assisting in implementation of hybrid instruments and entities

Profit repatriation planning

• Performing withholding tax planning for dividend flows   
• Advising on the legal form of investment vehicles   
• Analysing the tax impact of other payments made to offshore entities

Compliance with European tax legislation

• Analysing the compliance of local legislation with the EC Treaty and EC directives and regulations to identify tax opportunities for local businesses   
• Helping companies use and apply the judgments of the Court of Justice of the European Union to domestic tax issues