Cross-Border Tax Restructuring for a Technology Group
The Challenge
A technology conglomerate with operating entities in India, the US, and Canada was paying an effective tax rate of 34% due to suboptimal intercompany pricing, IP ownership sitting in a high-tax jurisdiction, and inconsistent use of available treaty benefits.
Our Approach
FYNX conducted a comprehensive tax health check across all three jurisdictions, reviewed existing intercompany agreements and transfer pricing documentation, and designed a restructured holding and IP licensing framework. We prepared contemporaneous transfer pricing documentation under BEPS Action 13 and coordinated implementation with local counsel in each jurisdiction.
Measurable Results
Reduced group effective tax rate from 34% to approximately 30.6% (340 basis points)
Restructured IP ownership with proper economic substance to withstand GAAR scrutiny
Prepared compliant transfer pricing documentation for all material intercompany transactions
Structure has withstood two tax authority inquiries without adjustment over 3 years