Strategic Solutions in International Taxation
The internationalization of operations requires increasingly strategic, technical tax management aligned with global standards. MCS Markup offers comprehensive solutions, supporting companies in regulatory compliance, tax optimization, and risk mitigation in international operations, with a focus on:
Transfer Pricing
TBU — Taxation of Profits Abroad
Pillar 2
BCR/DPP — Country-by-Country Reporting;
International Restructuring
Transfer Pricing
We support companies in the analysis, calculation, and documentation of Transfer Pricing, ensuring compliance with Brazilian legislation and alignment with international guidelines. With an experienced team and clear, secure processes, we perform:
· Mapping of eligible transactions;
· Analysis of applicable methodologies;
· Identification of comparable transactions in specialized databases, ensuring the application of the most appropriate methodology;
· Calculation of Transfer Pricing amounts;
· Updating of existing studies;
· Tax impact simulations using different methodologies, such as PIC and MLT;
· Evaluation of tax scenarios throughout the assessment period;
· Restructuring of international operations, seeking tax efficiency and reduction of tax risks.
We also provide support in preparing the specific records in the ECF (X360–X375), assistance with the preparation of the Local File and Master File, as well as technical review of calculations and ancillary obligations.
TBU — Taxation of Profits Abroad
MCS Markup supports companies in understanding and applying Brazilian rules, ensuring compliance and appropriate tax planning.
Our work includes:
• Mapping of foreign subsidiaries;
• Tax impact simulations with and without the adoption of the consolidation regime;
• Tax consolidation of the results of foreign entities;
• Calculation of the addition to taxable income;
• Reduction of tax payable;
• Use of deemed tax credits, when applicable;
• Restructuring of international operations aimed at greater tax efficiency and risk mitigation.
We also prepare the relevant records in the ECF, including blocks related to profits abroad (X340–X357), CBCR (W100–W300), and LALUR Part A/B (M300, M350, M410, M500).
Pillar 2 — Global Minimum Taxation
The new OECD global minimum taxation rule, Pillar 2, creates significant challenges for multinational groups.
MCS Markup supports companies with:
· Assessment of exposure to Top-up Tax;
· Analysis of the effective tax rate by jurisdiction;
· Calculation of the Safe Harbor, when applicable;
· Structuring of the QDMTT;
· Identification of the accounting and tax adjustments required under the
GloBE rules;
· Preparation for the GloBE Information Return and other ancillary obligations;
· Simulations of corporate reorganizations;
· Assessment of preferential tax regimes, enabling companies to anticipate the impacts of global minimum taxation.
CBCR/DPP (Country-by-Country Reporting)
Country-by-Country Reporting (DPP) is an increasingly important obligation for multinational groups, requiring full tax transparency regarding their global operations. MCS Markup supports companies in complying with these regulatory requirements, ensuring compliance with Brazilian legislation and alignment with the international guidelines of the OECD.
Our work includes:
· Mapping of the multinational group structure and identification of reportable entities;
· Detailed collection of revenues, profits, assets, and number of employees by jurisdiction;
· Analysis of the applicability of CBCR rules according to global revenue thresholds;
· Validation of financial and operational data for reporting purposes;
· Preparation and technical review of the Country-by-Country Report;
· Integration with related records in the ECF and ancillary obligations;
· Support in communications with the Brazilian Federal Revenue Service and other tax authorities;
· Scenario analysis and impact simulations of restructurings on future reporting.
We manage delivery schedules, ensuring compliance with the deadlines established by Brazilian and international tax authorities.
International Restructuring
International restructurings are critical operations and therefore require detailed strategic planning, combining technical analysis, regulatory compliance, and tax optimization. MCS Markup offers comprehensive support throughout this process, helping companies execute structured, efficient, and secure transactions.
Our work includes:
· Diagnosis of the current international structure, identifying opportunities for tax and operational efficiency;
· Mapping of tax exposures and risks related to the existing structure;
· Design of alternative restructuring scenarios, with tax impact simulations;
· Analysis of the effective tax rate and exposure to regimes such as Pillar 2 under different structures;
· Evaluation of Transfer Pricing in pre- and post-restructuring contexts;
· Planning of integration with obligations such as TBU, Pillar 2, CBCR/DPP, and Transfer Pricing;
· Support in the legal structuring of transactions, including incorporations, mergers, and reorganizations;
· Calculation of tax impacts, including foreign exchange effects and global minimum tax effects;
· Preparation of technical documentation and tax records related to the restructuring;
· Post-implementation analysis, compliance monitoring, and necessary adjustments.
We address restructurings in various formats: concentration of activities, expansion into new markets, centralization of operations, rationalization of complex structures, and transitions between tax regimes. Each project is customized according to the complexity and specific objectives of each client.
Rely on Specialists in International Taxation
MCS Markup combines technical knowledge, practical experience, and strategic vision to support companies operating globally. Our integrated approach ensures regulatory compliance, tax efficiency, and security in international operations.
Contact our specialists and discover how we can support your company’s global tax management.
Sócios Especialistas
