Change of Head Office

www.bethelfinance.com

European head office

There comes a time when a company may deem necessary to establish its headquarters outside the country of origin, for personal reasons, or tax policy.
It is perfectly natural to want to keep the result of years of work and relationships with customers and suppliers.
Your company makes money but, pays too much expenses or taxes – or your company is not working that well and will soon fill insolvency and … you dread filing for bankruptcy may affect you or you simply want to leave your country to other climes more favorable.
How to transfer abroad the headquarters of my company?
When the activity of the company is internationally oriented it is quite simple.
Except that the legislature of your country does not like relocation:
The transfer is always at the expense of the collector and you might be victim of the relocation benefits.
The different governments had therefore, sufficiently adorned the course of the relocation with obstacles, to discourage any hint of change of registered office.
Rest assured, we will be able to solve all these administrative details so you can benefit from better tax incentives.
The first step of our strategy before moving your head office is to transfer as much as possible the assets of the company to other companies build for that purpose
Why ?
Even if it is legal, the risk might be too high and you would certainly have to go to court (and win), which will be quite costly and will take a lot of your precious time.
Our approach
Our approach focuses on the value chain between the head-office and the PE. (permanent establishment)
The traditional transfer pricing approach is based upon an analysis of the factual and functional arrangement.
In addition, the contractual relationship is evaluated to determine the risk and assets deployed. Hence, in ordinary transactions between affiliates, it is possible to segregate functions, risks and ownership to assets by virtue of the contractual relationship.
This is the approach deployed by tax authorities and professionals when performing a functional and risk analysis.
The arrangement between a PE and its head office is referred to as a dealing.
Based on this multi-national technic, we will create real establisment outside your country and start transferring the functions operated previously in the head office.
What is the cost of this strategy ?
We will do the job four times cheaper than the big 4…
What is the benefit of this strategy ?
If you move your head office to Cyprus for instance, your corporate profit taxe will go down to only 10%.
The wages of your local employees will be at least 30% cheaper than your current cost of labor
This strategy will have then two major benefits, first have more profit to distribute to the shareholders and make your company more competitive to gain more market shares.

Transfer your head office within the EU

Each European company as a legal person has the possibility to cross borders within EU

Freedom of establishment is a fundamental right enshrined in the EC Treaty.
The Article 48 of the Treaty requires that ‘companies formed in accordance with the law of a Member State and having their registered office, central administration or principal place of business within the Community be treated in the same way as natural persons
who are nationals of Member States’.
The combination of Article 48 and Article 43 ensures that a company of any Member State has the right to operate undertakings or set up agencies, branches or subsidiaries in the territory of any Member State.
By and large, companies in Europe have largely benefited from this freedom over the years.
A look at the trend regarding intra-Community direct investment flows over the last 10 years shows that the right of establishment has been an important factor of economic integration at European level.
Dont think that your tax authorities will let you go just like that, many companies went to court to be free.
We at Bethel Finance believe that transfering the head office of your company is the end of a process and not the begining.
Your country has too much to loose in letting you go, we rather create subsidiaries and holding on the first stage and finally transfer the head office when the assets are already out of your country

To know more, call us at + 972 3 643 79 99 or email us at info@bethelfinance.com