TAXATION

1) Corporate Tax

We help multinational businesses achieve their business goals in a tax-efficient manner, both locally and globally. Understanding the tax impact on business operations and transactions in multiple jurisdictions is vital for a company’s survival. We provide tax consulting, advisory and cross-border restructuring support services from conceptualization of the tax strategy through analysis of tax and regulatory implications of transactions and finally implementation assistance, from the perspectives of domestic law and the international tax treaty network. With the increasing focus on governance and regulation, tax compliance has never been so important. Compliance failure represents not only a financial risk — financial penalties and possible increase in the tax charge, but also a serious business risk, as it can damage the taxpayer’s reputation with the authorities and the public. To remain competitive, companies are increasingly focusing on their core competencies and activities that create value for the company.

2) Stratagic Planning

• Formulating effective and tax-efficient cross-border strategies for both inbound and overseas investments
• Capitalising on planning opportunities presented by local tax law as well as treaty network
• Structuring acquisitions, divestitures and corporate reorganizations for tax optimization
• Staying abreast of new developments within the international arena that affect clients’ businesses, both globally and locally
• Advance rulings to lend an element of certainty to non-resident investors in their proposed transactions in Pakistan

3) Consulting and Advisory

• Analysing the tax impact of transactions holistically having regard to direct tax, indirect tax, regulatory and transfer pricing implications
• Providing opinions on transactions from a domestic law and tax treaty viewpoint
• Identifying tax planning opportunities and addressing potential problem areas in the course of undertaking day to day business activities

4) Business restructuring

• Conceptualization of the proposed structure in the light of business objectives
• Structuring the reorganization – merger, spin off, acquisition or capital arrangement – from a tax and regulatory perspective
• Implementation support to put the structure in place having regard to tax efficiencies, regulatory procedures and intended timeframes

5) Tax Compliance

• Tax return preparation
• Representation services before the tax authorities including assistance in tax audits by the tax authorities
• Assistance in appeal proceedings and tax litigation support
• Tax withholding advisory
• Review of tax status and evaluation of tax exposures
• Approval of retirement benefit funds from taxation authorities and other related matters thereto.

6) Due Diligence

• Audit of special purpose accounts with a tax perspective
• Ascertaining the tax liabilities (if any) that affect the financial performance of the entity, once the investment or disinvestment has been concluded

7) Tax operataion advisory service

Tax Operations Advisory Services provide the thought leadership, knowledge, and process methodologies needed to enhance the value of corporate tax function.

• Produce a tax strategy that is aligned with company’s business strategy.
• Produce a tax strategy that is aligned with company’s business strategy.
• Design tax savings measurement for our clients.
• Increase company’s return on investment from the tax function.
• Develop manual and / or automated tax processes that reduce costs.

8) Tax valuation service

Valuations often lie at the heart of disputes and negotiations with tax authorities. The specific demands of the tax authorities require specialist advice and detailed knowledge of their working methods and practices.

• A change in corporate structure, a disposal of assets or a new shareholding arrangements are just some of the issues that can impact business values and create tax liabilities.
• To maximize the possible tax benefits from a transaction, the tax aspects need to be integrated at the time that the transaction is being structured.
• In the event of a dispute with the tax authorities based on valuation, the appropriate documentation processes are essential for a swift and successful resolution.
• Share schemes and other forms of employee incentive programs need to be valued in accordance with specific legislation and regulations.
• Complex assets such as goodwill, know-how and other intangibles have to be valued for tax purposes.
• Unlisted businesses face specific challenge when negotiating and agreeing values with the tax authorities.

9) Regulatory

The Pakistan economy is one of the fastest growing in the world. Its burgeoning consumer class provides businesses with a huge market. Pakistan can also be an ideal launch-pad for the Asian market as well. Investors in Pakistan have to set up and manage their businesses to benefit from this opportunity while complying with the gamut of local laws and regulations impacting their investments. MMR & Co with organizations/corporations in seamlessly navigating through the regulatory framework and concurrently supporting their business initiatives.

• Structuring and implementing inbound and outbound investments
• Exchange control, corporate laws and foreign investment advisory
• Inbound Capital Flow Consulting, which would include advising on inbound ownership structures
• Entity structuring including advises on the choice of entry vehicle such as a strategic alliance partner, branch, subsidiary, joint venture etc.
• Processing regulatory approvals including Board of Investment, State Bank of Pakistan and other organizations.
• Multinational businesses are increasingly affected by tax, legislative and regulatory developments throughout the world. Understanding the impact of these developments on business operations and transactions between countries is vital for a company’s success. 
• We have experience in addressing these developments as well as all aspects of international taxation with the help of our network firms. Our teams are able to help you structure your business in a tax-efficient manner, both locally and globally.
• You need advice on tax when structuring a group of companies
• You need to repatriate profit
• You want to understand double tax relief planning
• You are planning cross-border acquisitions, disposals or reorganizations
• You have to defend tax authorities challenge regarding thin capitalization
• You are a local organization looking to expand overseas

How MMR & Co can help

• With effective and tax efficient cross-border strategies for both local and overseas investments
• By managing your global structural tax rate
• By keeping you abreast of new developments within the international arena that affect your business.
• Outbound structuring services
• Controlled foreign companies planning
• Country specific planning services
• Thin capitalization solutions
• Inbound structuring into Pakistan
• Pathfinder service – start up services for companies entering Pakistan

10) Corporate tax compliance and outsourcing

Managing tax compliance has become an increasingly complex issue with constantly changing assurance, regulatory and tax compliance requirements. These have led to a trend for companies to rethink how they meet their obligations to file timely and accurate tax returns. MMR & Co. can take care of your corporate tax compliance work allowing you to focus on your core business. We prepare tax returns and computations quickly and accurately and streamline the collection of data.

• You don’t have, or want to free up, an in-house tax resource
• You are concerned by escalating or uncertain costs
• You want to control your tax compliance issues, risks and opportunities
• You need to comply with the growing, and more visible tax burden
• You require greater flexibility than your current provider can offer

How MMR & Co can help

• Consistent application of best practice
• Better use of scarce, in-house resources
• A more responsive service within agreed timescales
• Economies of scale
• Better communications through continuity of staffing
• High technical quality.

11) tax accounting services

As a result of increasingly challenging financial reporting environment, which has been caused by complex accounting standards and the demand for greater transparency, it is proving even more difficult to prepare complete tax accounting calculations in accordance with the requirements and expectations of the regulators and financial markets. We can offer a comprehensive approach to help our client address these pressures and gain comfort that their tax reporting obligations have been met.

How MMR & Co can help

Tax provisioning and reporting. Technical tax accounting knowledge applied to transactions and other business issues.

Tax accounting consulting. Technical tax accounting knowledge applied to transactions and other business issues.

12) Personal taxation

The constantly changing tax legislations and complex domicile status issues have made it essential for high net worth individuals, owner-managers of businesses, corporate directors and executives to seek expert personal tax advice.

• You want to minimize your Income Tax liabilities
• You are a family business and seek bespoke advice on issues ranging from governance through to re-organization and tax planning
• You wish to know about efficient cross border planning strategies

How MMR & Co can help

• Identifying and advising on the tax planning opportunities available to minimize the tax burden based on the prevalent acceptable practices
• Drafting and reviewing of employment agreements
• Computation of tax liability to be withheld from monthly salaries, preparation and filing of monthly/annual statements
• Filing of tax returns, certificates etc
• Tax equalization workings

Indirect Tax

MMR & Co. Indirect Tax Practice is your business partner in addressing fiscal challenges through the core value proposition of the strategic management of indirect taxes. We offer comprehensive advice and assistance in all areas of indirect taxes from Customs to Federal Excise. All this is backed by litigation support at every appellate stage.

Sales Tax is a tax on value addition and a multi point tax, which is levied at every stage of sale. Sales Tax is not just a taxation issue; it spans the entire value addition process. It is collected at the stage of manufacture/resale and contemplates rebating of tax paid on inputs and purchases. It provides a broad tax base and more and more businesses will come in its net. Federal Excise Duty is a levy on manufacturing sector as well as on services sector. Customs Duty is levied on items imported into Pakistan, various items are exempted from Customs Duty, and at the same time some are levied at higher and lower rates, thus it requires expert advice

• You need to maximize indirect tax recovery.
• You want to increase margins.
• You want to ensure your group maximizes efficiencies for indirect taxes.
• You want to improve cash flow.
• Your organization has a high level of customs or excise duty and you want to ensure you don’t overpay.

How MMR & Co can help

• Advice on classification, valuation, applicability of taxes on transactions and admissibility to tax benefits/exemptions
• Opinions on indirect tax issues
• Identification of innovative tax planning opportunities
• Formulating indirect tax efficient business models
• Undertaking comprehensive reviews of business operations
• Carrying out health checks aimed at providing assurance in tax compliance
• Conducting indirect tax specific due diligence reviews (buy side/sell side)
• Indirect tax compliance support/outsourcing
• Preparations of customized compliance manuals on all indirect taxes
• Centralized coordination for tax payments, filing of returns & compilation of documents
• Drafting appeals & submissions
• Appearances & arguments before adjudication & appellate authorities
• Briefing Legal Counsel on need basis
• Representation before relevant Government authorities on tax & trade policy issues

1) Transfer Pricing

The explosive growth in world trade in recent years, and the resulting increase in cross-border transactions between related parties, has catapulted transfer pricing to the forefront of important international tax issues. MNCs of all sizes are finding their transfer pricing practices under increased scrutiny by tax authorities. Extensive transfer pricing regulations for Pakistan are in place according to which an arm’s length standard is applied on transactions between associates.

Transfer pricing has become the most difficult area of international taxation. We advise multinational companies on the most appropriate transfer pricing policy to be followed in accordance with the Income Tax Ordinance, 2001 and Income Tax Rules, 2002.

Our approach is marked by innovation and the resulting policy is one that is the most practical. It focuses on prices charged for related – party transactions, including inter – company transfer of tangible goods, intangible property services, loans and leases. It affects nearly every aspect of multinational operations – R&D manufacturing, marketing and distribution, after-sale services, and of course, an organization’s worldwide tax burden.

• You need help and guidance with documentation
• The taxation authorities are investigating your approach to transfer pricing
• You want to coordinate your worldwide transfer pricing policies
• You are looking for coordinated transfer planning advice

How MMR & Co can help

• Detailed functional analysis of selected entities and related industry analysis
• Comparable and benchmarking analysis exercises
• Representation before tax authorities for transfer pricing audit defense
• Management of international transfer pricing projects from Pakistan perspective