** High-Level Tax Woes for Flips: A Holding Company's Guide ⚠️**
Planning a Flip holding structure? Buckle up for these tax bumps:
1️⃣ Place of Effective Management (POEM): Founders abroad?
Holding co.'s taxes might haunt you back home! ✈️
2️⃣ Permanent Establishment (PE): Careful with those agents closing deals! They could trigger local taxes where they operate.
3️⃣ US Tax on Global Intangible Low-Taxed Income (GILTI): Subsidiary profits?
Uncle Sam might want a slice, even if you're not in the US. 🇺🇸
4️⃣ Base Erosion and Profit Shifting (BEPS): Global minimum tax looming? Check if your holding structure is safe. ⚖️
5️⃣ Transfer Pricing: Licensing those juicy IPRs?
Pricing matters - tax authorities in both countries will scrutinize! ⚖️
6️⃣ Flipping Jurisdictions: Not so fast! Moving your holding co.
can trigger transfer pricing and other tax headaches. ⚠️
7️⃣ GST & Transfer Pricing: Between-companies transactions may require "reverse charge" GST.
Don't get caught napping!
#Flips #HoldingCompanies #TaxPlanning #GlobalTax #TransferPricing #GST #Startup
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