Page 24 - Strategic Tax Planning for Global Commerce & Investment
P. 24

Cross Border Tax Planning Strategies


        pricing  can  have  a  substantial  impact  on  lowering  the
        enterprise's effective tax rate (ETR).


        2.  Jurisdictional Strategies

          Jurisdictional  strategies  focus  on  the  use  of  domestic  or  in-
          country  tax  laws.  Depending  on  the  country,  planning
          opportunities  may  include  the  use  of  local  country
          consolidations,  research  and  development  tax  credits  or
          similar  incentives,  the  use  of  tax  loss  carry-backs  or  carry-
          forwards and loss refreshing transactions, tax free asset step-
          ups and re-evaluations (e.g.  intangibles), income and capital
          planning  or  the  use  of  tax  holidays  or  special  tax  zones  to
          reduce direct and indirect taxes.


        Developing a Tax Planning Strategy


        Developing and implementing a comprehensive and integrated
        global  tax  plan  is  a  complex  problem  which  requires  an
        integrated  approach  and  an  understanding  of  many
        interdependencies. It involves the following steps:


                            Studying the global profit and tax drivers
                            Setting goals
                            Identifying  strategies  and  categorizing
                              planning techniques

                            Weighing and choosing alternatives
                            Implementing a plan
                            Periodically  reviewing  the  plan's  perfor-

                              mance




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