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Indirect Tax, Withholding Tax & Treaty Planning

Payment Flows Structured to Match Legal Form With Economic Reality

Averites advises businesses and investors on VAT, withholding tax and other cross-border tax issues affecting payments, supplies and investment returns.

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OUR APPROACH

How We Advise on Indirect Tax, Withholding Tax and Treaty Planning

  1. Why Indirect Taxes Matter Even Without Corporate Income Tax

    Indirect taxes can materially affect commercial arrangements even where the underlying transaction generates limited or no corporate income tax. Businesses operating internationally must consider how VAT and similar taxes apply to goods, services, imports, exports, e-commerce, digital products and intra-group transactions.

  2. VAT Treatment of Domestic and Cross-Border Transactions

    We advise on the VAT treatment of domestic and cross-border transactions, supply structures, place-of-supply questions, imports and exports, digital services and other commercial arrangements.

  3. Registration and Reporting Obligations for International Expansion

    For companies expanding internationally, we also consider whether the operating model creates registration, collection or reporting obligations in additional jurisdictions and coordinate local advice where necessary.

  4. Withholding Tax on Cross-Border Payments

    Withholding taxes are particularly important for international investment and financing structures. We advise on payments of dividends, interest, royalties and other cross-border amounts and on the availability of reduced rates or exemptions under domestic law and applicable tax treaties.

  5. Why Treaty Benefits Depend on More Than Formal Residence

    Treaty benefits increasingly depend on more than the formal residence of the immediate recipient. Tax authorities may examine beneficial ownership, substance, purpose, control over income and anti-abuse requirements when determining whether treaty relief is available. Our approach to treaty planning therefore begins with the commercial and operational substance of the structure.

  6. Structuring Payment Flows to Match Legal Form and Economic Reality

    We advise clients on structuring payment flows in a manner consistent with both the legal documentation and the actual economic relationship among the relevant entities.

  7. Coordinating Tax Analysis With Transactional Work

    Where withholding or indirect tax issues arise in connection with an acquisition, investment, financing or restructuring, our Tax team works directly with the transactional lawyers so that the tax consequences are reflected in pricing, documentation and closing mechanics.

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Precision across borders. Book a Meeting

New York c/o Chornous Law PLLC
30 Wall Street, 8 Floor
New York, NY 10005 Phone: +1 650 382 7764
London 124 City Road
London, England
EC1V 2NX Phone: +44 7405 138109
Kyiv 11 Panasa Myrnoho Street
Office 1/1
Kyiv, 01011 Phone: +380 63 148 27 37

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FAQ

Frequently Asked Questions

  • Yes. Indirect taxes can materially affect commercial arrangements even where the underlying transaction generates limited or no corporate income tax. Businesses operating internationally must consider how VAT and similar taxes apply to goods, services, imports, exports, e-commerce, digital products and intra-group transactions.

    • We advise on the VAT treatment of domestic and cross-border transactions, supply structures, place-of-supply questions, imports and exports, digital services and other commercial arrangements.

      • It can. For companies expanding internationally, we consider whether the operating model creates registration, collection or reporting obligations in additional jurisdictions and coordinate local advice where necessary.

        • We advise on payments of dividends, interest, royalties and other cross-border amounts and on the availability of reduced rates or exemptions under domestic law and applicable tax treaties — particularly important for international investment and financing structures.

          • Not necessarily. Treaty benefits increasingly depend on more than the formal residence of the immediate recipient. Tax authorities may examine beneficial ownership, substance, purpose, control over income and anti-abuse requirements when determining whether treaty relief is available.

            • We advise clients on structuring payment flows in a manner consistent with both the legal documentation and the actual economic relationship among the relevant entities.

              • Yes. Where withholding or indirect tax issues arise in connection with an acquisition, investment, financing or restructuring, our Tax team works directly with the transactional lawyers so that the tax consequences are reflected in pricing, documentation and closing mechanics.