International tax services: Financial services

Dynamic, diverse, and highly experienced in helping financial services organizations with their international tax structuring.

How PwC can help

The International Tax Services - Financial Services (ITS-FS) group assists financial services organizations, especially large and mid-size private equity & hedge funds, sovereign investment funds, pension funds, venture capital funds, and family offices. ITS FS helps  to navigate:

  • complex international tax environment,
  • stringent capital requirements,
  • risk management considerations,
  • management of operational tax risks,
  • tax implications of investing in different jurisdictions, and
  • enhanced reporting requirements.

International Tax View

International Tax View (“ITV”) is one of many tools found in a suite of services offered to the financial services industry by PwC.

International Tax View (“ITV”)

ITV is a comprehensive database of withholding and capital gains tax rates for over 130 jurisdictions that includes detailed commentary of the domestic tax treatment of income derived from 14 asset classes. In addition, it also provides withholding and refund procedures, domestic filing obligations and commentary on the country’s approach to obtaining double tax treaty relief for over 44 specific fund vehicles.

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Automated Tax Risk Scoping (“ATRS”)

ATRS automates the process of assessing capital gains tax risk in global investment portfolios at the financial instrument level. ATRS uses data from International Tax View to analyze investment portfolios line-by-line by applying tax calculation logic, including:

  • Application of an array of tax reductions and exemptions based on ownership threshold exemptions, likely double tax treaty exemptions, non-land rich exemptions and other domestic rules (e.g. listed security exemptions, EU exemptions);
  • “Flags” where the country/asset combination might have controversial tax treatments;
  • “Dashboard” - providing an aggregate view of the potential tax exposures and can be filtered by country, investment tier, investment platform, financial instrument, or by fund name;
  • A “Details” view providing the potential tax rate and determinations applied to each financial instrument, with the look and feel of a spreadsheet; and
  • Tax Calculations that are exportable in pdf reports and spreadsheets.

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Withholding Tax Reclaims services

PwC assists its clients in filing refund claims for taxes over-withheld on cross-border investment income in multiple jurisdictions across the globe, either based on tax treaties or EU law (‘Fokus Bank claims’).

We provide services to help our clients review the withholding tax rates used by their custodian banks, and identify and reclaim taxes over-withheld in the past.

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Multilateral instrument

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (“Multilateral instrument” or “MLI”) is intended to supplement and modify over 1,300 covered double tax agreements.

The PwC MLI Tracker Tool is another visualization tool showing the MLI’s potential impact on the existing tax treaties.

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Hotline

PwC also offers clients the possibility to contract a “hotline” service for an additional fee, allowing for easier and direct correspondence with PwC’s Operational Tax team. Under this service, and for a fixed quarterly fee, the client team can directly contact, at any time, our dedicated team who will reach out to overseas firms, as needed.

This service is meant to cover more specific international tax questions that may arise for global investors on liquid trading type of investments and that are not included in the International Tax View database. PwC’s Operational Tax team utilizes the required resources to quickly and accurately find and convey an answer.

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Contact us

Jason Becker

US Leader - International Tax Financial Services, PwC US

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