International Tax Services

Bringing trust and confidence through a globally connected community of solvers

The international tax atmosphere is in constant change, with increasing taxes, regulations, compliance and disputes. Our objective is to be by your side, wherever you operate, to help your organisation understand, comply and manage these global tax affairs, while achieving your strategic business goals.

From complexity to clarity

If you are an organisation doing business across borders, we can help you manage the complexity of tax.

How your company needs to approach tax is impacted not only by your business but also the current global geopolitical situation, the macroeconomic environment and the active international tax atmosphere. Legislation and tax rules are in constant change, followed by new taxes and compliance requirements, and an increase in tax controversy and disputes. Furthermore, the OECD Pillar Two is an unprecedented and evolving change to the global tax system that transcends physical borders and will challenge multinationals' ability to source data, comply and plan.

Your teams are likely to be working across borders more than ever, with the added complexity that brings. Our International Tax Services teams are here to help you navigate and manage your complex tax issues. We are a large but tightly connected community of solvers with worldwide presence. Together we can help you overcome cross-border tax challenges and identify opportunities to achieve your business goals. We can help you define and model the right tax strategies and operational structures to stay competitive and support your global footprint. And with our combination of people, processes and technology we can help you assess, report and comply with the OECD Pillar Two.

Explore our Services

Pillar Two

The OECD Pillar Two is an unprecedented and evolving change to the global tax system that transcends physical borders and will challenge multinationals' ability to source data, comply and plan.

With our combination of people from different networks, processes and technology we can help you get #PillarTwoReady. PwC international tax practitioners can assist you with the following tasks, among others:

  • Impact assessment and modelling of the Pillar Two rules in your organisation
  • Technical guidance on how Pillar Two may impact your group in general, and also the implications on proposed deals or intra group reorganisations
  • Status update on country implementations of the Pillar Two rules
  • Upskilling your teams and facilitating discussions with other relevant stakeholders within your organisation that may be impacted by Pillar Two.
  • Pillar Two reporting and compliance

We have developed PwC’s Pillar Two Engine, a technological tool to address the impact of the OECD Pillar Two. With this tool, we will assist you with the overall impact of Pillar Two, not only modelling the impacts but an end-to-end analysis, including calculations of the tax liability with both provision and compliance grade outputs.

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Additionally, PwC’s Data Input Catalog is at the centre of PwC’s end-to-end process for Pillar Two. The Data Input Catalog defines the data requirements for Pillar Two, giving MNEs a comprehensive understanding of the amount of work that lies ahead of them and can help MNEs anticipate the unique challenges they will face. Acting as the foundation to develop an extensive data strategy, assess operational preparedness, or determine a modelling approach, PwC’s Data Input Catalog is the core to Pillar Two readiness.

Cross-border transactions and structuring

In a highly globalised world, multinational companies are constantly involved in cross-border projects, from sale of goods or supply of services, to tax structuring projects to achieve a competitive effective tax rate, streamline cash and financing needs, or prepare for an M&A transaction with third parties.

Our outbound and inbound tax experts can help you with managing the direct tax implications derived from these cross-border projects, including:

  • Application of international tax rules and double tax treaties as well as staying up to date with international tax changes (e.g., EU ATAD, EU DAC or the OECD MLI) and how they can impact your structure and operations
  • Design and implement business-driven and tax efficient structures to achieve a sustainable and competitive global tax position, or invest or divest in different territories (either organically or inorganically), including pre-deal structures
  • Post-deal integrations: analyse how to integrate a recently-acquired business or group of companies with your existing organisation, as well as realise valuable deal synergies and increase tax strategies, without losing value and control
  • Develop and execute tax strategies and improve tax opportunities, whilst complying with diversified tax regulations and requirements.

International tax quantitative solutions

Tax legislations and regulations are constantly changing around the world, with new reporting and compliance obligations. Duly responding on time to these changes and new requirements is complex. Sophisticated tax functions today are using data-driven approaches to think ahead and act on robust, trusted data.

With our combination of people, process and technology we deliver tax and data analysis services tailored to meet your specific reporting, compliance and planning needs utilising deep expertise in data, technology and tax technical computations. Also, we can help you adopt best-practice modelling by taking your tax data and running it through tools that model the impacts of existing and potential tax structures on your global tax profile.


Multinational companies are focusing on transformation projects to adapt to the global geopolitical situation and macroeconomic environment. Companies are facing disrupted cross-border supply chains, workers spread around the world and operations spanning multiple jurisdictions and are currently re-evaluating their value chain to keep a competitive advantage.

PwC brings together multidisciplinary functional knowledge that shape the way our clients create new value, reduce costs and increase growth. We help you to develop and implement an effective, sustainable and seamless value and supply chain management process by considering and bringing all operational, legal and tax aspects together. We assist multinationals to unlock savings and multiply the tax value creation, with the key aim of greater profitability and sustainable growth.

Global Research and Development Tax Credits and Government Incentives

Our global network of government incentives and R&D experts assists large corporations develop optimal strategies to benefit from relevant incentives programs available for future investments, including innovation, research and ESG.

Government Incentives
PwC’s geolocalisation technologies and large scale incentives databases can match existing government incentives with multinationals’ assets, infrastructure and workforce around the world. We can perform deep analysis and manage the complexity of large organisations with these advanced program matching tools, leveraging different incentives (e.g., grants, subsidies, contributions, soft loans, tax credits, tax holidays and vouchers) available at the federal, state, provincial and municipal levels.

A technology-led, phased-approach in providing assistance is recommended, as outlined below:

  • Identification - we identify and prioritise potential incentives that may apply to your project. This is done through an analysis of your priority projects and a deep understanding of your key challenges.
  • Submission - we assist to set up and compile the necessary information, oversee and support the process of preparing the applications for the selected programs.
  • Government relations - we support you in developing and managing relationships with relevant government bodies that administer the identified programs and assist in responding to queries and in discussions with officials about funding incentives.
  • Compliance - we assist with responding to the prescribed reporting requirements, if any, for the awarded funding incentives.

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R&D credits
Our worldwide network of R&D experts can support global research and development activities. We are ready to help you efficiently manage your investments in innovation. We can help you shape your global R&D strategy and where you spend your R&D budgets, based on efficient ownership of IP and jurisdictional relief. We understand the global R&D tax credits and incentives that are available to you and can help you consider the effect of factors such as transfer pricing or lP incentives.

We can assist you to:

  • Identify the research activities that are eligible for the different programs in each country and region.
  • Analyse detailed accounting records to identify costs that qualify for jurisdictional relief
  • Gather, organise and develop documentation to support and defend eligible costs if tax authorities initiate an enquiry
  • Improve your internal procedures and tracking systems in order to improve identification and documentation of eligible expenditures.
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Doug McHoney

Doug McHoney

International Tax Services Global Leader, Partner, PwC United States