Tax Planning in an International Environment

This paper provides a practical overview and normative analysis of international tax planning ideas for entities who are establishing or restructuring their business affairs. In particular, in an international financial hub, such as Hong Kong, taxation advisors and lawyers need to be particularly vigilant in ensuring that their client complies with their taxation obligations and is commercially savvy.No doubt international tax planning is a sophisticated area which involves careful planning, detailed implementation and thorough understanding of a number of fundamentals of both international and domestic tax laws. This paper will discuss and examine four main international structuring techniques, namely (i) risk segregation; (ii) cross-border transactions; (iii) holding structures; and (iv) cost-sharing arrangements – also the impact of, for example, bank secrecy and OECD tax model, on international tax planning in this regard