Tax Advisory and Transactions

Supply and value chain tax advisory

A fundamental principle of tax strategy is to locate functions, assets, and risks in jurisdictions where they can be taxed at rates most favourable to the business.

Deloitte’s value chain alignment (VCA) teams integrate corporate operating models (or value chains) with global tax strategy for optimal value—helping multinational corporations build scalable, sustainable tax-advantaged supply chains that are poised for growth. With extensive experience in value chain tax advisory, intellectual property practices, and direct and indirect global tax strategy development, we help clients make effective decisions on an after-tax basis. This includes analysing, responding to, and effectively managing risks in relation to tax objectives.

Intellectual property management

Smart intangible assets management, especially with a focus on intellectual property (IP) protection, can confer a significant competitive advantage. With intangible assets becoming more and more central to market valuation, organisations must carefully consider how they evaluate and monitor IP location, value, and security. Adding to the complexity are shifting international tax laws, including a proliferation of rules around movement and pricing of intangible assets.

Deloitte’s intellectual property tax teams advise clients on creating, owning, and monetising intangible assets in line with their business models, and on the impact of location and structure of those intangible assets on a company’s global effective tax rate. Our teams of tax advisors work closely with financial advisory, legal, and accounting experts to identify and implement efficient and effective IP management structures for your business.

Learn more about Intellectual property management.

Finance and treasury tax advisory

Tax reforms adopted around the globe, often in response to OECD initiatives, could have significant tax implications for your finance and treasury functions. To respond effectively, you must be able to identify cash and risk exposures, understand liquidity positions, manage foreign exchange volatility, and deploy or repatriate cash. It takes powerful technology to do all of this, not to mention maximising operational efficiency while staying agile enough to respond to unexpected internal and external change.

When your treasury team needs support, turn to Deloitte’s finance and treasury tax specialists for advice on navigating the international tax landscape. We can help assess sustainable, global finance and treasury policies through a tax lens. From fund advancement to M&A and restructuring, we can help assess tax attributes, respond to regulatory changes, and mitigate risk.

As part of a multidisciplinary organisation, we collaborate with Deloitte accounting advisory, treasury technology consulting, financial advisory, legal, and other specialists, providing comprehensive, practical advice on the tax impacts of financial transactions.

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Legal entity structuring

Business units of multinational organisations don’t—and can’t—operate in isolation; actions can have far-reaching effects on business decisions and tax provisions across the organisation. International tax frameworks such as OECD, BEPS Actions, and the EU Anti-tax Avoidance Directive (ATAD) are constantly evolving, as are jurisdiction-based tax laws, leading to growing regulatory complexity and increased scrutiny. Tax rule changes can affect access to treaty benefits, application of domestic anti-abuse rules, foreign tax credit (FTC) utilisation, and application of controlled foreign company (CFC) rules—all of which must be considered when assessing legal entity and business structures.

Deloitte tax professionals with expertise in legal entity structuring can analyse local, bilateral, and multilateral treaties, laws, and regulations to clarify the impact of global operating structures on your tax obligations. Insight into the international tax implications of capital deployment; repatriation strategies; and proposed mergers, acquisitions, and divestments supports confident business decisions.

M&A tax due diligence

As long as organisations continue to restructure, enter new markets, or buy and sell entities, M&A will remain an important factor in competitive advantage. And due diligence is critical to assessing the soundness of any investment.

Deloitte’s M&A due diligence tax professionals provide corporate clients and private equity investors with a spectrum of tax due diligence services. Our multidisciplinary approach brings together M&A professionals with industry and tax technical specialists to analyse and quantify industry, country, and deal-specific tax risks and opportunities; determine tax asset quality; and identify potential hidden costs, contingencies, and commitments. On both buy side and sell side, we can conduct diligence inquiries, model alternative tax approaches, and analyse the effects of multiple scenarios on future cash flows and earnings.

M&A transaction tax structuring

Complex business transactions—mergers, acquisitions, joint ventures, equity investments, and divestitures—require the dedicated attention of experienced financial, accounting, legal, and tax professionals. And when a deal involves one or more parties with global operations, the range of considerations can be daunting.

Deloitte M&A transaction tax structuring professionals help companies navigate the myriad tax issues arising from cross-border transactions, including advising on tax-efficient deal structures. We can, for example, advise on transaction structure for an IPO or tax structure for an acquisition or disposal, on behalf of the buyer, seller, or financing party. Our focus is on optimising our client’s tax position, maximising tax synergies and attributes, and meeting the needs of all stakeholders, including related lenders and management. We do not advise in a vacuum, but recognise that accounting, legal, regulatory, cultural, and labor issues all play a part in M&A transaction tax analysis.

Post-merger integration

Following any merger or acquisition, businesses need practical strategies for reducing tax risk and maximising the likelihood of post-merger tax benefits. Deals involving global businesses must also take into account foreign and cross-border tax and global value chain considerations.

Deloitte can help identify post-merger integration tax synergies. We work closely with legal and financial advisers to review transaction documentation, release post-merger value, and manage local country requirements and tax risks. Once a deal is complete, we can help realise tax synergies in the supply chain, sales organisation, back-office operations, and other areas of a business.

Tax controversy advisory

Multinational organisations can spend enormous time and resources managing tax controversies and disputes across numerous jurisdictions. In today’s tax landscape, many authorities have moved beyond investigating technical merit and analysis to a growing focus on implementation and motive.

Deloitte's tax dispute resolution teams include former tax authority officials, alternative dispute resolution professionals, and, in many countries, tax litigation specialists—all devoted to supporting you at every phase of the tax dispute resolution cycle. We work across all tax fields, including domestic income tax, international tax, transfer pricing, indirect tax, and specialty areas such as incentives; in some markets, we also provide tribunal and court representation. Services include audit readiness assessment and preparation; strategies for minimising the impact of tax controversies; support for mitigation of potential disputes through revenue authority ruling systems; support for international treaty procedures; application of advanced pricing agreements (APAs), and other such tools.

Government grants, credits, and incentives

Many countries offer generous government grants, credits, and incentives for investment in areas such as digital infrastructure, energy efficiency, environmentally sustainable development, innovation, and workforce training. Several fuel R&D innovation through elaborate systems of government financial incentives that fund manufacturing process improvements, production trials, or software integration in laboratory research. While identifying, understanding, and prioritising the right government incentives for your organisation can be time consuming and challenging, it can also generate significant financial benefits.

Deloitte’s global government grants, credits, and incentives practitioners provide grant and incentive support to help organisations around the world pursue appropriate incentives and execute effective strategies, in industries from aerospace to healthcare to agriculture and beyond. Government incentives can also yield immediate cash benefits, including reducing effective tax rates and increasing earnings per share (EPS).

Learn more about Government grants, credits, and incentives.

High net worth and family enterprises: Compliance and advisory

Private and family-owned companies face a range of challenges that can affect not only the success of the business, but also the professional and personal ambitions of its owners. Whether your goal is to expand into new markets, plan for succession, sell your business, or pursue an IPO, integrated tax advice is critical. The same holds true when managing the tax obligations of other high-net-worth individuals and their family offices.

Deloitte tax specialists help private businesses and their owners, family offices, and other individuals with substantial assets to understand, plan, and execute effective business and tax strategies. We keep up with potential and new legislation and evolving markets, offering services tailored to each family’s unique circumstances. Our advice spans income tax advisory and compliance services, helping address the complex interrelationships of a privately held business and its owners, family offices, and employees. We can assist with owner and wealth planning, including wealth preservation and transition of wealth to future generations. Our global tax professionals can answer questions related to tax residency and domicile, and assess the tax implications of international investment opportunities. And we evaluate the potential tax consequences of business and personal wealth decisions on your tax, business, and personal objectives for generations to come.

Learn more about High net worth and family enterprises: Compliance and advisory.

Government and tax authority services

Tax authorities around the world need help modernising and streamlining their operations to keep pace with changes to technology, legislation, operations, and strategic direction.

Deloitte’s government and public sector tax professionals advise tax authorities around the world on policy development and new tax rule implementation, assess economic impact, develop compliance frameworks, and review taxation and enforcement procedures. We support tax technology and operational transformation by reviewing requirements and current business processes; developing specifications; and digitising tax calculation, review, filing, payment, refund, and dispute processes.

Indirect tax recovery and advisory

Faced with opportunities to recover domestic and foreign sales and use taxes—including value added tax (VAT) and goods and services tax (GST)—many businesses rely on time-consuming manual processes to gather sales and use tax recovery information and prepare and submit refund claims.
Deloitte’s global network of indirect tax recovery professionals provide advice and practical support to help businesses process and manage VAT/GST refunds more effectively. We support an end-to-end process, from opportunity identification through data collection and analysis, preparation and submission of refund claims, and any necessary follow-up.

Using Deloitte’s proprietary work processes, tools, and technology, businesses around the world can streamline processes and increase transparency, reducing the time and expense of VAT/GST recovery.

Accounting method services

Tax professionals must constantly evaluate the implications of international, federal, and local accounting method changes, including potential consequences on current and deferred tax.

Deloitte tax professionals offer advisory services designed to optimise tax accounting methods, with a focus on liability, effective tax rate management, and tax risk mitigation.