We believe it is important to approach the tax aspects of your business not only from the point of view of meeting statutory requirements but also with a continuous effort to advise you on the most advantageous techniques available to address your unique cross border and international tax needs.
We provide international taxation services, applying expertise gained through Big Four accounting firm and regional accounting firm experience. In addition, through our affiliation with MGI Worldwide, an international accounting network of independent professional service firms, RINA has access to the local knowledge of tax professionals in over 250 offices throughout 76 countries.
We specialize in the following international tax areas:
Transfer Pricing: We prepared a Transfer Pricing Study for a U.S. company which distributes networking equipment (modems and routers). In this study, we determined the arms-length price for the purchase of parts from the Taiwanese parent company. One of our findings was that the profit margins of the U.S. subsidiary were much greater than that of the comparable companies that were reviewed as part of the engagement. Therefore, we worked with the General Manager in the U.S. to restructure the contracts for the purchase of goods from Taiwan, effectively reducing the U.S. profits by $700,000.
“Since the U.S. tax rate was higher than the tax rate in Taiwan, we were able to help them significantly reduce their worldwide tax” — Tom Neff, International Tax Chair.
Contract Structuring: A U.S. distributor of mining equipment had entered into a contract to sell $7M of product to a Canadian company. RINA assisted them with the structuring of the sales contracts between Canada and Switzerland (the manufacturer’s location), and set up of a service agreement between the U.S. company and Switzerland. As a result, the sales were sourced to Switzerland which avoided our client’s exposure to U.S. taxation.
“By careful analysis of the U.S./Switzerland Income Tax Treaty, we were able to advise our client how to structure their multi-national sales and service agreements in a way that took full advantage of the treaty benefits”— Brenda Jemmott, co-chair of the International Tax Group.
MGI Worldwide is a quality controlled network and, like all member firms, we are subject to review of our quality assurance systems and procedures against international standards.
For more information on MGI Worldwide visit www.mgiworld.com.
International Tax Fact Sheet