Case study 1
Residency reassessed for each year of a rotating posting history
An aid worker had moved between postings every year or so over a long period, and the residence position had been set once at the outset and never revisited. We built the presence and posting history from contracts, travel documents and tenancies, tested residence for each year under the relevant domestic rules, and applied the treaty tie-breaker where both countries had a claim. The engagement produced a year by year residence schedule, amended filings for the years that had been wrong, and a rule for reassessing on each future move.
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Case study 2
Hardship allowances reconciled between employer treatment and local law
An organisation had reported hardship and hazard allowances as reimbursements while the worker country of residence treated them as ordinary employment income. We obtained the allowance policy and the payment records, established what each payment was actually for and whether it matched a cost incurred, and set out the treatment under the rules that applied. The work produced a written position on each allowance, an amended return reporting the taxable portion, and a request to the employer to change what its annual statement reported.
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Case study 3
Home base left available and tested against the residence rules
A worker had been told that keeping a flat at home made them resident there regardless of where they lived. We identified which test was being applied, gathered the facts it turned on, being occupation, letting, family location, the pattern of absence and the days actually present, and reached a position for each open year. The engagement produced a documented residence conclusion that differed from the assumption for part of the period, corrected returns for those years, and a note of what would have to change to hold the position.
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Case study 4
Employer posting and payroll countries settled in the right order
A worker employed by a body in one country, posted to a second and paid through a third had claimed relief in the wrong sequence, and the same income had been taxed twice. We established what each country asserted, identified the governing treaty for each pair, and set the order in which exemption and credit had to be taken. The work produced a corrected sequence of filings, a repayment claim in the country with no underlying right to the income, and the double charge removed.
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Case study 5
Posting agreement read to establish who an exemption covered
A team on one project were being taxed differently from each other, some relying on an exemption tied to the organisation arrangement with the host government. We obtained that arrangement and the individual posting agreements, established which staff the relief actually named and on what conditions, and reached a conclusion for the person who instructed us. The engagement produced a written position on the exemption, the filings that followed from it, and a document trail the host authority could check against its own agreement.
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Case study 6
Withholding in a third country recovered after the year end
Salary paid through a paying agent in a country the worker had never been posted to had been subject to deduction there throughout a contract. That country had no underlying right to the income under the applicable treaty. We established the authority the deduction had been made under, assembled the residence certificate and payment records required, and lodged the claim. The work produced a repayment of the tax deducted, a relief at source arrangement for the remainder of the contract, and a corrected credit position on the home return.
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Case study 7
Branch or Subsidiary, Decided Before Incorporation
The choice changes where profits are taxed, what has to be filed, and whether losses in the early years are usable. It is difficult to reverse once trading has begun, so it is modelled first.
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Case study 8
Residency Changed Mid-Year and Both Returns Assumed a Full One
A move part-way through a year produces two part-year positions, not two full ones. The engagement establishes the date residence actually changed, allocates income either side of it, and amends whichever return was filed on the wrong footing.
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