Antravia Research – Tax Architecture in Travel: VAT, Transfer Pricing, and the Exposure of Global Business Models

This white paper by Antravia (https://antravia.com/ )examines how VAT, transfer pricing, and permanent establishment risk shape profitability, compliance, and global scalability in the travel industry.

Drawing on structural analysis from OTAs, DMCs, hotel groups, and tax authorities, the paper presents a dual-perspective view:

For globally operating travel sellers: how indirect tax exposure, non-resident registration, and U.S. withholding rules create financial friction in cross-border bookings.

For destination-side suppliers and DMCs: how misclassification, bundling, and incorrect assumptions around VAT, TOMS, or agency status expose businesses to unplanned liabilities and blocked margin recovery.

The paper covers indirect tax risk, tour packaging frameworks, digital platform obligations, intercompany pricing models, permanent establishment thresholds, and jurisdictional tax architecture. It includes anonymised case studies and real-world rulings, written for senior finance, legal, and operational leaders in travel.

Key Themes

• VAT exposure in travel: non-resident registration, reclaim traps, and margin dilution

• TOMS, bundling, and the EU Package Directive — and why structure matters more than form

• Transfer pricing across OTAs, hotel brands, and contracting offices

• Digital platform taxation and OECD Pillar One

• Permanent Establishment risk from contracting, local teams, or dependent agents

• Strategic frameworks for aligning tax architecture with global business models

   

Who it’s for: Travel executives, legal teams, finance leads, and multi-jurisdictional operators designing scalable tax structures in a cross-border, high-scrutiny environment.

Published by Antravia Advisory – more resources at https://antravia.com/antravia-research