International Taxation

International Taxation

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Cross-border investments and operations raise a host of tax issues. Navigating the complexities of multijurisdictional taxation requires innovative tax planning, structuring and dispute resolution. When your business interests span the globe, turn to Dentons for advice.

As you enter new markets, new tax issues arise. Let our team guide you through the maze of cross-border taxation and offer practical solutions to minimize your worldwide effective tax rate. As your business changes, we will devise tax-efficient approaches to accommodate those changes, and advise you on the advantages and disadvantages of alternative structures.

Structure deals in markets around the world. Strategize acquisitions and disposals of foreign entities and repatriation of profits, thereby streamlining profits out of foreign entities. Minimize foreign income and withholding taxes though tax treaties. Develop a robust transfer pricing system. Whether your interests involve funds formation or global corporate transactions, we plan for the tax efficiencies you desire.

From the courtroom to the boardroom, you gain experienced representation to protect your business. Look to our lawyers to address all of your tax needs. Whatever your objective, we will give you the tax solution to achieve it.

Experience

Afinum Management GmbH: Advising on their investment in the British Overclockers Group. Afinum acquired Overclockers on behalf of its subsidiary Caseking Group, a leading German wholesaler and reseller of specialist PC components, accessories, and devices. With the acquisition of Overclockers Group, Caseking takes over a major British supplier with distribution structures across Europe. Our experienced private equity team in Frankfurt and London provided full-service advice to Afinum and Caseking on all legal, tax and structural aspects of the transaction.
AXA Investment Managers Private Equity Europe SA: Advising on the acquisition of a majority of shares in Competence Call Center Group (CCC) as well as on the structuring and financing of the transaction. This was AXA’s first commitment in the sector of call center and outsourcing services. The CCC Group, headquartered in Vienna and present in Austria, Germany, Turkey, Switzerland, Slovakia, and Romania, counts more than 2,000 employees and is a leading European company in this sector. Our private equity teams in Frankfurt, Bratislava, and Bucharest advised AXA on all relevant legal and tax structuring aspects of the transaction, working closely together with Vienna-based law firm Hausmaninger Kletter on aspects of Austrian law.
Multinational oil company: Advising on the sale of Natural Gas Liquids (NGL) business to Plains Midstream Canada ULC, a wholly owned subsidiary, for $1.67 billion. This is the most recent of several billion-dollar-plus transactions where Dentons has partnered with the oil company. The NGL business owns, operates and has contractual rights to assets that run the gamut of production and distribution functions, from extraction though to wholesale distribution of NGL products across Canada and in the Midwest United States. Among the assets, for example, are approximately 4,000 kilometers of pipeline systems and a storage capacity of 21 million barrels of NGLs.
Capital Power: Advising on financings, which have a combined value of US$995 million, specifically a US dollar note issue by Capital Power US Financing L.P., as issuer, and guaranteed by Capital Power L.P., as parent guarantor, pursuant to which US$230 million 5.21% Series A senior guaranteed notes and US$65 million 5.61% Series B senior guaranteed notes were issued, and the amendment and restatement of the senior syndicated credit facilities of Capital Power L.P. for US$700 million. The amendment and restatement included the addition of Capital Power (US Holdings) Inc. as US borrower.
Capital Power Income L.P.: Advising on its CA$1.1 billion acquisition by Atlantic Power Corporation.
COMESA: Advising on the establishment of a pan-African infrastructure fund.
Continental Wind Partners: Advising the investment fund on the sale of the first significant wind project in Romania to Czech-based CEZ, including liaising with the Romanian public authorities. Following this project, Dobrogea became the preferred location for renewable energy source (RES) investments in Romania.
Energy company: Advising on the tax aspects of the development of a greenfield sugarcane plantation, the construction of an ethanol refinery and a biomass fuelled power plant, including negotiating a tax incentives agreement with the Government of Sierra Leone.
Europe-based original equipment manufacturer and aftermarket automotive supplier: Advising on the massive refinancing of over $14 billion of debt related to a recent acquisition. We created the most tax advantageous structure for our client and continue to find business oriented solutions for the client in connection with the refinancing of the capital structure, while guiding our client to avoid transfer pricing adjustments, and ensuring regulatory compliance.
Family offices and ultra high net worth individuals: Acting for a number of clients providing tax advice on international investments, global portfolio structuring, yacht and jet leasing and acquisitions.
Grant Forest Products Inc.: Acting as counsel on the CCAA and US Bankruptcy Court approved acquisition of its oriented strand board facilities in Ontario and South Carolina, US by Georgia-Pacific LLC for US$400 million.
Large International bank: Advising a prominent international bank on a cross-border transfer of a leasing portfolio as part of the disposal of its non-core aviation arm. We drew upon our experience in cross-border leasing taxation and our creativity in resolving issues resulting from the interaction between tax systems to advise on the UK tax and value added tax aspects of the acquisition of the portfolio, negotiate amendments to the documentation and coordinate the highly intricate international tax aspects of the transaction.
Leading company in the rolling papers sector: Advising on the most efficient way from a tax point of view regarding the cross-border restructuring where the Spanish company sold its subsidiaries in Catalonia and Austria to a French company, cancelling the operations with the American headquarters. The team also advised on the implementation of the mentioned structure.
Multinational dairy products corporation: Advising and assisting the second largest dairy products group in the world and the second largest food products group in France on all tax aspects of its acquisition policy across Europe with special focus on the markets in Germany, France and Poland. Among the different specific services, our tax lawyers mainly focused on tax structuring work, an in-depth tax due diligence, financing schemes and Transfer Pricing schemes.
Natixis Zweigniederlassung Deutschland: Acting as lead adviser to the lenders in respect of the €190 million refinancing of a property financing facility relating to the Nova Eventis Shopping Center in the proximity of Leipzig; our real estate finance team advised the consortium of lenders led by Natixis Zweigniederlassung Deutschland and comprised of ING Bank, Deutsche Postbank and Bawag in a complex, cross-border structured real estate refinancing which spanned several jurisdictions and involved additional foreign counsel in UK, Guernsey and the BVI.
Energy infrastructure equipment and services leader: Providing one of the world’s leading energy infrastructure equipment and services leader with a sophisticated analysis clarifying open corporate and cross-border tax issues arising from the company’s then-existing capital structure. We designed and implemented a sophisticated reorganization of select members of the client’s European and Latin American operating structure to maximize operational efficiencies and reduce US taxation of ongoing operations while also realizing significant local tax savings for the company.
Polish, Luxembourg and Dutch tax: Advising on the Polish, Luxembourgian and Dutch tax aspects of setting up investment funds to operate on the Polish real estate market. International tax structuring allowing for tax-efficient conversion of tax into the target structure and obtaining relevant tax rulings in Poland and the Netherlands. The advice on the transaction addressed tax, legal and business goals of the client, taking into consideration the old structure and potential future changes to applicable laws.
Prevost Car Inc.: Advising before the Tax Court of Canada and the Federal Court of Appeal in Prevost Car, Inc. v. The Queen in a landmark international tax case dealing with the interpretation of the term "beneficial owner" in the Canada-Netherlands tax treaty. The taxpayer, Prevost Car, Inc. was a wholly-owned subsidiary of a Netherlands corporation, which was itself jointly owned by Swedish corporation Volvo AB, and a United Kingdom corporation Henly's Group PLC. The issue was whether the Netherlands corporation qualified as the "beneficial owner" of dividends paid by the taxpayer for purposes of the relevant tax treaty and therefore entitled to a reduced Canadian dividend withholding tax rate.
Private banks: Advising on lending to ultra high net worth individuals, including Shariah compliant structures and personal jet and yacht financing.
PSE Operator: Advising on the €120 million acquisition of a power interconnection between Poland and Sweden (SwePol Link) by PSE Operator (50 percent) and Svenska Krafnat (50 percent). The facilities consist of converter stations in Sternö (Karlshamn, Sweden) and Slupsk (Poland), as well as a submarine pole cable and return cables. The capacity of the link is 600 megawatts. The interconnection was initially operated by special purpose companies and following acquisition by PSE Operator and Svenska Krafnat became an inter-TSO project improving power grid stability in Poland and Scandinavia.
TerreStar Networks Inc.: Advising on the DISH Network Corporation acquisition of its assets, valued at C$1.37 billion. The transaction is unique in that DISH agreed to advance, and did advance, approximately 97 percent of the purchase price prior to the transaction receiving Canadian and US regulatory approval and for being one of the first deals under the new liberalized rules for foreign ownership of Canadian satellites. DISH completed its acquisition of TerreStar on March 9, 2012.
Total, SA: Advising in connection with the sale of its French solar energy subsidiary Tenesol to SunPower Corporation, a US company listed on the Nasdaq stock exchange, for US$165.4 million. Tenesol is a leader in the French market for large industrial and commercial solar installations, with operations in 18 countries and solar panel manufacturing facilities in France and South Africa.
Various Canadian clients: Advising on tax concerns with respect to entry into the Middle East and Africa through a European entity, investment with a US partner into a European operating entity and investments into Central Asia and Australia.

Recognition

Dentons secures 141 individual and 42 practice rankings in Legal 500 US 2017

June 6, 2017

Dentons earned 141 individual and 42 practice rankings in the most recent edition of Legal 500 US 2017, an annual legal directory, which catalogues the nation's best lawyers and law firms based on in-depth research and interviews.

Dentons Boosts Rankings in 2015 Edition of Legal 500 US

June 11, 2015

The 2015 edition of The Legal 500 US recognizes 24 Dentons practices and 75 lawyers.

Insights

The new United States tariffs and their effect on the Mexican manufacturing industry: some considerations

April 9, 2025

Mexico: The new United States tariff policy is now a reality and has already reshaped the global trade principals that were agreed since the enactment of the General Agreement on Tariffs and Trade (“GATT”) and the World Trade Organization (“WTO”). The Most-Favored-Nation principle (“MFN”) has now been replaced by a reciprocal tariffs system unilaterally proposed by the United States, the largest world’s economy.

Do President Trump’s Tariffs Constitute Force Majeure?

April 8, 2025

United States: President Trump has threatened to impose a 25% tariff on products from Canada and Mexico and a 10% tariff on Chinese products beginning February 1st, 2025.

Beneficios fiscales en México para atraer inversiones y promover la capacitación científica y tecnológica. Deducciones aceleradas y adicionales

January 28, 2025

Mexico: El 21 de enero de 2025, el gobierno mexicano publicó en el Diario Oficial de la Federación un decreto por medio del cual otorga beneficios fiscales específicos como parte del “Plan México” impulsado por la presidenta de México para atraer inversiones, promover la capacitación técnica y científica y fortalecer cadenas de suministro locales.

View all insights for International Taxation

News and Events

Recent Press Releases

Dentons advises Advenis on acquisition of new CSA European headquarters in Plattling, Germany

June 30, 2021

Global law firm Dentons has advised French investment manager Advenis Real Estate Investment Management ("Advenis") on the acquisition of an office property in Plattling, Lower Bavaria. The sellers are MB Park Deutschland and Isarkies Wohn- und Gewerbegrund. Advenis is purchasing the property as investment advisor for the French fund Eurovalys, which primarily invests in office and commercial properties in Germany.

Bloomberg Tax and Accounting has released the Business Operations in Russia portfolio, prepared by Dentons lawyers

May 26, 2021

Lawyers of Dentons St. Petersburg and Moscow offices under the project management of Yana Butrimovich, Manager in the Tax and Customs practice, and Vasilii Markov, partner in the Tax and Customs practice, have authored the updated edition of Business Operations in Russia portfolio for a division of the international analytical agency Bloomberg (Tax and Accounting).