• Investor tax advisory and Due Diligence reviews– Investor tax advisory and due diligence review is necessary to gain early warning of any key control weaknesses in the target companies. While the scope of this review can, of course, be tailored according to each client’s specific requirements, the standard scope would include:

1. A high level review of key control areas e.g. inventory management, procurement, sales, information systems and finance (including month/year end reporting and budgeting process etc);

2. A summary report to the parent company management including key control weaknesses and prioritized actions for improvement; and

3. Comment on the experience of management within the entity and their ability to implement any proposed changes.

• Off-shore financial planning (Thin Capitalization and Deemed Interest Planning)-Given the increasing scrutiny and the conclusion of the first thin capitalisation audit case, taxpayers are advised to closely monitor their financing arrangements in general and debt-to-equity ratios in particular, and to prepare proper documentation where the threshold ratios are exceeded in order to secure interest expense deductions. Our team will assist you to ensure that your financial arrangements are consistent with the required thin capitalization rules.

In line with this, we will also advise you on the tax implications that arise as a result of foreign loans received from controlling non-resident companies free of interest. This is in light of interest equal to the average ninety-one day Treasury Bill rate, deemed to be payable by a resident person in respect of any outstanding loans provided or secured by a controlling non-resident or its non-resident associate.