SDG are becoming increasingly concerned about their image with respect to their corporate social responsibilities and their tax compliance. Their current international tax strategies have evolved over the years under the advice of their previous tax adviser. The SDG Board believes they have been far too aggressive and have hired your Firm for tax services. They have requested a critical assessment of the specific issues (below) with reasonable advice on how best to restructure their international tax affairs without appearing overly aggressive. They want to minimize their global tax obligation, but within the letter and spirit of national and international tax laws to avoid any adverse media attention. The SDG Brand as an innovative manufacturer and retailer in ecologically sound and sustainable clothing must not be tainted by inappropriate tax strategies.
Transfer pricing issues regarding the various services provided within the Group under current legislation and the relevant legislative proposals (e.g. EU’s CCCTB and the OEDC BEPS2).

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Transfer pricing issues 1Intellectual property 2Highvalue services transaction 3Intercompany financi... View the full answer