There is an increasing public discussion on tax transparency and taxation of profits based on where value is created. This has led to the introduction of various legislative and regulatory measures on a global, regional and local level. Furthermore, tax audits are increasingly digitized and focused on data analytics. How will you prepare for discussions with local tax authorities on your company’s tax positions in this changing environment?
Tax authorities worldwide are taking additional steps to assess alignment between the business models of companies and their tax models in place. Examples include the OECD BEPS Actions, increased compliance demands (i.e. Country-by-Country Reporting and Master/Local File), and increased focus on transfer pricing in tax audits. Companies need to develop coordinated approaches to audits and disputes around the globe, and adopt preventative measures (such as pre-filing rulings and enhanced relationships with certain revenue authorities). PwC assists companies in (the preparation of) interactions with tax authorities – from advance certainty, tax audit prevention and preparation, through to communications and dispute resolutions if needed.
Develop tax dispute prevention techniques.
Achieve up-front certainty on transfer pricing by way of Advance Pricing Agreements (unilateral, bilateral or multilateral).
Communicate with tax authorities under Horizontal Monitoring Framework arrangements.
Develop tax audit management practices / strategies.
Prevent double taxation in case of any unilateral tax adjustments.
Audit readiness assessments including digital audit assessments.
Mock audits: is the required information available and what does it show?
Manage and respond to investigations, audits, and examinations initiated by revenue authorities worldwide.
Implement outcomes of discussions with tax authorities for end-to-end transfer pricing.
PwC has extensive experience in communications with the tax authorities to efficiently and effectively deal with all matters, and to advise your company on the most suitable approach.