WLA INTERNATIONAL TAX GROUP

Cross-border tax structuring, transfer pricing, BEPS compliance, and international tax disputes — co-practiced by specialist tax lawyers in every relevant jurisdiction. The WLA Tax Group works alongside the Transactional, Insolvency, and Immigration practices on every major cross-border matter.

FIND A TAX SPECIALIST — 48H EXPLORE CAPABILITIES

LIVE TAX INTELLIGENCE

UPDATING

OECD PILLAR TWO

Global Minimum Tax · 15%

15%

Effective 2024+

UAE CORPORATE TAX

Federal CIT — Free Zone

QFZP Rules Clarified

UK DST

Digital Services Tax

OECD Pillar 1 Watch

INDIA — DPDP

Transfer Pricing · Digital

+34%

TP Activity Rising

OECD PILLAR TWO — GLOBAL MINIMUM TAX

15%

The OECD Global Minimum Tax is live. Qualifying companies with revenue above €750M must now ensure an effective minimum tax rate of 15% in every jurisdiction they operate in. WLA Tax Group advises on compliance structuring across every relevant jurisdiction simultaneously.

OECD TWO-PILLAR FRAMEWORK

PILLAR ONE

Profit reallocation to market jurisdictions — large multinationals. OECD MLC under negotiation.

IN NEGOTIATION

PILLAR TWO

Global minimum effective tax rate of 15%. IIR, UTPR, and STTR rules now active in major jurisdictions.

LIVE · 60+ STATES

TAX CAPABILITIES

EVERY DIMENSION OF
CROSS-BORDER INTERNATIONAL TAX.

TRANSFER PRICING — CROSS-BORDER INTRA-GROUP TRANSACTIONS

Transfer pricing documentation, policy design, advance pricing agreements, and dispute resolution across all major tax jurisdictions. WLA Tax Group practitioners in each jurisdiction ensure TP policies are defensible locally and globally consistent. Country-by-country reporting compliance and BEPS Action 13 documentation coordinated across the group.

INTERNATIONAL TAX STRUCTURING — M&A AND HOLDING STRUCTURES

Tax-efficient structuring for cross-border M&A transactions, group reorganisations, IP holding structures, and financing arrangements — coordinated across all relevant jurisdictions simultaneously. WLA Tax Group works alongside the Transactional practice to ensure deal structure is tax-optimised in every jurisdiction before signing.

BEPS COMPLIANCE — OECD PILLAR ONE & PILLAR TWO

Comprehensive BEPS compliance across OECD Pillar Two (Global Minimum Tax), BEPS Actions 1–15, and national implementation legislation in each jurisdiction. WLA Tax Group practitioners advise on Qualified Domestic Minimum Top-Up Tax (QDMTT), Income Inclusion Rule (IIR), and Undertaxed Profit Rule (UTPR) compliance in every relevant territory.

TAX DISPUTES & CONTROVERSY — CROSS-BORDER

Cross-border tax disputes, mutual agreement procedure (MAP), competent authority negotiations, and international tax arbitration under BEPS Action 14 — co-practiced by WLA Tax Group practitioners alongside the Arbitration & Mediation Group. Transfer pricing disputes, PE attribution controversies, and withholding tax disputes across multiple jurisdictions.

TAX IN M&A — DUE DILIGENCE AND STRUCTURING

Tax due diligence for cross-border M&A — tax risk identification, deferred tax analysis, and transaction structuring to optimise tax outcomes in each jurisdiction. Warranty and indemnity alignment on tax representations. Post-completion tax integration planning across all operating jurisdictions.

PRIVATE CLIENT & HNW TAX — CROSS-BORDER

Cross-border personal tax planning for high net worth individuals, family offices, and internationally mobile professionals — working alongside the WLA Private Clients practice. Residency changes, exit taxation, trust taxation, and offshore structure compliance across all relevant jurisdictions.

BEPS & OECD COMPLIANCE

THE BIGGEST SHIFT IN
INTERNATIONAL TAX IN 50 YEARS.

BEPS / OECD ACTION TRACKER — WLA TAX GROUP

Pillar Two — Global Minimum Tax (15%)

IIR, UTPR, QDMTT — 60+ jurisdictions enacted

LIVE

BEPS Action 13 — CbCR & TP Documentation

Country-by-Country Reporting · Master File · Local File

ACTIVE

BEPS Action 15 — MLI (Multilateral Instrument)

Treaty modifications — PPT, LOB, PE provisions

ACTIVE

Pillar One — Profit Reallocation (Amount A)

MLC under OECD negotiation — large multinationals

IN NEGOTIATION

Digital Services Taxes — National Level

UK 2% · France 3% · India 2% · Multiple countries

ACTIVE PARALLEL

BEPS Action 14 — Tax Dispute Resolution

MAP minimum standards · Mandatory arbitration

MONITORING

WLA TAX GROUP NAVIGATES BEPS COMPLIANCE ACROSS EVERY RELEVANT JURISDICTION.

The OECD BEPS project and the two-pillar framework have fundamentally restructured international tax. For multinational companies, the compliance burden now spans dozens of jurisdictions — each implementing the OECD framework at a different pace, with different national variations, and different enforcement priorities.

WLA Tax Group practitioners in each jurisdiction track local BEPS implementation in real time — feeding into WLA Intelligence daily. The co-practice framework means your tax compliance is coordinated across all jurisdictions by specialist local practitioners, not managed centrally by a team without local expertise.

Pillar Two QDMTT analysis — does your group need a QDMTT in each jurisdiction?
IIR and UTPR exposure assessment — where is top-up tax due?
CbCR filing obligations — jurisdictions requiring local filing
MLI impact analysis — which of your tax treaties have been modified?
DST exposure — which countries impose digital services taxes on your revenues?

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BRIEF WLA ON YOUR CROSS-BORDER TAX MATTER. SPECIALIST IN 48 HOURS.

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WLA INTERNATIONAL TAX GROUP

EVERY DIMENSION OFCROSS-BORDER INTERNATIONAL TAX.

THE BIGGEST SHIFT ININTERNATIONAL TAX IN 50 YEARS.

EVERY DIMENSION OF
CROSS-BORDER INTERNATIONAL TAX.

THE BIGGEST SHIFT IN
INTERNATIONAL TAX IN 50 YEARS.