The international tax landscape has undergone significant reform in recent years and is under the spotlight more than ever. From tax authorities to an interested and well-informed public, entities' international tax affairs are scrutinised heavily. It is therefore vital that organisations adopt responsible tax strategies, remain fully compliant, and see tax as part of their overall ESG agenda. However, this can be a challenge—not least for international businesses operating in multiple jurisdictions.
PwC's international tax services team can help you align your global tax strategy with your business model, international footprint and supply chain, allowing for effective management of your worldwide effective tax rate and your global tax compliance obligations.
There are many reasons why companies choose Ireland as a destination for foreign direct investment (FDI). With our competitive corporate tax rate, extensive tax treaty network and competitive intellectual property and research and development regimes (including grants and credits), Ireland provides an attractive tax regime from which to grow and manage your international business. In addition to the country's well-educated workforce, Ireland offers access to the EU marketplace from an English-speaking and eurozone base. Companies can also connect easily to Asia in the morning and North America in the afternoon.
In terms of FDI, Ireland is home to:
Many companies—including an increasing number of social media, e-commerce, business services and online gaming companies—locate in Ireland as a tax-competitive operational hub, from which to expand and manage their international businesses.
Businesses need an organised and coordinated approach to managing global risk for two principal reasons: first, transactions are increasingly global in nature and second, tax authorities are under increasing pressure to generate revenue from international business activities carried out in their jurisdiction.
Conducting business in multiple countries requires the coordination of subsidiaries with diverse accounting practices, legislative environments and local business customs. Companies often outsource their global compliance to avoid risk, conserve resources and allow over-burdened tax departments to focus on higher value-add activities.
PwC Ireland can help your company overcome any global tax challenges your company might face. Providing a single point of contact, the Global Compliance Services team delivers a coordinated and uniform compliance service that leverages its global network of 37,000 tax experts in 157 countries to identify exposures and solutions and keep you up-to-date with relevant international tax updates.
Section 110 is at the heart of Ireland's structured finance regime. It allows organisations to achieve a neutral tax position provided certain conditions are met.
A Section 110 company is an Irish-resident special purpose vehicle (SPV) that holds and/or manages qualifying assets. This facility is often used as an onshore investment platform in an environment where there is an increased international focus on tax havens and transparency.
The ability to operate within an onshore regime is attractive to many investors due to the stability of the regime and its cost-efficient nature. This is particularly important in times of economic uncertainty. In addition, a Section 110 company qualifies for the benefits of Ireland's double tax treaty network, which should reduce or eliminate withholding taxes on income flows and capital gains.
Our structured finance team has vast experience in helping companies establish efficient investment structures, and works extensively with our global international tax teams to provide a comprehensive, expert-led service.
The tax transparency agenda has resulted in increased regulatory and reporting requirements that are technically complex. Financial Institutions and service providers operate in an environment that demands rigorous governance and robust compliance solutions in multiple areas, including testing of the quality of customer data and filing automatic exchange of information (AEOI, FATCA and CRS) reports. Understanding the regulatory frameworks and adapting internal processes and controls is imperative.
The breadth and depth of our clients and our active involvement in local and international working groups enables PwC to offer unparalleled insights on FATCA and CRS matters and industry-specific issues, as well as Irish, European and international tax updates relevant to your business.
Our Tax Information Reporting team, which specialises in tax transparency and AEOI, has the experience and technology capabilities to help you manage your FATCA, DAC2 or CRS, DAC 6 and DAC 7 obligations. We can also assist you in documenting your operational compliance and help you create sustainable solutions built on proper governance and internal controls.