Four tools that analyse an arrangement the way a practitioner would — then show you exactly how an examiner will challenge it.
Start analysing →Each runs on principles and the auditor's eye — not rate tables.
Describe an intercompany arrangement. Get the practitioner's analysis and the auditor's challenge, side by side.
Open → 02Describe activities in a foreign country. See which PE threshold is in play and how an authority would argue it.
Open → 03Describe a holding or financing structure. See whether it reads as genuine substance or a shell, and where it's exposed.
Open → 04You supply the treaty rate. It does the arithmetic and tells you whether that relief would actually survive scrutiny.
Open →An arrangement, a structure, or activities abroad — in a sentence or two.
The analysis you'd give, and the challenge it has to survive — reasoning over principles.
The likely line of attack and the open questions, so the position is built to withstand scrutiny.