International tax planning

What EY International taxation services can do for you

Our international tax professionals provide leading-edge tax consultancy services for many of the world’s largest multinational companies. Our team works to deliver tangible benefits to our clients, thereby contributing to their competitive advantage.

Our global network of international tax professionals work to promote local appoaches that tie in with and contribute to the client’s optimized overall tax position. Our market-leading global tax desk network — which consists of co-located teams of highly experienced professionals from multiple countries in several locations around the world — plays an important role in bringing together tax know-how from various jurisdictions for the benefit of the client.

Global treasury and capital structure

Treasury and tax departments of multinationals face increasing challenges to manage business and market risks effectively and apply funding efficiently. They also face increasing legislative activity and scrutiny of funding activities by tax authorities around the world. In addition, the current volatility in the global markets creates further challenges and stresses for businesses in ways that reduce cash and increase effective tax rates.

Our global treasury group consists of a network of tax professionals in key markets globally who focus on treasury and investment issues from financing and capital restructuring to risk management, whether that be with respect to interest rates, commodities or foreign currency. Our people bring tax efficiency to treasury goals, whether companies are financing their domestic or cross-border activities, hedging their risks with derivatives, structuring investment vehicles, trading securities or commodities, or managing or repatriating cash.

Business models and supply chain

The implementation of the outcomes of the Base Erosion and Profit Shifting (BEPS) project by the OECD is significantly affecting the supply chains of businesses around the world. Our operating model effectiveness (OME) team features the combined experience of Advisory, Assurance, Legal and Tax professionals who focus on supporting clients with business model efficiency, including adjustments to procurement operations, intangible management, permanent establishment risks assessment and risk mitigation.

Corporate structure and treaty qualification

There is increasing attention on the appropriate use of legal entities, both from tax authorities and business (for purposes of operational savings). Our professionals assist with tax efficiently, meeting these business and regulatory needs for legal entity rationalization. We also take into account the requirements under the multilateral instrument (MLI), such as the principal purpose test and other anti-avoidance measures, local country legislation and regulations such as withholding and capital gains taxes — while mitigating the impact on tax attributes in the different jurisdictions.

Tax operations focusing on cross border

The last few years have seen an ever increasing demand on tax departments to report on cross-border situations and transactions. Examples of this are many, such as master and local files in transfer pricing, country-by-country reporting, controlled foreign company reporting under EU Anti-Tax Avoidance Directives, global intangible low-taxed income in the United States and the Mandatory Disclosure Regime in the EU.

EY international tax service teams help you fully comply with these requirements and analyze and remediate the impact that these reporting obligations have on your global tax footprint.