Elevating your global tax strategy.
International tax services
Your international tax challenges
As the global economic and geopolitical situation becomes more complex, it becomes increasingly vital for businesses to have a cross-border view of their tax position and the elements that influence it, including changes to supply chains and organisational structure. This requires businesses to closely monitor shifting tax regulations, evolving business models, tighter credit constraints, and rising scrutiny around tax practices in order to fully understand the global tax implications of their decisions.
How PwC can help
We are proactive, discussing potential international tax legislation changes with clients, helping them to navigate the global and local effects of regulatory changes. This enables them to act decisively on cross-border investments, manage their restructuring and divestitures, respond to foreign tax authorities, address their global tax rate, and develop a sustainable tax strategy.
As part of the global PwC Network, we understand that an organisation’s tax position isn’t isolated from the rest of its business. That’s why we share our broader perspective with our clients, bringing deep country-specific tax and business knowledge to the table, as well as our expertise on digital, HR, IT, legal, and tax professional services.
What we can offer
- Substances and permanent establishment review
- Pillar Two
- Cash repatriation and optimisation
- Documentation for audits
Substances and permanent establishment review
Operating across borders brings opportunity – but also increasing scrutiny. Tax authorities worldwide are tightening rules around corporate substance, making it harder for organisations to justify where they’re a tax resident. Structures that once worked, such as minimal local presence, now risk triggering double taxation, penalties, or disputes. Many businesses struggle to keep pace with evolving requirements such as the OECD’s base erosion and profit shifting (BEPS) framework and EU directives. Our substance and permanent establishment review helps organisations assess their current position, identify risks, and implement practical, compliant solutions that strengthen their tax strategy and provide long-term certainty.
Pillar Two
Understanding the implications of Pillar Two is proving difficult for many organisations, particularly when it comes to impact modelling and the cautious use of safe harbour provisions. Concerns about how tax authorities may interpret these positions often slow decision-making and create uncertainty across the organisation. Our expert team helps cut through this complexity. They provide clear modelling insights, balanced perspectives on safe harbour use, and hands-on guidance – linking global strategy with local expertise to help clients navigate risk and take informed steps towards compliance readiness.
Cash repatriation and optimisation
For many organisations, cash repatriation is no longer a routine exercise, but a delicate balancing act. Shareholder expectations – particularly for listed companies – create pressure to distribute dividends, while inefficient structures can turn repatriation into a costly and complex process. Navigating these competing demands often leaves organisations unsure how to proceed without eroding value. Our multidisciplinary team understands these challenges. By combining deep international tax and transfer pricing expertise, we help design efficient repatriation strategies, align global structures, and support clients in meeting shareholder expectations while preserving cash and minimising risk.
Documentation for audits
When faced with tax authorities or auditors, documentation is often the first – and most critical – line of defence. Yet many organisations struggle to maintain clear, consistent records that reflect both transfer pricing policies and international tax structures. This disconnect can create unnecessary risk. Our team of experts brings these elements together. We support clients in developing thorough, well-aligned documentation that stands up to scrutiny, reduces uncertainty, and ensures businesses are always prepared – turning audit readiness from a reactive exercise into a position of strength.
The team that will support you
Cedric De Croock
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