GMT
Resolving a Complex Permanent Establishment Risk
We represented a prominent multinational consumer electronics company facing a Permanent Establishment (PE) tax inquiry. By reconstructing the economic facts and clarifying the legal framework, we successfully guided the case toward an administrative resolution, eliminating criminal exposure and securing a favorable settlement.
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Assessing Transfer Pricing Rules in Corporate Restructuring
We represented a South Korean logistics multinational in a TP dispute, successfully securing a tax court ruling that domestic restructuring did not require business transfer compensation.
Aligning Revenue Recognition with Long-Term Operations
We represented a Finnish vertical transport provider in a revenue recognition dispute, validating the percentage-of-completion method to secure a full cancellation of the tax correction.
