Tax

Understanding and managing tax related risks when moving employees around the world.

The employment activities of individuals in foreign locations can create a number of complex employer and employee tax issues which, if not dealt with appropriately, could result in significant additional costs and risks for employers.

What we do:

• Mobility strategy planning - we work with organisations to align mobility with their business' strategy
• Assignment planning - we help organisations reduce the costs of global mobility and manage the corporate and employee risks it creates
• Mobility policy design - we help organisations develop a sound framework to support global mobility
• Mobility policy benchmarking - we provide organisations with insight on global and industry specific policy trends and allowances
• Legal support - we advise on immigration and employment law issues created by mobility
• Employment tax compliance - using the global PwC network, we help organisations meet their employee and employer tax reporting/withholding obligations - wherever their people need to go
• Mobility technology - we provide organisations with access to market leading technology to help manage mobility in an effective and easy manner
• Employment structures - we work with organisations to design employment structures which facilitate the rapid deployment of workers, drive cost savings and create efficiencies.

If you’re operating across borders, having a robust tax strategy which is aligned with your corporate strategy continues to be a complex area.

If you are either a Georgia based group investing internationally or investing into the region, understanding the impact of tax policy and legislative changes on your operations and your cross-border transactions is more than ever a part of assessing the commercial returns on those investments.

Our Tax Services practice has dedicated teams based in Georgia, which are closely integrated with our global network.

What we do:

• Review and advise on corporate structure and cash repatriation mechanisms
• Help identify appropriate holding and operating structures that are commercially flexible and tax appropriate when expanding into new territories
• Assist in managing a group’s global tax profile and obligations associated with your operating model

Helping you manage tax risks and maximise deal vaue.

Whatever type of transaction you are contemplating - an acquisition, disposition, merger, joint venture, IPO, public-to-private, restructuring or refinancing – we are able to deploy experienced tax professionals at short notice – teams that combine specialist M&A tax expertise with local and industry knowledge.

What we do:

• Assess and manage tax risks associated with the transaction
• Assess and manage acquisition / merger risk
• Pre-acquisition or pre-sale tax due diligence
• Deal structuring to optimise investment returns and free cash flows
• Fund structuring
• Prepare businesses for disposal or an initial public offering
• Transaction documentation and funds flow assistance
• Tax structuring for co-investors and/or management.

Managing tax risk and addressing tax reporting, compliance and accounting needs efficiently

The increased attention given by regulators and other stakeholders on the tax affairs of companies escalates the importance given to compliance and how tax risks are managed. At the same time there is a constant drive to use technologies, processes and people in the most efficient manner possible in the fulfillment of compliance and accounting obligations.

What we do:

• Local country corporate income tax, withholding tax compliance
• Indirect tax compliance
• Accounting services, including preparing Statutory Financial Statements and augmentation of financial controller, accounting and bookkeeping needs
• Payroll services and employee taxation compliance
• Globally / regionally coordinated compliance services
• Helping tax functions address their strategic, organisational, process and technology challenges
• FATCA and country by country reporting
• Assistance with local IFRS and GAAP tax accounting and reporting.

Working with government and other stakeholders

What we do:

• Working with governments on their tax efficiency and capacity to establish effective tax regimes and administrative systems
• Undertaking benchmarking exercises, working in collaboration with outside organisations such as our Paying Taxes project with the World Bank Group
• Helping to bridge the relationship gap between tax administrations and businesses that want to adopt a more cooperative compliance regime
• Advising on the feasibility and efficiency of greater tax transparency that benefits businesses and policy-makers
• Exploring the impact of tax rule changes both domestically and internationally, as with the OECD’s Base Erosion and Profit Shifting (BEPS) action plan.

Establishing, documenting, and defending prices for cross border intra-group transactions.

Transfer pricing describes all aspects of inter-company pricing arrangements between members of a multinational group, including transfers of tangible goods; services; intellectual property; and loans as well as other financial transactions.

What we do:

• Support transfer pricing policies by preparing Masterfiles, Local Files and Country by Country reporting templates, in accordance with regulatory requirements
• Develop tax efficient and globally defensible transfer pricing models, in line with commercial business activities and international transfer pricing practices
• Advise multinational groups on business restructuring and value chain transformation
• Assist businesses with the practical implementation of transfer pricing models and provide Tax Authority dispute resolution services.

How we can help you

PwC Georgia’s Tax Dispute Resolution practice comprises leading international and Georgian tax specialists proficient in all areas of pre-trial and judicial tax dispute resolution and draws on the expert knowledge of the world's leading tax consultants.

We've assisted in preventing possible challenges from tax authorities and successfully defended our clients during pre-trial and all other stages of the judicial process.

What we do:

• Legal review of tax authorities' conduct and resolutions
• Support of desk and field tax audits
• Drafting objections to acts, complaints related to resolutions based on results of tax audits
• Pre-trial support during disputes with tax authorities
• Representing clients in all judicial instances
• Drafting of amicable agreements
• Drafting of agreements establishing consolidated groups of taxpayers.