US-EU Intercompany Design
Design tax-efficient intercompany structures for companies operating across the US and EU, addressing transfer pricing, double taxation treaties, substance requirements, and regulatory compliance.
SupaScore
84.3Best for
- ▸Creating holding company structures to minimize US-EU withholding taxes on dividends and royalties
- ▸Designing transfer pricing policies for IP licensing between US parent and EU subsidiaries
- ▸Structuring EU manufacturing operations to comply with OECD BEPS substance requirements
- ▸Optimizing intercompany debt structures while avoiding ATAD interest deduction limitations
- ▸Implementing DAC6 reporting compliance for cross-border tax arrangements
What you'll get
- ●Step-by-step entity restructuring plan with jurisdiction analysis, functional characterization, and arm's length pricing methodology selection
- ●Transfer pricing documentation package including economic analysis, comparable company benchmarking, and legal memorandum
- ●Treaty optimization matrix showing withholding tax rates across multiple jurisdictions with substance requirement checklist
Not designed for ↓
- ×Domestic US tax planning without international components
- ×EU VAT structuring or indirect tax optimization
- ×Immigration or employment visa requirements for international staff
- ×Securities law compliance for cross-border equity offerings
Current corporate structure details, business operations overview, revenue streams, and existing intercompany agreements for comprehensive tax optimization analysis.
Detailed intercompany structure recommendations with transfer pricing documentation, treaty optimization strategies, compliance checklists, and implementation timeline.
Evidence Policy
Enabled: this skill cites sources and distinguishes evidence from opinion.
Research Foundation: 8 sources (6 official docs, 1 books, 1 academic)
This skill was developed through independent research and synthesis. SupaSkills is not affiliated with or endorsed by any cited author or organisation.
Version History
Initial release
Works well with
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Common Workflows
International Tax Structure Implementation
Design optimal intercompany structure, prepare supporting transfer pricing documentation, then implement through legal agreements and contracts
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