Case Notes

Short, practical breakdowns of real projects — scope, approach, and outcome. These are anonymized and audit-ready in style.

VATCITPayroll & PIT WHTTransfer Pricing

VAT, CIT & PIT advisory (cross-border)

Advisory memo

Actionable memo with registration triggers, PE/WHT risks, payroll duties — plus a step-by-step plan.

Scope

  • VAT place-of-supply & registration triggers (local & OSS).
  • Permanent establishment risk & CIT implications.
  • WHT exposure for services/royalties; treaty relief options.
  • PIT & payroll duties for inbound staff; net-to-gross model.

Outcome

  • Clear go/no-go on registrations with timelines & forms.
  • PE risk triage with mitigation steps and monitoring plan.
  • WHT rates & documentation pack checklist.
  • Payroll set-up path; certificates & monthly workflow.

US SaaS → Serbia LLC

Company setup

Bank opened in 14 days, VAT in 10 days; first invoice compliant.

Scope

  • LLC incorporation pack & filings; UBO/KYC support.
  • VAT registration with e-invoicing onboarding.
  • First-invoice checklist (content, FX, VAT statement).

Outcome

  • Transparent timelines aligned with bank KYC.
  • First compliant invoice issued on day 1 post-VAT.
  • Founder checklist for payroll & PE considerations.

WHT treaty relief (German investor)

WHT & treaties

WHT reduced to 5%; added +15% extra net.

Scope

  • Treaty analysis; beneficial ownership & substance review.
  • Residence certificate & documentation pack.
  • Forms; filing & follow-up with tax office.

Outcome

  • Reduced rate applied; refund process mapped.
  • Reusable document pack & annual refresh checklist.

TP local file

Transfer Pricing

TNMM — 7.8% median — accepted at audit.

Scope

  • Related-party mapping & scoping; functional analysis.
  • Benchmarking (TNMM); policy draft; risk flags.
  • Local file to audit standard; review support.

Outcome

  • Defensible margin corridor; policy embedded.
  • Clean review; no audit adjustments.

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