BrainBuddy Tax Strategy

BrainBuddy Tax Strategy
Board Advisory
A comprehensive guide to navigating international tax frameworks, BEPS implications, and strategic considerations for sustainable growth in the digital economy.
Chapter 1
Understanding BEPS 2.0
The OECD's Base Erosion and Profit Shifting (BEPS) 2.0 framework introduces fundamental changes to international taxation through two pillars that will reshape how multinational enterprises operate and pay taxes globally.
Pillar 1: Nexus and Profit Allocation
Pillar 1 fundamentally changes where companies pay taxes by establishing new nexus rules that allow market jurisdictions to tax portions of multinational enterprise profits even without physical presence, based on where users and customers are located.
New Nexus Rules
Market jurisdictions can now tax MNE profits based on customer location, not just physical presence.
Revenue Threshold
Applies to MNEs with global turnover exceeding EUR 20 billion and profitability above 10%.
BrainBuddy Status
Currently below threshold but should actively monitor growth trajectory.
Amount A: Profit Reallocation
Amount A represents a significant shift in profit allocation, reallocating 25% of residual profit—defined as profit exceeding 10% of revenue—to market jurisdictions where customers are located. This mechanism ensures that highly profitable digital businesses contribute tax revenue in the markets they serve, regardless of physical presence.
For BrainBuddy, while currently below the threshold, understanding this mechanism is crucial for future strategic planning as the company scales its operations across multiple jurisdictions.
25%
Residual Profit
Portion reallocated to market jurisdictions
10%
Profit Threshold
Minimum profitability trigger
Amount B: Baseline Marketing
Amount B provides a simplified approach for pricing baseline marketing and distribution activities, aiming to reduce transfer pricing disputes and compliance burdens for routine functions. However, its scope remains under development.
Action Required: BrainBuddy should closely monitor Amount B developments as the scope and implementation details continue to evolve at the OECD level.
Chapter 2
Pillar 2: Global Minimum Tax
Pillar 2 introduces the Global Anti-Base Erosion (GloBE) Rules, establishing a global minimum effective tax rate of 15% for large multinational enterprises. This framework aims to eliminate the race to the bottom in corporate taxation and ensure fair tax contributions worldwide.
GloBE Rules Framework
01
Revenue Threshold
Applies to MNEs with consolidated revenue exceeding EUR 750 million annually.
02
Minimum Rate
Establishes 15% global minimum effective tax rate across all jurisdictions.
03
BrainBuddy Position
Company is nearing this threshold and must prepare for compliance requirements.
04
Calculation Method
ETR calculated on a jurisdictional basis using specific GloBE income and tax definitions.
Top-Up Tax Mechanisms
When the effective tax rate in any jurisdiction falls below 15%, a top-up tax is imposed to reach the minimum rate. This is enforced through multiple mechanisms designed to ensure compliance.
Income Inclusion Rule (IIR)
Parent company pays top-up tax on low-taxed income of subsidiaries.
Undertaxed Profits Rule (UTPR)
Backstop mechanism when IIR doesn't apply, allocating top-up tax among group entities.
QDMTT
Allows jurisdictions to collect top-up tax domestically before IIR or UTPR apply.
Qualified Domestic Minimum Top-up Tax
The Qualified Domestic Minimum Top-up Tax (QDMTT) represents a strategic opportunity for jurisdictions to retain tax revenue that would otherwise be collected by foreign tax authorities under IIR or UTPR mechanisms.
By implementing a QDMTT, a country can ensure that any top-up tax owed by entities operating within its borders is collected domestically, maintaining sovereignty over its tax base while complying with Pillar 2 requirements.
Potential Impacts on BrainBuddy
Compliance Burden
Significant increase in tax compliance requirements with extensive data collection, jurisdictional ETR calculations, and detailed reporting obligations across all operating entities.
Effective Tax Rate
Likely increase in actual ETR, potentially nullifying benefits from tax incentives in low-tax jurisdictions and requiring reassessment of location strategies.
Tax Planning Complexity
Group tax planning becomes riskier and requires more sophisticated analysis, with greater scrutiny on structures and increased need for expert advisory support.
Chapter 3
Tax Transparency and ESG
Tax transparency has emerged as a critical component of Environmental, Social, and Governance (ESG) frameworks, reflecting a company's commitment to responsible corporate citizenship and sustainable business practices.
Tax as a Social Responsibility
Tax represents a crucial part of the "Social" component in ESG, demonstrating how companies contribute to the societies in which they operate. Responsible tax practices reflect a commitment to sustainable development and fair contribution to public services.
For BrainBuddy, embracing tax transparency aligns with broader ESG goals and demonstrates leadership in the digital economy, where tax practices face increasing scrutiny from stakeholders.
Why Tax Transparency Matters
Stakeholder Trust
Builds confidence with investors, customers, employees, and governments by demonstrating ethical business practices and commitment to fair tax contributions.
Reputation Enhancement
Strengthens brand value and corporate reputation, differentiating BrainBuddy as a responsible digital platform in an increasingly conscious marketplace.
Risk Mitigation
Reduces exposure to tax disputes, penalties, and reputational damage from aggressive tax planning or lack of transparency.
Talent Attraction
Helps attract and retain top talent who increasingly prioritize working for companies with strong ethical standards and responsible business practices.
Developing a Tax Strategy
A robust tax strategy aligned with ESG principles should emphasize fairness, compliance, and avoidance of aggressive tax planning. This strategy must be clearly articulated and consistently applied across all jurisdictions.
Strategic Alignment
Ensure tax strategy supports business objectives while maintaining ethical standards and ESG commitments.
Fairness Principle
Commit to paying fair share of taxes in jurisdictions where value is created and economic activity occurs.
Compliance Focus
Prioritize full compliance with tax laws and regulations, avoiding aggressive planning schemes.
Tax Governance Framework
1
Board Oversight
Establish clear Board-level responsibility for tax strategy and risk management, with regular reporting and review processes.
2
Management Accountability
Define roles and responsibilities for tax management across the organization, ensuring proper expertise and resources.
3
Risk Assessment
Implement systematic processes for identifying, assessing, and managing tax risks across all jurisdictions and business activities.
4
Internal Controls
Develop robust controls and procedures to ensure accurate tax reporting, compliance, and documentation.
Voluntary Disclosure Approaches
Beyond legal requirements, BrainBuddy should consider voluntary disclosures that demonstrate commitment to transparency and build stakeholder trust. These disclosures require careful consideration of benefits and potential risks.
Public Country-by-Country Reporting
Benefits
Demonstrates transparency commitment
Builds stakeholder confidence
Aligns with emerging regulatory trends
Enhances ESG credentials
Reduces information asymmetry
Risks to Consider
Competitive sensitivity of disclosed information
Potential misinterpretation by stakeholders
Resource requirements for preparation
Need for contextual narrative
Ongoing commitment implications
Recommendation: Carefully weigh benefits against risks, considering phased approach or selective disclosure aligned with regulatory developments.
Additional Disclosure Options
1
Narrative Reporting
Publish clear explanations of tax strategy, governance approach, and decision-making principles in annual reports or dedicated tax transparency reports.
2
ETR Reconciliation
Provide detailed reconciliation of effective tax rate to statutory rates, explaining key drivers of differences across jurisdictions.
3
Tax Contribution Analysis
Report total tax contribution including corporate income tax, employment taxes, and other taxes paid and collected.
Stakeholder Communication
Clear, proactive communication of BrainBuddy's tax approach is essential for building trust and managing expectations across diverse stakeholder groups.
Investors
ESG-focused disclosures and risk management
Customers
Brand values and responsible practices
Employees
Ethical standards and corporate culture
Governments
Compliance commitment and cooperative approach
Communities
Local contribution and social responsibility
Monitoring ESG Standards
The landscape of ESG reporting standards continues to evolve rapidly. BrainBuddy must stay informed about emerging frameworks and requirements to maintain best-in-class transparency practices.
GRI 207
Global Reporting Initiative standard specifically addressing tax transparency and reporting requirements.
SASB Standards
Sustainability Accounting Standards Board frameworks for industry-specific ESG disclosure.
Emerging Frameworks
Monitor developments in ISSB, TCFD, and regional requirements like EU CSRD.
Chapter 4
Transfer Pricing Strategy
Transfer pricing represents a critical area of international tax management, requiring careful attention to ensure compliance with arm's length principles while supporting business objectives across multiple jurisdictions.
IP Holding: Current Structure
BrainBuddy's current intellectual property structure requires careful management to ensure compliance with transfer pricing regulations and alignment with value creation principles.
01
Benchmark Royalty Rates
Establish arm's length royalty rates for IP licensed to Singapore and Indonesia subsidiaries using comparable uncontrolled transactions (CUPs).
02
DEMPE Analysis
Ensure royalty rates align with Development, Enhancement, Maintenance, Protection, and Exploitation (DEMPE) functions performed.
03
Documentation
Maintain comprehensive documentation supporting royalty rate determination and functional analysis.
04
Regular Review
Periodically reassess rates to ensure continued arm's length nature as business evolves.
DEMPE Framework
The DEMPE framework is fundamental to transfer pricing for intangibles, ensuring that profit allocation reflects the location of value-creating activities rather than mere legal ownership.
Development: Where IP is created and developed
Enhancement: Ongoing improvements and upgrades
Maintenance: Preserving IP value and functionality
Protection: Legal and strategic IP protection
Exploitation: Commercial use and monetization
BrainBuddy must ensure royalty arrangements reflect where these functions are actually performed.
Future IP Transfer Considerations
If BrainBuddy considers transferring IP ownership in the future, several critical factors must be addressed to ensure compliance and minimize tax authority challenges.
1
Commercial Justification
Develop robust business rationale beyond tax benefits, demonstrating strategic value of the transfer for operations and growth.
2
Valuation
Obtain independent, defensible valuation using appropriate methods considering IP's unique characteristics and future potential.
3
Tax Authority Engagement
Anticipate and prepare for challenges from Vietnamese tax authorities regarding exit taxation and profit reallocation.
Inter-company Services
Proper characterization and pricing of inter-company services is essential for transfer pricing compliance and avoiding disputes with tax authorities across BrainBuddy's operating jurisdictions.
Service Characterization
Accurately identify and document technical, marketing, and administrative services provided between group entities.
Arm's Length Pricing
Apply appropriate transfer pricing methods such as cost-plus, ensuring services provide genuine benefit to recipients.
Comprehensive Documentation
Maintain thorough records of services rendered, pricing methodology, and supporting rationale.
Service Pricing Methodology
Typical cost-plus markup ranges for different service categories. Actual rates should be benchmarked against comparable transactions and reflect value provided.
Chapter 5
BEPS 1.0 Considerations
The original BEPS Action Plan introduced 15 actions to address tax avoidance strategies. Several actions remain highly relevant for BrainBuddy's international operations and require ongoing attention.
Permanent Establishment Risk
The digital nature of BrainBuddy's business model creates potential permanent establishment (PE) exposure in multiple jurisdictions, particularly through remote activities and online service delivery.
Remote Support Activities
Vietnam-based support teams specializing in core markets could create service PE exposure depending on duration and nature of activities performed.
Software Implementation
Remote software implementation services may trigger PE risk in customer jurisdictions under certain circumstances.
Remote Work Arrangements
Employees consistently working remotely from another country could create fixed place of business or agency PE.
Treaty Abuse Prevention
BEPS Action 6 addresses treaty shopping and abuse through the Principal Purpose Test (PPT) and other anti-avoidance measures. BrainBuddy must ensure all transactions and structures have genuine commercial purpose beyond obtaining treaty benefits.
The PPT requires that obtaining tax benefits was not one of the principal purposes of arrangements or transactions. This subjective test demands careful documentation of business rationale and commercial substance.
50%
Treaties Updated
Approximately half of global tax treaties now include PPT provisions
Transfer Pricing Documentation
BEPS Action 13 introduced a three-tiered documentation approach: Master File, Local File, and Country-by-Country Report. Given BrainBuddy's size and international footprint, robust documentation is essential.
Master File
High-level overview of group's business, transfer pricing policies, and global allocation of income and economic activity.
Local Files
Detailed transfer pricing analysis for each jurisdiction, including functional analysis, comparability analysis, and selection of transfer pricing method.
CbC Report
Jurisdiction-by-jurisdiction reporting of revenue, profit, tax paid, employees, and other indicators of economic activity.
Chapter 6
BEPS 2.0 Implementation
As BrainBuddy approaches the EUR 750 million revenue threshold, proactive preparation for Pillar 2 compliance becomes critical. The company must develop systems and processes to meet these complex requirements.
Pillar 2 Readiness Actions
1
Calculate Jurisdictional ETRs
Develop methodology and systems to calculate effective tax rates on a jurisdictional basis using GloBE income and covered tax definitions.
2
Assess Tax Incentive Impact
Evaluate how current tax incentives in various jurisdictions will be affected by the 15% minimum rate and potential top-up taxes.
3
Model Top-up Tax Liabilities
Create financial models to project potential top-up tax obligations under various scenarios and business configurations.
4
Review Location Strategy
Reassess the strategic rationale for entity locations and operations in light of Pillar 2's impact on effective tax rates.
GloBE Income Calculation
Calculating GloBE income requires adjustments to financial accounting income to arrive at the tax base for Pillar 2 purposes. Understanding these adjustments is crucial for accurate ETR determination.
1
Starting Point
Begin with financial accounting net income before tax from consolidated financial statements.
2
Adjustments
Apply specific GloBE adjustments for items like dividends, equity gains/losses, and certain accruals.
3
Allocation
Allocate adjusted income to each jurisdiction where the group operates.
Substance-Based Income Exclusion
Pillar 2 includes a substance-based income exclusion (SBIE) that allows a portion of income to be excluded from the top-up tax calculation based on tangible assets and payroll in each jurisdiction.
The exclusion equals 5% of the carrying value of tangible assets plus 5% of payroll costs. This incentivizes maintaining real economic substance in operating jurisdictions.
For BrainBuddy, maximizing SBIE requires strategic decisions about where to locate employees, equipment, and other tangible assets, particularly in jurisdictions with lower tax rates.
5%
Tangible Assets
Exclusion rate for asset carrying value
5%
Payroll
Exclusion rate for employee costs
R&D Cost Allocation
Proper allocation of research and development costs across the group is essential for both transfer pricing compliance and Pillar 2 ETR calculations. BrainBuddy should consider formal arrangements to support its allocation methodology.
1
Cost Contribution Arrangement
Consider implementing formal CCA to share R&D costs among entities benefiting from the research.
2
Allocation Keys
Develop appropriate allocation keys based on sales, profits, or other metrics aligned with expected benefits.
3
DEMPE Consistency
Ensure cost allocation methodology aligns with DEMPE functional analysis and value creation.
4
Documentation
Maintain comprehensive documentation of methodology, rationale, and annual true-ups.
Chapter 7
Permanent Establishment Management
Managing PE risk is critical for BrainBuddy's digital business model. The company's remote operations, online service delivery, and distributed workforce create multiple potential PE exposures requiring careful assessment and mitigation.
PE Risk Assessment Framework
01
Activity Mapping
Create detailed inventory of all activities performed in each jurisdiction, including employee locations, customer interactions, and service delivery.
02
Treaty Analysis
Review relevant tax treaty provisions for each jurisdiction pair, analyzing fixed place of business, agency, and service PE definitions.
03
Threshold Monitoring
Track time thresholds for service PE and other activities that could trigger PE status in various jurisdictions.
04
Risk Evaluation
Assess likelihood and impact of PE creation, considering both legal analysis and practical enforcement risk.
Types of PE Risk
Fixed Place of Business
Physical location through which business is wholly or partly carried on, including offices, branches, or even home offices of employees.
Agency PE
Dependent agent habitually exercising authority to conclude contracts on behalf of the enterprise in another jurisdiction.
Service PE
Services performed in a jurisdiction for specified periods, often 183 days in any 12-month period, though thresholds vary by treaty.
Digital PE
Emerging concept where significant digital presence could create PE, though no international consensus exists yet.
Remote Work PE Considerations
The shift to remote work has created new PE challenges. Employees working consistently from home offices in foreign jurisdictions can potentially create PE exposure for their employer.
Risk Factors
Duration of remote work in jurisdiction
Nature of activities performed
Authority to bind the company
Visibility to local tax authorities
Availability of home office space
Mitigation Strategies
Clear remote work policies with duration limits
Restrict contracting authority
Monitor and track employee locations
Consider local entity establishment if needed
Obtain advance rulings where appropriate
Service PE Thresholds
Service PE provisions vary significantly across tax treaties. BrainBuddy must carefully track service activities to avoid inadvertently crossing thresholds.
Example service PE thresholds in key markets. Actual thresholds depend on specific treaty provisions and may have additional conditions.
PE Mitigation Strategies
Remote Work Policies
Implement clear policies limiting duration and scope of remote work in any single jurisdiction. Establish approval processes and tracking systems.
Contract Centralization
Centralize contract conclusion authority to avoid creating agency PE through employees or contractors with binding authority.
Independent Contractors
Use genuinely independent contractors rather than dependent agents, but ensure proper classification to avoid misclassification issues.
Local Establishment
Consider establishing local subsidiaries or branches where scale of operations justifies it or PE risk is unavoidable.
Digital PE Developments
While no international consensus exists on digital PE, several countries are exploring or implementing unilateral measures to tax digital businesses based on significant economic presence without physical presence.
BrainBuddy should monitor developments in key markets, particularly India, which has implemented significant economic presence rules, and EU countries considering similar measures.
The implementation of Pillar 1 may eventually address digital PE concerns, but until then, uncertainty remains regarding how digital activities could create taxable presence.
Chapter 8
IP Transfer to Singapore: Critical Analysis
The proposed transfer of intellectual property to Singapore while maintaining DEMPE functions in Vietnam presents significant challenges and risks that require careful consideration before proceeding.
Fundamental Challenges
Arm's Length Principle Violation
Separating IP ownership from DEMPE functions creates artificial structure difficult to justify under arm's length principle. Independent parties would not typically separate ownership from value creation.
Valuation Complexity
Valuing IP when DEMPE functions remain elsewhere is extremely complex and contentious. Tax authorities will scrutinize whether Singapore entity deserves residual profits.
Commercial Justification
Strong business rationale needed beyond tax benefits. Difficult to demonstrate why IP ownership should move while all development activities remain in Vietnam.
Tax Authority Scrutiny
Both Vietnamese and Singaporean tax authorities will likely challenge this structure, creating significant compliance risks and potential disputes.
1
Vietnamese Challenges
Exit tax on IP transfer, profit reallocation arguments, and potential penalties for aggressive planning.
2
Singapore Review
Anti-avoidance provisions, substance requirements, and potential denial of tax benefits under domestic law.
3
Other Jurisdictions
Market jurisdictions may challenge profit allocation, arguing insufficient value creation in Singapore.
BEPS 2.0 Implications
Under Pillar 2, this structure faces additional challenges. Singapore's low tax rate would likely trigger top-up taxes, potentially eliminating intended tax benefits.
The substance-based income exclusion would be minimal in Singapore due to lack of tangible assets and payroll related to DEMPE functions, resulting in most income being subject to top-up tax.
15%
Minimum Rate
Pillar 2 would likely eliminate Singapore tax advantage
5%
SBIE
Minimal exclusion without Singapore substance
Reputational Risk Assessment
Beyond tax and legal risks, this structure poses significant reputational risks in an era of increased focus on tax transparency and corporate responsibility.
Public Perception
Structure could be perceived as aggressive tax avoidance, damaging BrainBuddy's brand and stakeholder relationships.
ESG Impact
Conflicts with ESG commitments and tax transparency principles, potentially affecting investor relations and access to capital.
Talent Retention
May create challenges attracting and retaining employees who prioritize working for ethically responsible companies.
Recommended Approach
Reconsider the Transfer
Given the substantial risks across multiple dimensions—tax compliance, financial, reputational, and strategic—the most prudent recommendation is to reconsider this IP transfer structure.
Maintain Current Structure
Keep IP in Vietnam where DEMPE functions are performed, ensuring alignment with value creation.
Optimize Within Vietnam
Explore legitimate tax optimization opportunities within Vietnam's framework and available incentives.
Build Substance
If expansion to Singapore is strategically valuable, build genuine operational substance there first.
Alternative: Licensing Structure
If Singapore operations are commercially justified, consider a licensing arrangement rather than IP transfer. This approach maintains IP ownership in Vietnam while allowing Singapore entity to use IP for specific purposes.
Benefits
Maintains IP where DEMPE functions exist
Easier to justify commercially
Lower valuation and exit tax risk
More defensible transfer pricing position
Better alignment with Pillar 2 requirements
Requirements
Arm's length royalty rate determination
Clear commercial purpose for license
Proper documentation and substance
Regular benchmarking and review
Compliance with local regulations
If Transfer Proceeds: Mitigation Requirements
Should BrainBuddy decide to proceed despite the risks, extensive mitigation measures are absolutely essential to minimize exposure and demonstrate good faith compliance efforts.
1
Transfer DEMPE Functions
Move substantial DEMPE functions, personnel, and resources to Singapore to create genuine substance and justify profit allocation.
2
Expert Advisory
Engage top-tier international tax and transfer pricing advisors in both Vietnam and Singapore for structure design and documentation.
3
Robust Valuation
Obtain independent, defensible valuation from recognized experts using multiple methodologies and conservative assumptions.
4
Full Transparency
Prepare for complete transparency with tax authorities, including advance pricing agreements or rulings where possible.
Chapter 9
Digital Services Taxes
Digital Services Taxes (DSTs) represent unilateral measures implemented by various countries to tax revenues of large digital companies. These interim measures create additional compliance complexity for BrainBuddy's B2C platform operations.
DST Overview and Landscape
DSTs are typically levied on revenues rather than profits, targeting digital services where user participation creates value. They're generally seen as temporary measures pending Pillar 1 implementation.
Revenue-Based
Tax calculated on gross revenues from digital services, not profits, creating cash flow and margin pressure.
Threshold-Driven
Apply to companies exceeding global and local revenue thresholds, varying by jurisdiction.
Service-Specific
Target specific digital services like online advertising, marketplaces, and user data monetization.
Interim Nature
Expected to be withdrawn upon Pillar 1 implementation, but timing remains uncertain.
DST Management Framework
01
Inventory Creation
Develop and maintain comprehensive inventory of DSTs in all operating jurisdictions, particularly core markets.
02
Applicability Assessment
Evaluate whether BrainBuddy's B2C freelancer platform activities fall within scope of each DST based on revenue thresholds and service definitions.
03
Compliance Procedures
Establish systems for registration, data collection, tax calculation, payment, and reporting for each applicable DST.
04
Ongoing Monitoring
Track legislative developments, threshold changes, and Pillar 1 progress affecting DST landscape.
Key DST Jurisdictions
Example DST rates and thresholds in selected jurisdictions. BrainBuddy should verify current rates and assess applicability to its specific business model.
Pricing and Profitability Impact
DSTs create strategic pricing decisions for BrainBuddy. The company must determine how to handle this additional cost layer while maintaining competitiveness and profitability.
Absorb Cost
Company bears DST burden, reducing margins but maintaining pricing competitiveness.
Pass to Freelancers
Reduce freelancer payments to offset DST, potentially affecting platform attractiveness.
Increase Prices
Raise customer prices to cover DST, risking competitive position and demand.
Differentiate by Market
Apply different pricing strategies based on DST exposure in each jurisdiction.
Double Taxation Challenges
DSTs create potential double taxation since they're levied on revenues while corporate income tax applies to profits. This layering of taxes can significantly impact effective tax rates and cash flows.
While some jurisdictions allow foreign tax credits for DSTs, limitations often apply. The non-deductibility of DSTs for corporate income tax purposes in many jurisdictions exacerbates the burden.
Note: Track developments in bilateral tax treaties and domestic legislation that may provide relief mechanisms.
Monitoring Pillar 1 Developments
The future of DSTs is closely tied to Pillar 1 implementation. Countries have committed to withdrawing DSTs once Pillar 1 is operational, but timing and transition mechanisms remain under negotiation.
Current State
Multiple DSTs in force creating compliance complexity and cost burden.
Pillar 1 Agreement
International consensus on Amount A and B implementation details.
Transition Period
Gradual phase-out of DSTs as Pillar 1 mechanisms become operational.
Future State
Unified approach under Pillar 1 replacing unilateral DST measures.
Chapter 10
Strategic Recommendations
Based on comprehensive analysis of international tax frameworks, BEPS implications, and BrainBuddy's specific circumstances, the following strategic recommendations provide a roadmap for sustainable tax management.
Immediate Action Items
1
Pillar 2 Preparation
Develop systems and processes for GloBE calculations, ETR monitoring, and top-up tax modeling as revenue approaches EUR 750M threshold.
2
Transfer Pricing Documentation
Strengthen transfer pricing documentation, including Master File preparation and robust local file maintenance across all jurisdictions.
3
PE Risk Management
Implement comprehensive PE risk management framework including activity mapping, remote work policies, and monitoring systems.
4
DST Compliance
Establish DST compliance procedures for applicable jurisdictions and assess pricing strategy implications.
5
Tax Transparency
Develop tax transparency strategy aligned with ESG commitments, including governance framework and disclosure approach.
6
IP Structure Review
Reconsider Singapore IP transfer proposal and maintain current structure aligned with DEMPE functions in Vietnam.
Building a Sustainable Tax Future
BrainBuddy stands at a critical juncture in its international tax journey. The evolving global tax landscape presents both challenges and opportunities for companies committed to responsible growth.
By proactively addressing BEPS 2.0 requirements, strengthening tax governance, embracing transparency, and maintaining alignment between tax structures and genuine business substance, BrainBuddy can build a sustainable tax framework that supports long-term success.
The recommendations outlined in this presentation provide a foundation for navigating complexity while maintaining stakeholder trust and competitive advantage in the digital economy.
60+
Countries
Implementing BEPS measures
15%
Minimum Rate
Global standard reshaping tax planning
100%
Commitment
To responsible tax practices