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Companies’ international activities often lead to foreign subsidiary and branch creations, which entail multiple tax consequences for the group, not only for the choices of countries where to establish, but also for the formula to adopt regarding international taxation and taxes related to “transfer pricing”.



Companies’ international activities often lead to creation of foreign heads of office. The choice of these heads is often dictated by local tax considerations. Moreover, international tax rules may lead to questions on which formula to adopt between the subsidiary company or the foreign branch.

If taxation is determining the choice of international setting up and its form, it also leads international societies to examine the contracts to conclude between the different companies of the group, as well as the questions of transfer pricing, likely to be brought by any good tax organization.
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