Foreign Direct Investment

Empowering you to achieve your global business needs.

The international tax landscape is constantly evolving. Whether you are a well-established business or embarking on your global business journey, our experienced team at PwC Ireland is here to help. We will guide you through the complexities of global and local tax developments, working alongside you to create sustainable solutions tailored to your specific business needs.

Navigating global business obligations

As the international tax landscape evolves, businesses need access to experienced professionals and solutions they can trust. At PwC Ireland, we offer comprehensive support for inbound investment into Ireland and the European Union (EU), as well as mergers and acquisitions.

Market Access
Efficiency
Governance and Substance
Compliance

Market Access

Companies with a global footprint or those looking to expand their activities must strategically position their operations in the most efficient jurisdictions. This strategic positioning allows them to access international markets seamlessly and enhance their supply chain capabilities with minimal disruption. However, managing market access can be complex — particularly from a tax perspective.

Expanding commercially into new jurisdictions often brings about significant tax complexities. The rapidly changing regulatory landscape further complicates companies’ ability to meet their international tax compliance obligations. Achieving commercial growth and expanding into new markets while remaining compliant is essential for developing a sustainable business model and safeguarding your company’s reputation.

Efficiency

Achieving and maintaining cost and fiscal efficiencies is a crucial business driver. For companies with a global outlook, it is essential to structure their operations efficiently to reduce overall operating costs. This can be accomplished by accessing various incentives, such as research and development (R&D) and intellectual property (IP) regimes.

Businesses operating in multiple countries must also coordinate subsidiaries with unique and diverse accounting practices, legislative environments and local business customs. Managing this environment is more important than ever, especially with governments’ and tax authorities’ heightened focus on tax transparency.

Governance and Substance

Managing the governance and substance requirements of global business groups that operate across borders can be challenging, especially given the rapidly evolving regulatory environments in which they operate.

Companies must continually monitor regulatory changes, manage substance requirements and structure their activities to align with their business model. Organisations need to optimise their global tax strategy and understand the impact of tax policy and legislative changes. Keeping pace with these obligations is essential as a critical governance pillar.

Whether you are a mature business or a startup in a hyper-growth phase, aligning business models and substance requires constant monitoring to ensure that obligations are not overlooked. As the business expands into new product lines, markets and regions, the tax function must be agile and ready to provide the necessary advice to support this journey.

Compliance

The consequences of non-compliance are becoming increasingly severe while the complexity of compliance requirements continues to rise. Companies must manage their global compliance footprint to mitigate risk, conserve resources and enable overburdened tax departments to focus on higher-value-added activities.

With the growing number of compliance obligations, information reporting requirements and real-time reporting demands, companies need access to regular and timely information. This information allows them to effectively monitor global business trends, regulations and challenges. As more information becomes publicly available through enhanced information exchange between tax authorities, the importance of compliance being right first time has never been greater.

Our Foreign Direct Investment services

Inward Investment
IP Structuring
Finance Restructuring
Holding Company Locations
Tax Compliance and Revenue Interventions
Entity Governance and Compliance

Inward Investment

We specialise in assisting businesses with all aspects of investments in and through Ireland, catering to companies of all sizes. We support clients on various inward investment projects, including establishing entities and operations in Ireland, expanding existing operations and making acquisitions and divestments. Whether you are making an acquisition or need to integrate it into your existing business model, we can guide you every step of the way.

We leverage our global PwC network to support companies on these projects. Specifically, we provide due diligence services to assist both buyers and vendors in preparing detailed tax reviews. We help companies structure acquisitions and understand how their corporate structure will look post-merger or acquisition, considering tax efficiency and aligning substance with the business model. Additionally, we offer assistance with the tax elements of legal transaction documents.

IP Structuring

We collaborate with companies to analyse their current and prospective intellectual property (IP) and value chain strategies. Our support includes implementing optimal structures that align with the current business model while providing flexibility for future business needs. We also deliver robust structuring solutions by leveraging and coordinating our local PwC specialist teams and broader global PwC network.

Specifically, we assist companies with transferring IP, accessing IP tax regimes and relevant reliefs, and preparing necessary tax filings. We provide recommendations for the ongoing care and maintenance of these structures, considering local and global tax policy developments.

Finance Restructuring

We assist companies in evaluating and executing effective financing and debt planning strategies. Such finance restructuring enables groups to access both internal and external funding, facilitating the efficient management and transfer of funds between group entities to support business needs.

Our services encompass various topics, including proposing robust structures that align with Irish and global tax policy developments. We analyse the Irish tax and withholding tax implications of the proposed financing and consider the application of interest limitation rules. Additionally, we guide companies on the ongoing governance and substance requirements following the implementation of these structures.

Holding Company Locations

We collaborate with companies to evaluate and establish efficient holding company structures that incorporate flexibility to accommodate future business model changes and needs.

Leveraging our global network, we provide multi-jurisdictional comparisons of holding company locations and offer structuring options that align with both Irish and global tax policy developments. Additionally, we support companies with ongoing compliance and structuring requirements related to efficient repatriation, investment and divestment strategies.

Tax Compliance and Revenue Interventions

We provide real-time support to help companies prepare and plan for local, global and Pillar Two tax compliance obligations. As there is no one-size-fits-all solution for compliance, we create efficient and bespoke processes to streamline these workstreams and leverage our local and global network to meet all compliance deadlines.

Additionally, we keep companies informed by providing regular local, global and Pillar Two tax technical and tax policy updates. We also support companies in their interactions with local and international tax authorities, leveraging our local and global specialist teams to assist with tax authority interventions.

Entity Governance and Compliance

Our experienced team provides a comprehensive range of annual compliance services designed to keep our clients fully informed and compliant with all regulatory requirements. Our proactive approach ensures that you are made aware of your annual compliance obligations well in advance of filing deadlines, allowing you to focus on your core business activities.

We offer a variety of services, including the incorporation of companies and registration of branches, preparation and filing of annual returns, and drafting of annual general meeting documentation. We also maintain statutory books or registers, update clients on company law changes and provide a registered office address. Additionally, where permitted, we can act as company secretary, attend board and shareholder meetings, draft minutes and prepare and file appropriate documentation concerning changes to company or director particulars.

We provide advice and support on corporate restructuring and reorganisations including legal entity rationalisation projects.

In addition to our compliance and restructuring services, our team delivers practical and focused advice on strengthening corporate governance practices. These services include training sessions for the board or senior management team, advice on board reporting and subsidiary governance, guidance on minutes and agendas, and secondments.