We design tax structures that allow you to operate across countries with order and foresight. From market entry to transfer pricing, treaty planning, and cash repatriation, we organize the key information and compliance timelines so each decision is grounded in technical support and is explainable to third parties.
Market-entry & PE assessment
Analysis of economic presence and permanent establishment thresholds (agents, warehouses, offices) and contractual mitigations.
Transfer Pricing Policy
Methods, benchmarking, intercompany agreements, and documentation aligned with the OECD Transfer Pricing Guidelines (including Master File / Local File and, where applicable, CbCR).
Treaty & Withholding
Application of treaty benefits, W-8BEN-E / W-8IMY, and beneficial-owner / LOB support to reduce withholding friction on cross-border payments.
CFC/GILTI modeling
Potential inclusions, coordination with foreign tax credits (FTC), and evaluation of high-tax exclusion where available.
VAT/GST & e-invoicing
Registrations, applicable rates, platform rules, and evidentiary support to handle VAT/GST correctly.
Cross-border M&A
Tax due diligence, acquisition structuring, and post-deal integration with a cross-border tax and compliance lens.
Cash repatriation
Dividends, interest, and royalties; analysis of withholding and treaty relief, plus a payment schedule that avoids surprises.
Pillar Two
Readiness for global minimum tax frameworks in jurisdictions that adopt them, including impact mapping and reporting requirements.
We start with a diagnostic of your international footprint (entities, operations, value chain, and payment flows). We map typical risk areas—permanent establishment, transfer pricing, withholding and treaty use, CFC/GILTI, and, for larger groups, exposure to Pillar Two—and define the operating model (intercompany contracts, pricing, documentation, and metrics).
The deliverables are a tax memo with recommendations, a milestone-based roadmap, and a compliance calendar by jurisdiction.
Frequently Asked Questions
Which countries do you work with?
We support teams with operations across multiple jurisdictions. We operate from Florida and work with groups that have a footprint in the U.S. and countries such as the United Kingdom, Spain, Mexico, Argentina, Canada, Colombia, Venezuela, Portugal, Costa Rica, Uruguay, Peru, Aruba, Curaçao, Guatemala, France, Australia, South Africa, South Africa, and others.
Can you help with transfer pricing documentation?
Yes. We prepare policies, intercompany agreements, and supporting files in line with the OECD Transfer Pricing Guidelines (Master File, Local File, and, where required, CbCR), coordinating with local advisors when needed.
How do treaty-based withholding reductions actually work in practice?
We review the relevant treaty provisions and, where a reduced rate applies, we prepare the appropriate W-8 forms and beneficial owner/LOB documentation so the payer can apply the reduced rate with sufficient support for auditors and tax authorities.
What are typical timelines for an initial rollout?
Usually 6–10 weeks: international footprint diagnostic, operating model design, intercompany contracts, benchmarking, compliance calendar, and first local registrations or filings.
What is Pillar Two and how could it affect us?
Pillar Two is a global minimum tax framework for groups above certain revenue thresholds, currently being implemented in various jurisdictions. We assess your group’s potential exposure, model effective tax rate impacts, and help prepare for related reporting and data requirements.
Is GILTI still relevant for U.S. shareholders?
Yes. GILTI continues to apply to certain income of controlled foreign corporations held by U.S. shareholders. There are elections and planning options, including high-tax exclusion, that can materially change the outcome. We model scenarios and coordinate with U.S. foreign tax credit planning.
International Tax Strategy with Documentation Ready for Third Parties
If you are opening a subsidiary, selling into new countries, or consolidating global operations, we help define structure, related-party pricing, and local requirements. In an initial session, we review your case and propose a plan with tasks, timelines, and documentation so you can operate across borders without constant surprises.
Guillen Pujol CPA P.A
6161 Waterford District Dr., Suite 475 Miami, FL 33126
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Guillen Pujol CPA P.A
6161 Waterford District Dr., Suite 475 Miami, FL 33126
Guillen Pujol CPA P.A
6161 Blue Lagoon Dr.Ste 475, Miami, FL 33126
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