“Our experience drives our expertise. We master international taxation”

The team at Level International works closely with tax leaders at multinationals, international finance teams, entrepreneurs, founders, private equity partners, fund managers and other decision makers. We offer solutions to leverage opportunities for growth in international taxation. Taxation includes payment of taxes and the hard work of compliance. Our services tailor to reducing tax charges and to derive benefits from being taxed. Turn taxation into a competitive advantage, is the motto we live by.

We provide consultancy in the following areas:

  • Domestic tax law under double tax treaties
  • Effects of OECD and BEPS transformative works
  • International exchange of information, mandatory disclosures
  • Capital, business and asset structuring
  • European Union Tax Law and Brexit

Double Tax Treaties

We cover the following subjects:

  • Permanent establishments for traditional and digital businesses
  • Intangibles and royalties
  • Capital and dividends and interest
  • Permanent establishments, personal services and people remuneration
  • Mitigation of double taxation, rulings and mutual agreement procedures
  • Income from shipping, air and land transport,
  • Capital gains and fund management
  • Professional and ıntra group services
  • Director’s fees and personal tax liabilities for artists and athletes
  • Pension, annuities and social security pay-outs
  • Derivatives and other income


Digital Economy

Globally there is a clear trend to tax digital businesses. To avoid surprises, we evaluate your operations within the electronic trade from several perspectives: “permanent establishment”, “controlled foreign company income” and “transfer pricing”. The advices we issue always include trends of the OECD / BEPS Action Plans. Then we propose optimum net taxation solutions such that your business can continue to grow and adapt its business models over time. Competitive Effective Tax Rates in digital economy require forward thinking, acceptance of increasing tax burdens and contemporaneous adjustment of operational models.

Intra-Group Financing

At Level International we carefully evaluate the cross section of short, mid and longer-term financing plans, current and anticipated (OECD / BEPS) regulations. Then we propose solutions of compliance and effective group financing strategies with maximized interest deductions.

Permanent Establishments

Doing business across borders, often raises the question “Do we have a taxable presence in foreign lands?” We support our clients in evaluating whether foreign tax filings must be made for electronic trade with in-country warehousing, dispatchment, customer service activities. We advise on local tax declarations and VAT compliance.

Intellectual Property Ownership and Royalty Optimization

Taxation of IP has increased focus of OECD and many Taxing Authorities. This vast and complex arena has traditionally been exploited to reduce Effective Tax Rates of international groups. Digital business has traditionally been extremely low taxed. With increased scrutiny OECD, Finance Ministries across the globe aim to increase taxation on IP and Digital Economy. At Level International we are not surprised. With our services we provide agile solutions, competitive tax rates. We aim to unburden company valuation multiples for start and scale-ups from excessive IP and Digital Economy taxes. Our process is robust and asserts;

  • To which legal entity an intangible asset belongs
  • Any difference between legal and economic ownership
  • Functional analysis of IP exploitation across a supply chain
  • The economic realities of the operations of the IP owner entities
  • Contracts
  • OECD / BEPS Action Plan compliance
  • Existing Transfer Pricing studies and supporting documentation, incl. ERP assessment

The OECD has identified certain traditional tax planning tools and under the BEPS project deems those no longer acceptable. Our services include a review of existing or planned arrangements and proposals to unwind or restructure them.

  • Hybrid (legal) instrument and cross border taxation mismatches
  • Income from tax heaven and low tax entities
  • Tax treaty protection by virtue of Limitation of benefit and principal purpose tests
  • Artificial risk and capital allocations for construed transfer pricing benefits

We know taxation is a subjective matter. Hence, we represent clients in direct communication with authorities to obtain Rulings, Advance Agreements, and if required appeals to arbitration. For the UK we have easy access to respected (tax) barristers.

International Exchange of Information

Almost all countries apply automatic exchange of information on different subjects. These exchanges aim to force transparency by taxpayers in their country of residency.  These Common Reporting Standards (CRS) were introduced in 2017 and are gradually becoming the norm across the world.

Complying with the automatic exchange of information rules imposes serious compliance and potential liabilities on MNE Groups and their subsidiaries, individuals as well as certain tax advisors.

We are of the opinion these reporting standards can be turned into value drivers. The work required can be used for improvement of cross functional collaboration, team work and a process redesign may make your organization less dependent on consultants. Equally, dialogue with tax authorities may be improved such that tax planning 2.0 becomes a possibility. With a mindset of Growth through Compliance we help our clients to get a return on tax compliance beyond a mere license to operate.

  • We help to navigate CRS, CbCR and EU exchange of information rules (e.g. DAC6)
  • We assist to prepare CbCR filings and can propose tax technology solutions
  • We help tax and finance leaders to derive value from intra-organization processes

Investment, Asset, Business and Capital Structuring

Level International offers full support for Capital, Debt, IP and other Investment structuring and re-structuring. We have tested M&A experience. We are versed on start and scale up challenges as we are with tax, corporate finance and governance challenges of mature and fading businesses.

We assist our clients with:

  • Determining operating and restructuring models
  • Designing, sanitizing and implementing international operating and holding structures
  • Debt, Equity, Mezzanine financing and royalty arrangements
  • Holding and Fund structures
  • Tax effective supply chains and market penetration models
  • M&A, divestment and re-financing

European Union Law

Having been at the forefront of EU law cases and operating models for decades. We have know-how to optimize and weather proof business models from EU laws. Often, local legislation conflicts with EU principles. The gaps either grant opportunities or cause risks. Our platform can assist you with:

  • Capturing EU law opportunities
  • Minimizing risks and uncertainties of local and EU law conflicts
  • Mandatory disclosure compliance
  • EU entities, cross country mergers and de-mergers
  • Cross border transfer of losses and deductions
  • Clarity on exit taxes when relocating a business within or beyond EU
  • Intra EU VAT and VAT upon entry into EU
  • Brexit
Request International Consultation

Request International Consultation

We have a highly experienced, diverse and international team who can listen to your needs, quickly evaluate options and offer an integrated tax and corporate solution at an attractive price.