Substance and governance review
To qualify as a tax resident company and avoid potential double taxation, your organisation must have and maintain sufficient substance in the countries where you do business.
Substance is key to a sustainable tax strategy
Cross-border tax initiatives like the OECD’s base erosion and profit shifting (BEPS) framework and various EU initiatives mean your organisation must demonstrate adequate and minimum substance in countries where you operate.
You need strategic management decisions and business operations on location. Insufficient substance may lead to double taxation and challenges by multiple foreign tax authorities.
How we can help
Our PwC tax specialists will perform a comprehensive substance-level assessment of your foreign operations. We will deliver a report that highlights any red flags and make recommendations for improvement, including substance guidelines and manuals (e.g. overview of preferred management processes) tailored to your organisation’s unique situation.
We will advise your leadership team on the sustainability of your corporate structure and operational models from a substance perspective. These measures can help to reduce your risk of successful substance challenges by foreign tax authorities and limit withholding tax challenges arising from queries about beneficial ownership.
Why PwC?
As one of the first organisations to publish information on substance, PwC's been ahead of the curve from the beginning. We collaborate with our extensive global network to keep on top of the latest developments in residency exposure worldwide.
Our dedicated tax specialists will guide you through these developments and implementation of through end-to-end substance strategy.
