International Tax & Permanent Esablishment (ITP)

In Rosso Alba & Rougès we develop comprehensive cross-border tax strategies identifying critical features associated with the interphase of two or more taxing systems and the potential pitfalls connected with them leading to multiple taxation, whether by means of timing or characterization issues, or by means of the overlapping of local tax laws and the inadequate use of tax treaty advantages. Our experts’ in-depth knowledge and experience of the rules and practices in the area of international taxation and treaties allows the Firm to offer its clients a comprehensive understanding of all tax protection alternatives according to international tax rules as well as state-of-the-art solutions for cross-border investments and operations across Latin America, into Latin America or from Latin America.

We offer integrated advice promoting solutions and alternatives that minimize the tax cost of an investor’s return in cross-border projects, jointly with the determination of the tax consequences, risks and other impacts in any phase or stage of said cross-border projects.

Our services for International Tax & Permanent Establishments (ITP) include legal advice and guidance in relation to:

• International Tax Structuring
• Double and Multilateral Tax Treaty Expertise
• Cross-border tax and business optimization
• Mitigation of domestic and foreign Double Taxation
• Support on Mutual Agreement Procedures (MAPs), arbitration and Litigation on PE and other issues
• International Tax Compliance in local and foreign tax reporting obligations, bookkeeping requirements, and other obligations
• International Tax review on contract negotiations or contract clauses
• Risk Management