Substance and permanent establishment 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

A post office box in a foreign country is no longer sufficient to claim residency abroad. 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 substance in countries where you operate.

You need senior management and business operations on location. Insufficient substance can lead to double taxation and challenges by multiple tax authorities.



How we can help

Our PwC tax specialists will perform a comprehensive substance-level assessment of your foreign operations. We’ll 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’ll advise your leadership team on the sustainability of your corporate structure and operational models from a substance perspective. These measures can help reduce your risk of successful substance challenges by Belgian and/or foreign tax authorities and limit withholding tax challenges arising from queries about beneficial ownership.

Flags waving outside of PwC Brussels office

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 and permanent establishment exposure worldwide.

Our dedicated tax specialists will guide you through these development and implementation of through end-to-end substance strategy.