Case study 1
Re-reading a treaty position after the multilateral instrument applied
A group had relied on the same withholding position for years, papered against the bilateral treaty text. That text was no longer the operative rule: both countries had adopted modifications through the multilateral instrument, and the position had to be read against the treaty as modified. We identified which provisions applied between the countries concerned, restated the position on that basis, and set out where the answer had changed and where it had not. The engagement produced a revised position paper, a corrected treaty claim going forward, and a list of the group's other treaties needing the same exercise.
Case study 2
Documenting why a holding company exists before anyone asks
A holding company had been established for a reason its founders considered obvious and had never recorded. With treaty access now conditioned on purpose, obvious was not enough. We interviewed the people who took the decision while they were still with the group, gathered the board papers and correspondence from the period, and wrote the rationale as a dated paper with the documents named and attached. Where the record could not support a claim we said so instead of improving it. The engagement produced an evidence pack and a standing practice of recording the reason at the time for each new entity.
Case study 3
A group's first country-by-country report
A group crossed into country-by-country reporting for the first time with its data in several systems and no single owner. We established which entity carried the filing obligation and in which jurisdiction, mapped the group's own figures to the categories the report requires rather than to its management reporting, and documented each mapping decision so that the following year is a repeat rather than a rediscovery. The engagement produced the filed report, a reconciliation from the group's consolidation to it, and a written methodology the group now maintains itself.
Case study 4
A financing structure whose only rationale was the mismatch
An intra-group financing arrangement produced a deduction in one country and no corresponding inclusion in the other, and that mismatch was the whole point of it. Anti-hybrid rules neutralise that outcome, so what remained was a structure with running costs, no benefit, and a purpose the group could not state if asked. We set out the position under the current rules, modelled the arrangement unwound and refinanced conventionally, and documented the commercial reason for the replacement. The engagement produced a simplified financing structure and a written rationale that does not depend on the mismatch.
Case study 5
When the report and the local files told different stories
The group's country-by-country report and its local transfer pricing documentation described the same business differently, profit attributed one way in the report and explained another way in the files, because the report and the files had been prepared by different teams from different sources. We reconciled them, established which description matched what the entities actually did, and corrected the one that did not. The engagement produced a report and a set of local files that tell one story, with any remaining differences explained in writing rather than left for an authority to notice first.
Case study 6
Answering an authority that asked why a structure existed
An authority asked why an intermediate entity existed, and the group had a year of correspondence and no answer written down. We reconstructed the decision from what the group held — the contracts, the approvals, the staffing, and the decisions genuinely taken in that jurisdiction — and separated what the evidence supported from what the group merely believed about itself. The answer given was narrower than the group's own account, and it was supported. The engagement produced a documented response to the query and a record of the parts of the structure that could not be evidenced and were changed afterwards.
Case study 7
Trips That Added Up to a Filing Obligation
Short visits are tracked against a treaty threshold that is measured over a moving window rather than a calendar year. Where the threshold is passed, the obligation reaches back over the whole period.
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Case study 8
One Salary, Two Countries Claiming It
A US citizen resident in Canada, taxed in full on both sides because each return was prepared without the other in view. Deciding which country has the first right to the income, then claiming relief on the second return in the right order, is what stops the same dollar being taxed twice.
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