Previously, all the operating companies had been held by one single holding company. The idea was that each regional holding company would have its own management team who would be free to manage and develop business in their region, assessing and rewarding staff on the basis of performance in their particular operating company.
Our job was to analyse the various possible holding structures to achieve this global objective, identifying a structure for each region that would not trigger adverse tax consequences. For each new regional holding company, we were also asked to:
- draft a tax-efficient action plan.
- set up the structure identified as the most efficient, liaising as necessary with the tax authorities to achieve the required tax clearance. This involved coordinating the lawyers, international teams etc. and reviewing all the documents relating to the new structure.
- monitor the structure on an ongoing basis.
Didier-Marie, a member of the International Corporate Tax department, is the most junior member of the project team. His job is to ascertain the tax consequences of setting up each new regional holding company, analysing all documents from this angle and writing up his findings. This means working closely with Antoine, the project manager and Pierre, the partner in charge of the project. The three often meet internally to discuss how the project is going, particularly before conference calls with the client or other KPMG firms' teams involved in the project.
"The project is a real opportunity for me to work with people who have a lot of experience in international tax," says Didier-Marie. "This is something that I particularly enjoy about working for KPMG. The managers and partners are really accessible and there is a real team approach to every project."
Antoine is the manager on this project. His role involves supervising Didier-Marie, setting priorities with him and monitoring the project on a day to day basis. He makes sure that correspondence with the client, lawyers and KPMG colleagues is properly dealt with and that deadlines are met. He also anticipates potential issues in implementing the new structures.
Pierre, the partner in charge, supervises all the work performed by the team to make sure it meets client expectations. He also reviews any tax advice and takes any important decisions relating to the client relationship or risky technical issues. His role is to manage our firms' global relationship with the client on an ongoing basis to ensure complete client satisfaction.
We have already implemented a new holding structure for the Asia-Pacific operations and are currently working on the new structure for the American operations.
Our ability to work on a global level like this, with several KPMG member firms working together, is highly appreciated by the client. We have built a strong relationship with them and hope to enhance this still further as we continue with the restructuring.