Tax authorities pay a great amount of attention to transactions between connected parties – it is where tax authorities note loopholes in the tax law and where people see opportunities for tax evasion.
We can assist with a review of your intergroup transactions and arrangements including funding, and advise on commercially practical and sometimes better ways of doing things.
Some examples of the type of issues we advise on are as follows:
- Rates of interest charged on intergroup loans
- Service charges from service company to other companies in the group
- Setting up service company structures and charging arrangements