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Tax efficient intra-group financing


While cross-border intra-group financing arrangements may be relatively straightforward from a commercial perspective, they could give rise to a range of tax issues, including withholding taxes, transfer pricing, thin capitalization rules etc.
Therefore, consideration has to be given as to how to move cash between legal entities ensuring full compliance with legal and foreign exchange requirements and minimal tax costs.
For businesses that require an innovative, tax efficient approach to financing, PwC delivers a range of finance and treasury services to address tax issues associated with debt and/or equity financing in both Serbia and abroad.

Your situation:

  • You need maximised tax efficiency of financing;
  • You want increased effectiveness of treasury/cash management function;
  • You want to minimize costs of withholding tax on interest;
  • You want to provide deductibility of interest expenses for tax purposes;
  • You want to perform repatriation of funds at minimal tax cost;
  • You want to take advantage of local tax incentives and Serbian treaty network benefits;
  • You wish to manage tax risk relating to intra group financing (deductibility of interest expenses).

Our services:

  • Advice on tax efficient debt versus equity financing;
  • Review of loan arrangements and advice on the restructuring of existing debt financing within a group;
  • Advice on tax efficient use of foreign based financing companies, both through use of Serbian treaty network and off-shore locations with low effective tax rate on interest;
  • Maximizing leverage and tax deductibility of interest expenses within thin capitalization and transfer pricing restrictions.

Contact us

Branka Rajicic

Partner, Tax and Legal services

Tel: +381 11 3302 100

Dragan Draca

Partner, Tax Services

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