350+ locations 150+ countries 5 regions

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1 tax structuring

2 who are we? PKF is a global family of legally independent firms bound together by a shared commitment to quality, integrity and the creation of clarity in a complex regulatory environment. With offices in over 350 locations, we operate in more than 150 countries across our 5 regions, and specialise in providing high quality audit, accounting, tax, and business advisory services to international and domestic organisations in all our markets. where we operate 350+ locations 150+ countries 5 regions

3 right people right size right solutions

4 how can we help you? With the international tax environment changing rapidly through initiatives such as BEPS, and the initiatives in Europe such as the state aid discussions and changes to the Parent-Subsidiary directive, there has never been a more critical time for international companies to review their existing structures, and plan new structures, to ensure alignment with the changes. As a global service provider, PKF provides a full suite of tax structuring services, which include the following: Tax structuring PKF provides a complete, tax efficient strategy covering the life of your planned operations, from start to finish, which is robust and BEPS resistant. Typically, this includes a tax efficient investment strategy, a tax efficient extraction route for funds generated during operations, recommendations to minimise local taxable profits and consideration of all available double tax relief for cross-border acquisitions, disposals and reorganisations. PKF also provides a tax efficient exit strategy to minimise any capital gains tax implications and provides a tax efficient route for the remittance of residual funds. In addition, our tax structuring services extend to setting up investment funds, acquisition structures for mergers and acquisition transactions, the tax efficient management of intellectual property and intangible assets and tax due diligence exercises. In particular, our PKF tax structuring specialists are highly experienced in dealing with different tax systems and revenue authorities and using their global and local expertise to reduce the tax impact of foreign operations and minimise your global effective tax rate. We can help in other areas Whilst undertaking tax structuring work we are often asked to provide additional services, such as: International tax advice Typically, tax advice on the establishment of overseas operations or joint ventures, financing, overseas mergers and demergers, investment and divestment, business changes (expansion, sale or acquisition) or advice on the tax implications of entering into or exiting from a foreign market, including the foreign regulatory aspects and local practices. Foreign tax compliance PKF can efficiently take care of all your foreign tax compliance obligations including filing tax returns, dealing with tax assessments and responding to all tax authority enquiries. It is more efficient to deal with one firm on a worldwide basis and, with PKF s tax compliance expertise across the globe, PKF should be that firm.

5 why do you need us? PKF has a highly experienced, up-to-date tax structuring group with considerable resources to ensure that every tax structuring plan not only considers all the angles from a local and global perspective, but also tailors tax efficient planning for any key commercial considerations of a client. It is this attention to detail and listening to our clients that often separates PKF from its competitors, in addition to the following values: A fresh approach PKF tax professionals have a fresh approach that defines us; the passion we have to make a difference, to strive to improve and strengthen the tax positions of companies with which we work, and the passion for doing things properly. Our tax people all share the same values and ambitions and combine decades of tax experience with a straightforward, no-nonsense approach. A global service provider PKF is highly experienced in providing tax structuring advice to multinational companies or organisations wherever they may have operations in the world. The benefit to a client in using PKF and having this one shop service is that they just deal with one adviser and so matters become more efficient and controlled, and reporting is streamlined. We are up-to-date with best practice The landscape of the tax world is changing, not least in light of the expected impact of the OECD s BEPS Plan. Our active tax structuring professionals constantly keep abreast of the proposed changes and can provide options to reduce the risk of BEPS on your existing structures and ensure new structures are BEPS resistant. In this way the tax positions are likely to be preserved much longer and not subject to short-term challenges. Right people, right locations PKF s efficient, comprehensive tax structuring service is more than just applying the relevant legislation; it also considers proposed changes (both tax and regulatory), the attitudes and practices of local tax authorities and expected global and local changes. We provide comprehensive tax advice at this level of consideration by our highly experienced tax structuring team having the wealth and depth of local knowledge and experience at each location at their fingertips. PKF has the right people in the right places across the world. We ve got it covered PKF s tax structuring services are comprehensive and provide a client with a full range of services which can include arranging matters in a tax efficient manner to reduce the effective global tax rate, recovering overpaid tax, meeting regulatory tax compliance obligations in all countries (providing assistance with the completion and submission of tax returns) and mitigating risk. With PKF s breadth of services and extensive recources, our clients have it all covered.

6 right people right size right solutions who should you contact? Africa Theo Vermaak Africa, Regional Director Phone: Asia Pacific Amy Hui Asia Pacific, Regional Director Direct dial: Latin America Sergio Villagarcia Latin America, Regional Director Direct dial: North America Job Dieleman North America, Regional Director Direct dial: Europe, Middle East and India Oliver Grosse-Brauckmann Europe, Middle East and India, Regional Director Direct dial: PKF International Limited, 12 Groveland Court, London, EC4M 9EH, United Kingdom Telephone: PKF International Limited administers a family of legally independent member firms and does not accept any responsibility or liability for the actions or inaction on the part of any individual member firm or firms.

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