Tax advice that holds in every jurisdiction you operate in.
Corporate and indirect tax obligations, transfer pricing requirements and permanent establishment rules differ in every country, and enforcement has tightened in most of them. HSP’s international tax advisors work to your operating model, your objectives and your risk threshold.
Advisory coverage
Advice is cheap to give and expensive to be wrong about.
A company operating across borders carries tax obligations in each jurisdiction it touches, and those obligations move. Three things decide whether the position you take survives contact with a local tax authority.
The advisor is in your jurisdiction, not reading about it
The team works across the corporate and indirect tax requirements of more than 100 countries and is placed across the Americas, EMEA and Asia Pacific, so advice comes from the time zone your operation sits in rather than from a central desk interpreting a summary.
The position is carried into the return that reports it
Tax advisory sits alongside entity management, accounting, payroll and legal. A position taken in one country is carried through the filings and the books that follow it, prepared by the same team, so the numbers in a local file reconcile to the numbers that are filed.
Positions are documented to the local standard
Tax authorities review more actively than they did and exchange information automatically across borders. Every position is documented to the standard the local authority applies, so the evidence exists before anyone asks for it rather than being assembled under audit.
One position, carried through to the accounts.
Most tax advice arrives as a memo and stops there. Somebody else then has to turn it into a registration, a return and a set of statutory accounts, and that handover is where positions drift.
- The advisor who takes the position and the team that files the return sit in the same engagement
- Master files, local files and clearance applications are prepared to the standard the local authority applies
- Advice can still be standalone — you are not required to move your filings to HSP to take it
Three tiers of documentation, and a threshold that misleads.
The OECD’s base erosion and profit shifting program rewrote transfer pricing reporting. More than 100 countries have committed to the minimum standards, and tax authorities now exchange country-by-country reports automatically across more than 2,000 bilateral relationships.
- Assessment of your countries of operation and their thresholds, then analysis of the related-party supply chain against each one
- Functional analysis across the group, with single-country and pan-regional benchmarking behind the files we prepare
- Documentation you already hold can be stress tested instead, to find gaps between the files and how the group actually prices
Map, review, act.
The same shape covers a single transaction review and a multi-country documentation program. What changes is the scope, not the method.
We set out every jurisdiction your group touches and the obligations each one creates — corporate income tax, indirect tax registration, transfer pricing documentation, permanent establishment and withholding. You see the full picture before anyone proposes work.
We test your current positions against local law and identify the tax implications and the reliefs available to you. Where documentation already exists, this is the stage that stress tests it against how the group actually operates and prices.
We agree a scope, a timetable and an SLA, and deliver against it in each country — registrations, filings, master and local files, clearance applications, refund claims or responses to a tax authority review.
Who gives the advice.
HSP’s international tax team brings together specialists who work across the corporate and indirect tax requirements of more than 100 countries. Consisting of former Big Four partners and senior leaders, the team is placed across the Americas, EMEA and Asia Pacific, and supports groups of every size, from single-entity market entrants to established multinationals.
100+
countries covered
1,000+
clients supported
3
regions with advisors in place
“A review of your intragroup cross-border withholding tax positions can often reduce tax leakage.”
Tom Lickess, FCA — VP, Global Head of Tax, HSP Group
Where we advise.
Direct corporate tax
Multi-jurisdiction corporate income tax, permanent establishment and tax residency, treaty interpretation and withholding tax.
Indirect tax (VAT and GST)
Indirect tax reviews, registrations and deregistrations, filings, refund and reclaim processes, import and export taxes and duties, and technical analysis of individual transactions.
Transfer pricing
Assessment and documentation, including the global master file and local files, functional analysis, single-country and pan-regional benchmarking, and stress testing of documentation you already hold.
Structuring and supply chain
Tax structuring and tax-effective intra-group financing, tax-efficient supply chain reviews, and multi-country supply chain models assessed for where they create registration and recovery obligations.
Entity reorganization and rationalization
Global entity and supply chain review to establish which entities the group needs, wind-down options by entity type and jurisdiction, tax clearance and deregistration, and repatriation of profits, assets and intra-group balances on a tax neutral basis.
Audit and dispute support
Domestic and international tax authority strategic review and audit assistance, indirect tax examinations, and strategic responses to and management of tax authority reviews.
More on cross-border tax positions.
Questions we get asked.
How is this different from your tax compliance service?
Compliance is the recurring obligation: registrations, returns and filings on a calendar. Advisory is the position behind them — what you owe, where, and on what basis. The two run well together, because a position taken in advisory is carried into the filings that report it, but they are separate engagements and you can take either on its own.
Do we have to move our filings to HSP to take the advice?
No. Advisory engagements are scoped on their own and many clients keep their existing compliance arrangements. Where HSP does handle the filings as well, the benefit is that the same team prepares the documentation and the return, so the numbers reconcile.
Who actually gives the advice?
HSP’s international tax team, led by Tom Lickess, VP, Global Head of Tax. The team consists of former Big Four partners and senior leaders working across the corporate and indirect tax requirements of more than 100 countries, placed across the Americas, EMEA and Asia Pacific.
We are below the EUR 750 million threshold. Do we still need transfer pricing documentation?
Possibly. The EUR 750 million figure is the general threshold for country-by-country reporting, and it is materially lower in certain countries. Thresholds for master file and local file documentation are set country by country and are often considerably lower again, so a group below the reporting threshold can still carry documentation obligations in several jurisdictions. The assessment stage establishes which ones apply to you.
Can you review documentation we already have?
Yes. We work through your legal entities and intra-group operating framework against the existing documentation to find gaps or inconsistencies between the master file, the local files and how the group actually operates and prices, then assess whether the position or the documentation should be updated. The same exercise usually surfaces further efficiency opportunities.
We have entities we no longer use. Can you close them?
Yes, and the cost of a dormant entity continues until it is formally closed. We review the group’s entity footprint against what the operating model needs, advise on wind-down options by entity type and jurisdiction, handle tax clearance and deregistration, and repatriate trapped cash, assets and intra-group balances on a tax neutral basis. You get a jurisdiction-by-jurisdiction cost and timeline before you commit.
How does an engagement get scoped and priced?
The mapping stage comes first and shows you every jurisdiction and obligation involved. From that we agree a scope, a timetable and an SLA, with the cost set out country by country before any work starts.
Is anything on this page tax advice?
No. This page is general information and is not tax or legal advice. Positions depend on your facts and on the law in each jurisdiction involved, which is what an engagement establishes.
100+
countries covered
1,000+
clients supported
1
scope and SLA across every jurisdiction involved
Start with the map.
Tell us which countries you operate in and we will set out the obligations each one creates, before anyone proposes work.
A tax advisor replies within one business day. No sales sequence.