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International taxation and tax structuring



A specialised team of PwC experts will answer questions related to international transactions, propose a tax optimal business structure, or recommend a change of existing structure to allow you to decrease tax costs and, thereby, increase profit.

  • Are you a foreign company planning to invest in the Czech Republic?
  • Are you a Czech company that is planning to expand abroad?
  • Are you interested in knowing whether your company could make use of holding or financial structures with international elements to optimise group tax burdens?
  • Does your company make payments abroad in the form of dividends, interest, or service fees?
  • Do you cooperate with foreign partners in the Czech Republic?


Typical projects

Transactions with an international element

  • Advisory on international invoicing of goods and services, including advisory on application of withholding tax
  • Creation and taxation of permanent establishments in the Czech Republic and abroad
  • Analysis of agreements from the perspective of tax optimisation, including assessment of tax-deductibility of fees for managerial services

Design of holding or financial structures

  • Design of optimal tax strategy for doing business in the Czech Republic or abroad
  • Design and implementation of tax effective holding and financial structures
  • Design of structures while making use of tax heavens

Optimisation of existing structures

  • Review of existing strategies and business structures and recommendation for their modification leading to tax savings
  • Proposal for a structure for change of ownership of intangible assets (such as trademarks) within the group


David Borkovec

David Borkovec

Market leader for Czech Republic, PwC Czech Republic

Tel: +420 724 369 345

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