What makes app & game studios different from an ordinary filing?
App-store revenue arrives net of platform fees and sometimes net of foreign tax, and in-app purchase taxation follows the player's location rather than the studio's. An ordinary preparer applies the general rule and stops there, which is how the relief in the specific provision goes unclaimed.
Can you work with my existing accountant?
That is how most of these engagements run. They keep the domestic file, we take the cross-border piece, and the boundary is agreed in writing so nothing is done twice or missed.
Why is my app store payout smaller than the sales my dashboard shows?
Several things come out between the two figures. The platform's commission accounts for most of it and is the one you can see. Underneath sit refunds, currency conversion, and in some territories tax that the store has collected or withheld before paying you. The dashboard shows gross player spend; the payout is what survives all of that. The only way to know which part is tax is to work through the platform's financial reports rather than the summary screen. The distinction matters, because tax suffered abroad may be creditable and commission is simply an expense.
Do I owe tax where my players live or where my studio is?
Both questions have answers and they are not the same answer. Consumption taxes on in-app purchases generally follow the player's location, which is why the store applies different rates to the same item in different territories. Tax on the studio's profits follows the studio: where the company is resident, and any country where it has enough presence to be taxed there. So a studio can have consumption tax exposure in dozens of territories while its profits are taxable in one or two. Treating the two as a single question is the usual source of trouble.
The store says it handles the sales tax for me, is that the end of it?
For the transactions it covers, largely yes, and it is a real simplification. What it does not cover is everything outside the store: sales from your own site, sponsorship and advertising income, publisher and platform deals, and business-to-business licensing. It also does not touch the studio's own profit filings, or any registration you may need for those other streams. We look at the revenue that does not come through the store first, because that is where the unhandled obligations usually sit.
Our contractors abroad are treated as employees there, what does that mean for us?
It can create obligations for the studio in their country, not only for them. Where a country decides that someone working for you is in substance an employee, the questions that follow are about payroll registration, withholding and social contributions there. A closely related question is whether that person's activity gives the studio a taxable presence in that country at all, particularly if what they do is central to the business rather than support work. Both turn on what the person actually does, so the contracts and the working reality have to be looked at together.
Can I claim back tax that a platform withheld on my revenue?
Sometimes, and it depends on what was withheld and why. Tax deducted at source on a cross-border payment to you is a different thing from consumption tax collected from your players, and only the first is ordinarily creditable against your own tax. The treaty between the two countries may also cap the rate that should have been applied in the first place, in which case part of the answer is fixing the paperwork with the platform for future payments. Both routes need the withholding identified and evidenced from the platform's reports.
We have players everywhere but only file in one country, is that wrong?
Not necessarily wrong, but worth testing rather than assuming. Having players in a territory does not by itself make the studio taxable there on its profits. What can is a person, an office or an arrangement in that territory doing something substantive for the business. Consumption tax is the separate question and is often handled by the store. So the test is not where the players are but where the studio does things and through whom. That is usually a short review and it is better done before a filing history accumulates.
Is "fund transfer pricing" the same thing as transfer pricing?
No — and if you came here to calculate FTP, this is not it. Fund transfer pricing is a bank's internal allocation of funding costs and benefits between its own business units, a treasury and asset-liability management discipline used to measure branch or product profitability. Tax transfer pricing is about prices between legally separate related parties across borders, and about which country taxes the resulting profit. The words overlap; the fields do not. See our transfer pricing work.
What happens if the two countries disagree about which of them can tax me?
The treaty has a procedure for exactly that. You apply to the competent authority in your residence country, which takes the case up with its counterpart, and the two negotiate a position that removes the double taxation. Some treaties add binding arbitration if they cannot agree. It is slow and it runs on documents, so the practical work is preserving the record and filing protective claims while the clock runs. See our treaty work.
