Specialist Tax Services

Our expert team provides comprehensive solutions in tax risk and controversy, transfer pricing, workforce tax, payroll solutions, VAT and global trade and customs.

At the forefront of change and transformation, our team of 11 partners and over 220 professionals offers integrated solutions that leverage specialist expertise. We deliver technology-driven solutions that add value covering cross-border supply chains, tax governance, Revenue audits, workforce reshaping, payroll processing, and consulting and compliance. Our collaborative approach combines deep technical knowledge with innovative thinking and an unwavering focus on understanding our clients’ priorities, ensuring impactful solutions and comprehensive support for evolving tax needs in today’s dynamic business landscape.

 

Client priorities

In today’s complex tax landscape, our clients face diverse challenges. We’ve profiled six areas where our expertise can drive value, helping businesses navigate risks and realise opportunities.

Transfer pricing

Transfer pricing (TP) is crucial for international operational and tax strategies in today’s global economy, with organisations facing increased scrutiny of their TP policies and rising compliance burdens in an evolving international tax landscape. Managing TP risk is critical as businesses and tax authorities navigate changing tax policies and legislation and demands for tax transparency.

Our team of over 60 TP specialists leverages extensive local and international expertise, PwC’s global network and leading-edge digital tools to provide innovative and comprehensive solutions for clients — from fast-growing start-ups to established multinational corporations.

 

Navigating Revenue interventions and disputes

Taxpayers face increased scrutiny as tax authorities become more sophisticated and aggressive, using technology to target their attention and efforts. Cross-border and domestic tax disputes are also rising, with DAC 7 enabling joint audits by Irish Revenue and EU tax authorities. This environment demands a forward-thinking approach to managing tax affairs and disputes.

Our Tax Risk and Controversy team, with their proven track record of successful resolutions, work closely with our colleagues across Tax to help you navigate these complexities by delivering strategic, tailored solutions to meet your unique business needs.

 

Mastering VAT in a digital economy

Value Added Tax (VAT) complexity and the cost of non-compliance pose significant business challenges, and the VAT environment remains dynamic. For example, upcoming changes in e-invoicing and digital reporting within and outside the EU require proactive monitoring and planning due to their wide-ranging business impacts. We’ve also observed an increase in Revenue VAT audits and compliance interventions, which demand substantial time and resources.

Our team of experts can help you stay on top of important international VAT developments and can help ensure that Revenue interactions are managed appropriately and efficiently, helping businesses stay compliant while minimising disruption.

 

Streamlining cross-border trade

Customs considerations are crucial for the cross-border movement of goods. Organisations engaged in importing or exporting must navigate complex requirements to ensure compliance and maintain strategic advantages.

Recent developments like the Carbon Border Adjustment Mechanism (CBAM) bring new regulatory challenges and the upcoming 2028 recasting of the Union Customs Code (UCC) signals comprehensive EU customs reform. Meanwhile, Revenue has increased customs audits and export controls remain a critical compliance area requiring extreme care.

 

Workforce tax management

Organisations face increasing complexity and risk related to people issues. Operating across multiple territories with mobile employees requires compliance with country-specific legislation and tax regulations. Increased enforcement efforts from taxation authorities worldwide heighten this challenge.

The emergence of new business models and a diverse workforce, including traditional employees and ‘gig’ talent, adds further complexity. Ensuring accurate employment tax positions is increasingly challenging, with growing financial and operational risks. Our experts can help you navigate these complexities, mitigating risks and ensuring compliance.

 

Transforming payroll for the modern workplace

Payroll complexity is increasing due to constant legislative changes and greater scrutiny from tax authorities, who now have access to real-time information. This environment heightens compliance risks and reporting challenges. Additionally, businesses managing payroll in-house face rising costs in attracting and retaining skilled payroll expertise.

In response, organisations are seeking to transform payroll delivery. Key objectives include managing compliance risk, streamlining processes, standardising controls and improving overall efficiency and flexibility. These efforts aim to provide a consistent experience for HR, payroll, finance teams and employees while navigating the evolving payroll landscape.

 

Our specialist tax services

Transfer pricing consulting

We provide comprehensive consultancy services to help clients navigate the complex TP landscape. 

Our TP design expertise includes developing practical, defensible TP policies aligned with commercial strategy, assessing and managing TP risks through gap analyses and DEMPE (development, enhancement, maintenance, protection and exploitation) reviews of IP, and optimising TP models for evolving businesses and acquisitions. We also provide value chain transformation, TP governance and business restructuring support services.

From a defence perspective we manage and defend TP audits and interventions globally, support due diligence reviews and engage with tax authorities on advanced pricing agreements. Our team is adept at resolving issues through correlative relief and mutual agreement procedures, ensuring your TP strategy remains robust and compliant.

Transfer pricing compliance

Our transfer pricing compliance services are designed to help you adhere to TP requirements and implement policies effectively and efficiently. 

We assist in documenting your TP policies and meeting your requirements by preparing local files, master files and Country by Country Reports (CbCRs). Our team assesses and addresses gaps in your current TP documentation and compliance requirements, ensuring alignment with other reporting obligations such as the Corporate Sustainability Reporting Directive (CSRD). We also review your CbCR for adherence to Pillar 2 and Public CbCR requirements.

In terms of delivery, we focus on operational TP, implementing TP policies through technology to transform and automate execution. We can assist by optimising intercompany processes and provide analytical tools, significantly reducing the time and effort spent on TP monitoring and adjustments. We establish robust governance and control frameworks to limit the impact of human error while ensuring you meet internal and external reporting requirements. This comprehensive approach to TP compliance not only ensures adherence to regulations but also enhances efficiency and accuracy.

 

Tax risk and controversy

Our Tax Risk and Controversy team, comprising ex-Revenue officials, a former Tax Appeal Commissioner, solicitors, barristers and tax professionals, offers an end-to-end service managing Revenue interventions and tax disputes.

We ensure swift, discreet and effective resolutions for our clients by proactively managing clients’ risk, conducting risk assessments and developing tax control frameworks. We also prepare robust defence files and procedures to support taxpayer positions.

Our team works closely with specialists across Tax in supporting clients through Revenue interventions, including joint audits, by undertaking comprehensive pre-audit testing to identify tax underpayments for disclosure, thereby minimising the risk of publication.

We support clients in navigating the tax appeals process and assist with hearings before the Tax Appeals Commission and higher courts. Additionally, we help clients negotiate with Revenue to resolve disputes effectively.

VAT

Our comprehensive VAT services cater to a wide range of client needs. We prepare, review and manage Irish and international VAT compliance and reporting obligations, including assistance with VAT registrations and international refund claims. We also provide expert support during Revenue VAT audits and compliance interventions, ensuring smooth processes and minimising risks.

We offer in-depth VAT advice on complex share, property and other M&A transactions, as well as guidance on intricate cross-border supply chains to maximise efficiencies. Our services include VAT product rate reviews to ensure correct rate charging on goods and services and thorough VAT due diligence. Additionally, we keep clients informed about imminent changes in the VAT landscape, such as the ‘VAT in the Digital Age’ proposals, advising on optimal preparation strategies. Our goal is to provide tailored, proactive solutions that address current needs while anticipating future challenges in the evolving VAT environment.

 

Global Trade and Customs

PwC provides comprehensive support across customs, excise, export control and trade policy areas, ensuring that organisations can conduct cross-border trade confidently while maintaining compliance and strategic effectiveness. Our expert team helps domestic and international organisations execute compliant imports and exports, conducting detailed reviews to obtain accurate commodity codes, customs origin and valuation.

We guide clients through the process of applying for crucial customs authorisations such as authorised economic operators (AEO) status, inward processing (IPR) and customs warehousing. Our services extend to customs duty planning, helping organisations optimise their trade operations. We conduct thorough export control assessments and business reviews to ensure adherence to regulations and work closely with clients to review their excise duty footprint, ensuring the correct application of rates. Our holistic approach aims to streamline global trade processes while mitigating risks and maximising opportunities.

 

Workforce tax

Our Workforce Tax team combines extensive tax knowledge with advanced technology capabilities to provide comprehensive employment tax solutions. We advise on domestic and international employment tax issues, we have significant experience advising on the tax treatment of all types of pay, reward and benefits. We assist clients in determining the employed or self-employed status of individuals engaged by them. Our expertise extends to preparing organisations for interventions and audits by tax authorities, involving proactive risk management through employment tax health checks to quantify exposures and make formal disclosures when necessary.

We offer specialised guidance on designing, implementing and administering share schemes, including creating appropriate employee communications. Our team supports clients in developing and implementing workforce reshaping programmes, assisting with tax calculations and employee communication. Additionally, we help companies navigate gender pay gap reporting requirements, offering services from calculating reporting numbers to developing communication plans and reviewing diversity, equity and inclusion (DE&I) strategies. Our holistic approach ensures that organisations can effectively manage their workforce tax obligations while optimising their employment strategies.

Payroll solutions

Our Payroll Solutions team offers comprehensive services tailored to meet diverse client needs. We provide domestic payroll processing for organisations of all sizes, from single-employee businesses to those with over 2,000 staff, with our processes externally audited to ISAE 3402 standards. As part of the PwC Global payroll network, we also offer global payroll processing solutions, coordinating services across more than 160 countries.

For organisations seeking to address gaps in their payroll teams, we provide experienced professionals for secondments or resourcing, flexibly adapting to specific requirements. Our holistic payroll consulting solutions apply the lenses of payroll compliance, operations, digital/data and employee experience to resolve challenges and drive efficiencies. This multifaceted strategy ensures we address immediate payroll needs and optimise processes for long-term success.

 

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Ronan Finn

Ronan Finn

Partner, Specialist Tax Services Leader, PwC Ireland (Republic of)

Tel: +353 87 625 9907

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