SYNAPTAX structures and implements cross-border reorganisations by ensuring long-term coherence between legal form, tax treatment and economic reality.
Strategic legal and tax structuring
We structure and implement complex international reorganisations by integrating strategy, finance, law, tax and operations into a single, coherent design. Tax is a structuring tool, not an isolated objective.
Secure implementation across juridictions
We act as a point of connection within an international network of lawyers, ensuring consistent coordination across juridictions.
Support in tax audits and disputes
We assist during tax audits and selected disputes related to cross-border reorganisations, whether the structuring was made by us or others, ensuring continuity between structuring and defence.
Our solutions
International tax management of restructurings
Advise on the tax consequences
of proposed Luxembourgish and
cross-border reorganizations
Financial optimizations
Transfer pricing analysis and documentation
Design investment
or group financing in compliance
with transfer pricing rules
Tax reporting and tax accounting projects
Support for DAC 6 reporting
and
tax accounting projects
Recent news
Does the tax audit of a Luxembourgish financing structure only focus on the interest rate of the loans ?
What are the key elements of a Tax audit of a Luxembourgish financing structure? Is it sufficient to apply arm’s length interest rates to the loans to avoid a tax assessment by the Luxembourgish tax administration?
Should my Luxembourgish company order a Transfer Pricing report for its current loans or receivables?
Is it financially better to run the risk of a tax audit or to order a TP report?
Can we mitigate the risks by changing the current structure?
To which extent are the Transfer Pricing rules applicable if the other companies are resident in Luxembourg?
