Tax Services

 

Controlled Foreign Companies Rules | CFC Rules Advisory Services

Controlled foreign companies rules / CFC rules are a tax system designed to tackle tax deferral structures. The controlled foreign companies rules / CFC rules are necessary with respect to income of a corporate structure whose shareholders might otherwise not be taxed. In 2015, the Organization for Economic Co-operation and Development (OECD) released its final report on strengthening controlled foreign companies rules / CFC rules under Action 3 of its Action Plan on Base Erosion and Profit Shifting (BEPS), so that the topic is being tackled substantially and all corporate structures should be examined in detail by experts in order to verify if advisory services and changes are necessary.

Controlled foreign companies rules / CFC rules vary from country to country, however, the features listed below are common in most controlled foreign companies rules / CFC rules systems:

A member of a foreign corporation that is controlled by domestic members must include in its income the person’s share of the controlled foreign corporation / CFC income. The reportable income generally includes income received by the controlled foreign corporation / CFC, like income from passive sources, including interest, dividends and royalties from unrelated parties; from purchasing from and selling goods to related parties; or from non-operating, insubstantial, or passive businesses. Controlled foreign companies rules / CFC rules may have a certain needed percentage for shareholding.

The specialists of Mühler McKay are experienced advisors in regard to controlled foreign companies rules / CFC rules, have solutions and strategies to structure your business in a tax compliant way and render only highest quality advisory services. The general goal should always be to improve your businesses after tax profits and its cash flow in the growing global markets. Mühler McKay, based in Hong Kong can also assist your business in developing appropriate tax and legal structures to optimise your entire business operation.

Our controlled foreign companies rules / CFC rules advisory services generally include:

  • Assessing your controlled foreign companies rules / CFC rules situation

Part of our controlled foreign companies rules / CFC rules advisory services is to assess your controlled foreign companies rules / CFC rules situation in detail. We will then work out a strategy for a tax efficient structure which will give your business a better position among your competitors.

  • Advisory services in regard to the tax efficient structuring of your business

We can help you with structuring your entire business or operations in a tax efficient manner so that no issues from controlled foreign companies rules / CFC rules will arise.

  • Dealing with different jurisdictions and their unique tax regulations

We are experienced in dealing with different jurisdictions and their unique tax regulations in case authorities are challenging your corporate structure.

  • Supporting services

Mühler McKay also provides supporting services for business operations such as assistance with incorporation services / company formation services, advising on tax efficient legal structures for (groups of) companies (corporations, for instance a Hong Kong Limited Company, partnerships, branches, representative offices), bookkeeping and accounting (according to Hong Kong principles) as well as audit arrangement, general corporate compliance like provision of company secretary services (in Hong Kong) as well as providing a registered address or virtual office in Hong Kong, obtaining obligatory registrations, permits and licenses, as well as employment advice, including Hong Kong work visa application and controlled foreign companies rules / CFC rules advisory services.

Mühler McKay offers comprehensive controlled foreign companies rules / CFC rules advisory services which include arranging businesses and operations in a tax efficient manner in order to bring down your effective global tax rate, satisfy international tax compliance obligations and mitigate taxation risks.

We appreciate the opportunity to assess your controlled foreign companies rules / CFC rules situation and to assist you with our advisory services to obtain tax efficiencies in regard to your international business.

Please contact us or visit us in Hong Kong for your first consultation for our controlled foreign companies rules / CFC rules advisory services.

Mühler McKay based in Hong Kong is a business advisory firm with worldwide reach and renders, among others, general international tax and expert controlled foreign companies rules / CFC rules advisory services to a diversified international client base from various industries and sizes.