Deloitte.com/tax standardization project Service category, service line and tax home pages text Contents Tax home page text Tax home page ....................................................................................................................................................... 3 Service category pages text Global business tax services ................................................................................................................................... 5 Cross-border tax ..................................................................................................................................................... 6 Global employer services ........................................................................................................................................ 7 Indirect tax .............................................................................................................................................................. 8 Service line pages text Business tax .......................................................................................................................................................... 10 Customs & Global Trade (C&GT) .......................................................................................................................... 12 Global employer services ...................................................................................................................................... 14 Indirect tax (VAT or GST) ...................................................................................................................................... 16 International tax..................................................................................................................................................... 18 Legal services ......................................................................................................... Error! Bookmark not defined. Mergers & acquisitions .......................................................................................................................................... 19 Private company services ..................................................................................................................................... 20 Research & development and government incentives .......................................................................................... 22 Tax management consulting ................................................................................................................................. 28 Transfer pricing ..................................................................................................................................................... 27 1 Tax home page text 2 Tax home page Deloitte offers clients a broad range of fully integrated tax services. Our approach combines insight and innovation from multiple disciplines with business and industry knowledge to help your company excel globally. Deloitte International Tax Source (DITS) Doing business in a cross-border environment? DITS provides tax and income tax treaty rates for more than 65 jurisdictions worldwide, as well as comparative information on holding companies and transfer pricing policies. International Tax Business and Guides Business Guides provide an overview of the investment climate, taxation and operating conditions for 48 jurisdictions, while the Highlights series offers major tax rates and investment information for over 130 jurisdictions. 2011 Global transfer pricing desktop reference This report—formerly known as the Strategy Matrix for Global Transfer Pricing—is one of the most comprehensive and authoritative guides of its kind, compiling essential information regarding the transfer pricing regimes in 52 jurisdictions around the world and the OECD. Contacts: Nazrien Kader Service line leader Taxation Services 3 Service category pages text 4 Global business tax services Business tax (link to member firm Business tax service line page) Deloitte delivers a comprehensive, practical approach to tax planning that helps multinational businesses meet their worldwide tax and statutory responsibilities while identifying planning opportunities and providing specialized services to achieve cost efficiencies in line with the company’s risk profile. We believe that the most defensible tax strategies are aligned with the company’s operations and integrated with the overall business plan. Private company services (link text to member firm Private company services service line page) Private companies face a range of challenges that affect not only the success of the business enterprise, but also the professional and personal goals of their owners. Whatever the end goal — an IPO, expansion into new markets, succession to a family member, or sale — integrated tax planning is critical. Our services to private companies include entity income tax planning and compliance services, individual tax and wealth planning matters, international tax, and family offices. R&D and government incentives (link text to member firm R&D and government incentives service line page) Deloitte helps clients to lower the effective cost of doing business locally and globally by optimizing cash incentives that are available retrospectively and those that are based on future investment plans. Our specialists work closely with a Quality Assurance team who review deliverables and computations to evaluate whether the rules and other criteria are properly applied and that the full scope of qualifying costs is considered. We provide more transparency and ensure compliance with regulatory changes through the application of global technology solutions and deep tax technical expertise worldwide. Tax management consulting (link text to member firm Tax management consulting service line page) With tax technical, technology, and consulting experience, Deloitte helps businesses meet the challenges of multijurisdictional tax operations, including compliance, reporting and risk management for direct and indirect taxes. We help clients transform processes and technologies to enhance efficiencies, align data, and improve transparency from the ERP systems all the way through the reporting and documentation process. Contacts: Trevor Rogers 5 Cross-border tax Deloitte professionals advise companies on a broad range of inbound and outbound tax issues, including structuring initial overseas investments, financing international operations, cross-border transactions, management of the global effective tax rate and business re-structuring. International tax services (link text to member firm International tax services service line page) One of the biggest challenges – and greatest areas of opportunity – for a multinational company today is effectively managing local and foreign taxes in a way that aligns with its overall business objectives and operations. The tumultuous global economy requires a closer relationship between a company’s tax and business operations to maximize every opportunity for cash tax savings and tax efficiencies. Deloitte’s innovative approach helps multinationals reduce taxes on earnings, enhance margins and grow their businesses. Mergers & acquisitions (link text to member firm Mergers & acquisitions service line page) All transactions—whether mergers, acquisitions, joint ventures, equity investments, or divestitures—involve complex issues that require the dedicated attention of experienced professionals. When those deals involve companies with global operations, wading through the additional range of considerations is even more daunting. Deloitte can assist and provide advice in effectively navigating the myriad of tax, accounting, legal, regulatory, cultural, and labor issues in cross-border transactions to help manage compliance risks and potentially enhance returns. Transfer pricing (link text to member firm Transfer pricing service line page) Deloitte’s globally-managed transfer pricing team helps companies reduce risks by aligning practical transfer pricing solutions with overall global business operations and objectives, assists with strategic documentation to support transfer pricing practices, and resolves disputes efficiently. Contacts: International Tax: Louise Vosloo M&A Tax: Helgo Rapsch Transfer Pricing: Billy Joubert 6 Global employer services (See Global employer services service line page text, below) Contacts: Bernie Abbott 7 Indirect tax Customs & Global Trade (link text to member firm Customs & Global Trade service line page) Effective management of global trade decisions and obligations is of strategic significance to a company’s global supply chain. Deloitte has a market leading, worldwide network of Customs & Global Trade specialists experienced in global trade strategy, automation, export controls and import/export compliance. Our professionals help design strategies and structure global transactions to reduce customs duty payments and other international trade costs, increase duty recoveries, and help to ensure legal and regulatory requirements are met in a cost-effective manner. Indirect tax (VAT) (link text to member firm Indirect tax (VAT or GST) service line page) VAT, (Value Added Tax) taxes are broadly based on transactions, and liability will arise regardless of profitability. Because most countries impose these taxes, most transactions are affected. Deloitte can help with timely planning and the application of technology-based compliance management solutions. This can help clients reduce costs, minimize risk and at the same time increase confidence that nothing has been missed. Deloitte has a worldwide network of professionals who provide advisory services and a full spectrum of highly efficient outsourcing and co-sourcing solutions. Contacts: Customs & Global Trade: Jed Michaletos VAT: Severus Smuts 8 Service line pages text 9 Business tax Deloitte delivers deep knowledge of tax and statutory requirements as well as a breadth of experience applying them in practice worldwide. Practical, innovative tax advice combined with our globally-managed tax compliance framework instils confidence that a consistent approach is followed in all jurisdictions. We help simplify tax management and oversight while providing global visibility for making informed strategic decisions ― all with the ease of a single global provider. Our services include: Compliance services (text should be anchor-linked down to corresponding subheading further down page) Financial accounting for income taxes (text should be anchor-linked down to corresponding subheading further down page) Tax controversy services (text should be anchor-linked down to corresponding subheading further down page) Advisory and consulting services (text should be anchor-linked down to corresponding subheading further down page) Consulting – post merger integration (PMI) services (text should be anchor-linked down to corresponding subheading further down page) Foreign Account Tax Compliance Act (FATCA) (text should be anchor-linked down to corresponding subheading further down page) Compliance services As businesses expand operations into new markets the complexity of managing tax risks and complying with reporting requirements multiplies. Our globally-managed tax compliance framework enables Deloitte’s tax professionals to help multinational organizations achieve their goal of accurate, cost-effective compliance that also provides global visibility to the right information for making informed strategic decisions. Back to top Financial accounting for income taxes Financial accounting and reporting for income taxes have become increasingly complex. Tax departments must keep up with the latest regulatory developments and guidance related to income tax accounting, disclosures and documentation, as well as seeking ways to address their tax provision process and technology needs more reliably and efficiently. Deloitte tax professionals understand the complexities and can provide practical insight, standardization, and technical expertise to help clients navigate through the maze of statutory requirements. Back to top Tax controversy Multinational organizations will continue to spend more time and resources managing tax controversies in both their local and overseas markets. Tax authorities are sharing information about companies and focusing increasingly on implementation failure and motive rather than technical merit. Deloitte’s team includes former tax authority officials, alternative dispute resolution specialists, and in many countries, tax litigation specialists who can assist multinational businesses at all levels of the Tax Controversy Cycle. We developed Tax Controversy Management software to help multinational companies consistently control and manage tax controversies across multiple jurisdictions. Back to top Advisory and consulting services One of the biggest challenges – and greatest areas of opportunity – for taxpayers is effectively managing local and foreign taxes in a way that aligns with overall business objectives and operations. Deloitte advises companies on a broad range of domestic and foreign tax matters, including management of the global effective tax rate, business re-structuring and planning for the impact of new and proposed regulations. Our globallymanaged team helps companies implement practical, innovative strategies to better manage taxes earnings and enhance cash flow so they can focus on growing their businesses. Back to top 10 Consulting – post merger integration (PMI) services All transactions—whether mergers, acquisitions, joint ventures, equity investments, or divestitures—raise complex issues regarding potential tax risks and provide opportunities to implement practical strategies to improve tax efficiency and certainty. When those deals involve companies with global operations, wading through the additional range of considerations is even more daunting. Deloitte can assist in effectively navigating the myriad of tax, accounting, legal, regulatory, cultural, and labor issues that arise in a transaction and help you to fully realize the anticipated post integration synergies. Back to top Foreign Account Tax Compliance Act (FATCA) Beginning in January 2013, virtually all non-U.S. financial intermediaries and withholding agents that own or hold U.S. investments will be subject to the information reporting and disclosure requirements of the Foreign Account Tax Compliance Act (FATCA). This U.S. legislation will greatly impact organizations’ tax functions, technology systems, operations, and business strategy. As a recognized leader in both tax and technology, Deloitte is uniquely qualified to assess and address all of the implications related to compliance with FATCA. From analysis and remediation of existing systems to design and implementation of enterprise-wide systems and practical procedures needed to identify and report required information to the U.S. Internal Revenue Service, our specialists keep businesses one step ahead in this developing area of compliance and risk. Back to top 11 Customs & Global Trade (C&GT) Effective management of global trade decisions and obligations is an important – and sometimes overlooked – factor in a company’s global supply chain. Deloitte's global network of Customs & Global Trade specialists are experienced in global trade strategy, automation, export controls and import/export compliance. Our professionals help design strategies and structure global transactions to reduce customs duty payments and other international trade costs, increase duty recoveries and help ensure legal and regulatory requirements are met in a cost-effective manner. We offer services in the following main areas: Export controls (text should be anchor-linked down to corresponding subheading further down page) Trade compliance & controversy services (text should be anchor-linked down to corresponding subheading further down page) Consulting (text should be anchor-linked down to corresponding subheading further down page) Business model optimization (text should be anchor-linked down to corresponding subheading further down page) Tax Management Consulting (TMC) (text should be anchor-linked down to corresponding subheading further down page) Export controls Deloitte’s market leading export control practice is a multidisciplinary, multilingual team of lawyers, consultants, ex-government officials and industry specialists, combining years of experience in global export controls. Our professionals are experienced in U.S. export controls and extraterritorial restrictions, as well as local and regional export regulations. Deloitte has a strong reputation for its knowledge in encryption controls and leads international thought-leadership activities in this field. Our export control team works with clients to review current compliance processes, conduct large scale, multi-country classification projects, provide training, develop or enhance existing compliance programmes, and implement automated solutions to support internal controls. Our team’s specialization includes both dual-use and military controls. Back to top Trade compliance & controversy services Companies are facing an increasing number of compliance requirements imposed by the countries in which they operate, as well as more rigorous enforcement by tax authorities. Deloitte offers efficient, cost-effective Customs & Global Trade compliance services including cosourcing and outsourcing options. We help companies reduce risk and provide more timely and transparent reporting through the application of technology based solutions. This approach improves data management and ensures data integrity and accuracy. When controversies arise Deloitte provides audit assistance, representation and litigation before authorities, advisory opinions and reports Back to top Consulting Deloitte’s Customs & Global Trade team includes lawyers, accountants, auditors, customs brokers, economists, former government officials, and industry specialists. We advise companies on both fiscal and non-fiscal regulations to help them avoid additional duties, taxes and penalties related to non-compliance, as well as consequences like complete import or export stops (e.g., REACH (Registration, Evaluation, Authorization and Restriction of Chemicals), Customs-Trade Partnership Against Terrorism , Authorized Economic Operator and others). Deloitte professionals help companies with a variety of Customs & Global Trade related needs such as optimizing post merger integration by tracking duty risks and opportunities for potential tax deductions and in helping to reconcile and determine consistent support for what is an “arm’s length” or “fair” value for both customs and transfer pricing purposes. Back to top Business model optimization Companies are looking for a sustainable competitive edge. Deloitte’s Business Model Optimization (BMO) professionals work as part of an integrated team consisting of Consulting, Enterprise Risk and Tax specialists. We focus on removing avoidable costs from global trade transactions while ensuring compliance with the myriad of trade regulations around the world. Deloitte’s approach to optimizing business models and supply chains considers both import and export requirements, which helps companies to avoid incremental duty/trade costs 12 and/or supply chain interruption. It also affords companies an opportunity to optimize their Customs & Global Trade processes and to gain a sustainable competitive edge through increased efficiency. Back to top Tax Management Consulting (TMC) Deloitte provides companies and public bodies with support and advice on global trade technology solutions for Tax accounting and reporting. We deliver comprehensive, tailored solutions to clients through centrally led, global teams that consist of Information Technology consultants, economists, former government officials, lawyers, and industry specialists. We assist businesses with vendor selection to assess and identify the optimal solutions; blueprinting of Customs & Global Trade processes; functional and technical implementation(s); integration of the trade solutions with various ERP systems (SAP, Oracle, AS400, and others); and post launch application support. Back to top 13 Global employer services As companies grow and become more global in scope, employment issues become more complex. Among the most serious challenges businesses face today is compliance with multifaceted tax laws and labor regulations. Deloitte offer well-rounded plans and program development strategies that can help transform global employment programs in a tax- and cost-efficient manner. Our services include: International assignment services (text should be anchor-linked down to corresponding subheading further down page) Compensations & benefits (text should be anchor-linked down to corresponding subheading further down page) International human resources (text should be anchor-linked down to corresponding subheading further down page) Risk talent rewards (text should be anchor-linked down to corresponding subheading further down page) Technology (text should be anchor-linked down to corresponding subheading further down page) International assignment services An important corporate legal and reputational risk that global employers must contend with is ensuring they and their employees are aware of and comply with local filing requirements. A successful international assignment program requires companies to strike a balance between competitive compensation and cost control, always taking care to have effective policies and procedures for regulatory compliance. Deloitte can help with this complex challenge through our extensive knowledge of tax laws across jurisdictions and our specialized compliance and consulting skills and software. Our professionals help companies coordinate various elements related to a globally mobile workforce, to address worldwide compliance with employees’ individual and payroll reporting and filing requirements. Back to top Compensations & benefits Organizations seek to design and operate compensation and benefit programs in a cost-effective, tax efficient and compliant manner – for the employer as well as employees. Deloitte professionals help align compensation and benefits programs with a company’s overall talent and corporate strategies, and the marketplace needs. We help address a complex array of tax matters at various stages of a company’s lifecycle, including mergers, acquisitions, divestitures, right-sizing, and general restructuring. Beyond compliance, our integrated team of specialists can help explore opportunities to transform global employment programs, such as, discerning the total rewards that critical employees want and need; identifying incentives for employees to successfully carry out company business and talent plans; and exploring ideas that provide a cost-efficient return on investment (ROI). Back to top International human resources Whether creating a company’s first international program for employees, re-examining the operational effectiveness of an existing program, taking a second look at a current provider, or transitioning the administration of a program to address regulatory concerns, Deloitte’s International Human Resources professionals can help. We work with companies to administer the internal financial and compensation elements of their global mobility programs. Our approach aligns international assignment program goals with overall human resource and corporate strategies. We offer specialized experience in policy design, benchmarking and administration coupled with delivery skills to contribute significant value to the employer which allows them more time to focus on enhancing the employee’s international assignment experience. Back to top Risk.Talent.Rewards. The success of every organization is directly linked to its people. Today’s global environment challenges companies to think strategically about harnessing the energy and ingenuity of a geographically and culturally diverse workforce. Deloitte professionals help multinational organizations assess, improve, and ultimately transform their global mobility, global rewards, global talent and performance management programs. We draw upon the diversity of our organization’s experience and insight to provide clients with leading edge planning that incorporates a practical perspective on implementation and ongoing operations. Additionally, we offer services that support the design and implementation of appropriate controls to manage the financial and regulatory risk of 14 deploying talent across-borders. Well designed, well managed programs allow companies to quantify ROI and make more strategic decisions about how best to achieve talent management objectives. Back to top Technology Technology provides the efficiencies, controls, and business intelligence that allow our clients to raise service levels to their assignees, vendors, and management. Deloitte is a recognized leader in the design, development, and implementation of innovative expatriate services technology that can significantly streamline program administration and leverage international employee data. We have helped many global organizations integrate technology into their international assignment programs and become e-enabled. Our web-based tools can enhance customer service, speed transactions, and monitor quality and accountability. Through our next generation GlobalAdvantage Portal, users can access our tools and customize their experience with interactive, dynamic functionality. Back to top Relocation Services Global assignments have proven to carry considerable costs and effort for companies involved in expatriate placements. In answer to this challenge Deloitte Taxation Services has expanded their Global Employer Service offering to include a Relocation Service. Our service consists of the complete business process associated with the transfer of an employee and their family to a new place of work and residence providing a seamless and effective integration into the new community, including home finding, school search, language lessons, cross cultural training and complete settling in services. 15 Indirect tax (VAT) VAT, (Value Added Tax) taxes are broadly based taxes on transactions, and liability will arise regardless of profitability. Failing to account for these taxes correctly can have a significant impact on business costs and cash flows. Deloitte specialists work with both businesses and the public sector. Deloitte can help with timely planning and the application of technology-based compliance management solutions, thereby helping to reduce costs, reduce risk, and increase the confidence that nothing has been missed. Our services include: Indirect tax consulting (text should be anchor-linked down to corresponding subheading further down page) Business model optimization for indirect tax (text should be anchor-linked down to corresponding subheading further down page) International indirect tax compliance and outsourcing (text should be anchor-linked down to corresponding subheading further down page) Transactional consulting for indirect tax (text should be anchor-linked down to corresponding subheading further down page) Indirect tax consulting With rates ranging up to 25 percent in various jurisdictions, VAT/GST, Sales & Use Tax and other indirect tax exposures can grow quickly without a cohesive strategy and a firm understanding of each jurisdiction’s specific indirect tax requirements. Deloitte provides client focused advisory services on local and international indirect tax related matters including planning, rate determination and international consulting such as foreign indirect tax requirements. We take a standardized approach from start to finish. We employ smart tools like web-based questionnaires to help fully control the process. Based on the outcome, we can help determine which indirect tax strategy aspects require attention. In the ever-changing environment, Deloitte professionals can help clients stay current with compliance obligations. Back to top Business model optimization for indirect tax From the Indirect Tax perspective, Business Model Optimization (BMO) involves designing and implementing an approach for goods or services that embraces the convergence of technologies while optimizing overall tax efficiency and decreasing the levels of strategic risk. The benefits of BMO include: Lower overall tax rate for the business (text should be anchor-linked down to corresponding subheading further down page) Improved reported earnings (below the line) and cash flow (text should be anchor-linked down to corresponding subheading further down page) Reduced complexity (text should be anchor-linked down to corresponding subheading further down page) BMO projects inevitably touch many aspects of business operations. Deloitte provides integrated services that cover tax, accounting, and business consulting, providing clients with holistic solutions, as a result of considering multiple perspectives. Back to top International indirect tax compliance & reporting services (compliance and outsourcing) Deloitte offers leading edge International Indirect Tax Compliance Outsourcing & Co-Sourcing services. We have established several Indirect Tax Compliance Centers to help ensure consistent and highly efficient processing of returns. Deloitte can assume partial or full responsibility for Indirect Tax compliance obligations across multiple jurisdictions. With our ability to deliver worldwide proven experience and innovative application of technology, Deloitte offers a full spectrum of highly efficient Compliance Outsourcing and Co-sourcing solutions. So whether you need to file only one or over 1,000 returns, Deloitte can help you. Back to top Transactional consulting for indirect tax Transactions are often not part of the day-to-day operations of the finance department or in-house Indirect Tax experts. To fill this knowledge and experience gap, Deloitte provides transactional advisory services delivered by professionals who specialize in Indirect Tax and are immersed in it every day. Deloitte professionals follow a 16 holistic approach by working with Deloitte transactional specialists in financial advisory, consulting, and other tax specializations to help ensure the indirect tax advice delivered is within the context of the transaction as a whole. We track possible transaction tax or duty risks while helping clients maximize tax deductions for, and tax recovery on, transaction costs. Deloitte’s diligence helps ensure that after a deal has been closed, the post merger integration occurs in a tax optimized way. Back to top 17 International tax Deloitte’s International Tax professionals help multinational companies reduce taxes on earnings, enhance margins and grow their businesses through a wide variety of compliance and advisory services. Deloitte offers innovative approaches that align with a company’s overall business objectives and the way the company operates. Professionals in our globally managed international tax practice provide a comprehensive range of inbound and outbound tax services, including: Compliance services (text should be anchor-linked down to corresponding subheading further down page) International strategic tax reviews (text should be anchor-linked down to corresponding subheading further down page) International mergers and acquisitions (text should be anchor-linked down to corresponding subheading further down page) Business model optimization (text should be anchor-linked down to corresponding subheading further down page) Compliance services Tax departments of multinational businesses face formidable challenges coping with the profusion of compliance requirements imposed by the countries in which they operate. The increasing number of rules, more rigorous enforcement by tax authorities and staffing constraints compound these challenges. Deloitte offers efficient, costeffective compliance services, including co-sourcing and outsourcing options and a proven suite of integrated tax technologies that provide benefits throughout the life cycle of the organization. We help multinationals gain greater confidence in their level of compliance through improved data management and by validating data integrity and accuracy. We help reduce risk, provide more timely and transparent reporting and improve overall compliance efficiency by automating and systematizing routine and repetitive tasks. Back to top International strategic tax reviews As companies expand globally, their global tax and treasury strategies need to become more integrated, flexible and sustainable. Deloitte’s International Strategic Tax Review (ISTR) helps companies understand the drivers of their effective tax rate (ETR) and potential opportunities to reduce it. We assist with foreign tax credit planning, repatriation planning, ETR modelling, post-merger integration and legal entity rationalization. An ISTR provides a framework for discussion, design and implementation of global tax and treasury strategies that are aligned with the company’s business objectives. Deloitte’s fact-driven, analytical – rather than intuitive – approach helps multinational companies to objectively and methodically chart their tax strategy going forward. Back to top International mergers and acquisitions International mergers and acquisitions (M&A) continue to be a prime focus of tax authorities around the world. The host of challenges raised by M&A transactions calls for deep experience across a wide range of issues in multiple jurisdictions. Deloitte’s International Tax professionals around the world deliver targeted support designed to guide companies through cross-border deals with an understanding of local culture and business environments. Deloitte participates in all aspects of cross-border mergers, acquisition or disposition transactions, including due diligence, structuring, modelling, financing, post-merger integration and reporting. Back to top Business model optimization In light of today’s dynamic global economic environment and the potential for legislative changes, assessing a multinational’s global business model may no longer be an optional exercise. Deloitte’s Business Model Optimization (BMO) team provides high quality, customized tax and business model transformation services. We focus primarily on global supply chain and intellectual property planning, seeking to align business objectives with tax minimization. Our goal is to help multinationals integrate their operational and tax planning in a scalable and sustainable way to enable business leaders make more effective decisions on an after-tax basis. Back to top 18 Mergers & acquisitions All transactions—whether mergers, acquisitions, joint ventures, equity investments, or divestitures—involve complex issues that require the dedicated attention of experienced professionals. When those deals involve companies with global operations, wading through the additional range of considerations is even more daunting. Deloitte can assist and provide advice in effectively navigating the myriad of tax, accounting, legal, regulatory, cultural, and labor issues in cross-border transactions to help manage compliance risks and potentially enhance returns. Our services include: Deal structuring and due diligence (text should be anchor-linked down to corresponding subheading further down page) Sell-side services (text should be anchor-linked down to corresponding subheading further down page) Post transaction services (text should be anchor-linked down to corresponding subheading further down page) Restructuring and bankruptcy services (text should be anchor-linked down to corresponding subheading further down page) Deal structuring and due diligence Deloitte’s M&A professionals provide corporate clients and private equity investors with a spectrum of tax advisory services. Our multifunctional approach teams these professionals with industry and technical specialists to provide assistance and advice targeted toward managing tax compliance risk and enhancing business returns. We analyze and quantify industry-, country-, and deal- specific tax risks and opportunities; analyzing asset quality; and potential hidden costs, contingencies and commitments and help to develop negotiating positions. We suggest alternative tax structures and prepare formal tax structuring memoranda and pro forma financial statements that illustrate the effects of various structuring alternatives on future cash flows and earnings. Back to top Sell-side services We help analyze potential tax, accounting, labor, operational, and system issues before going to market. We work with clients to analyze whether the transaction structure is in line with company strategy, and quantify the strategic value of tax risks and opportunities. We perform pre-sale due diligence including analysis of tax financial and regulatory matters, review of compensation-related agreements, and analysis of information quality. We also know that the tax considerations of a deal can be simple or complex and will vary depending on the nature of the deal. We can assist and advise clients regarding estimated gains and losses, analyze the allocation and preservation of tax attributes, and explore tax structures that address clients’ goal for cash proceeds from the deal. Our professionals can help clients navigate deal execution and work closely with their team and other advisors to enhance efficiency of effort and knowledge transfer. Back to top Post transaction services For both acquisitions and separations, our team provides a holistic approach that can help tax departments address its Day 1 readiness needs as well as its longer term requirements. This includes advising on a variety of tax issues, such as addressing regulatory, tax planning and compliance matters; simplifying corporate tax structures, especially where overlapping legal entities arise; harmonizing accounting methods; and merging tax systems, processes, and departmental personnel. We work with the tax function to explore tax opportunities that arise as part of the company’s overall merger synergy efforts, whether those changes arise in supply chains, sales force organization, back-office operations, or other areas. Back to top Restructuring and bankruptcy services We work with financially challenged companies by analyzing relevant tax issues and financial considerations, assisting in evaluating restructuring options, and exploring planning opportunities that address those tax and financial burdens, while building a framework allowing for future tax efficiencies. Our professionals have extensive experience working with debtors, creditors, and creditor committees with respect to both in–court and out-of-court restructurings. We also work with clients’ other professional advisors to pursue favorable business and tax results. Back to top 19 Private company services Private companies face a range of challenges that affect not only the success of the business enterprise, but also the professional and personal goals of their owners. Whatever the end goal — an IPO, expansion into new markets, succession to a family member, or sale — integrated tax planning is critical. Deloitte help private companies, their owners, and individuals with substantial assets apart from businesses they directly operate to understand, plan and execute effective business and tax strategies — altering course when needed to respond appropriately to potential tax consequences of new legislation and evolving market conditions. Our services include: Income tax planning and compliance for private companies and their owners (text should be anchor-linked down to corresponding subheading further down page) Comprehensive owner and family wealth planning (text should be anchor-linked down to corresponding subheading further down page) International tax and estate planning (text should be anchor-linked down to corresponding subheading further down page) Family office services (text should be anchor-linked down to corresponding subheading further down page) Income tax planning and compliance services for private companies and their owners Ongoing legislative and regulatory changes, along with an increased tax authority focus on high-wealth individuals, create a demanding environment for private companies and owners to proactively manage their tax liabilities and risks. Deloitte is experienced in addressing the complex relationships among the private business enterprise, its owners, family offices, and employees of the business enterprise or family office. Deloitte helps private companies and their owners evaluate the potential tax consequences of various business and personal wealth decisions, keeping tax, business and personal objectives in mind. Deloitte can help explore tax-savings opportunities, prepare for changes in the tax and economic climate, and help resolve disputes with tax authorities. Back to top Comprehensive owner and family wealth planning Individuals and families with substantial assets often face difficult decisions associated with protecting and extending their legacy. Deloitte is experienced in addressing the many facets of wealth planning for private company owners and their families. Our professionals assist private business owners in exploring the issues relevant to wealth preservation and the transmission of wealth to future generations. Deloitte’s estate tax planning specialists work closely with the private client’s other professional advisors to address the complex issues involved in estate, gift, inheritance, trust, and charitable planning and to develop and implement an estate plan tailored to their needs. Back to top International tax and estate planning Increased mobility among high net-worth individuals and families has coincided with the broad expansion of a globally integrated economy — featuring greater cross-border trade and investment — to create an increasingly complex range of global tax issues. Deloitte professionals work closely with clients to address issues of tax residency and domicile and to assess the tax aspects of international investment opportunities. We provide multijurisdictional tax and estate planning advice, taking into consideration family mobility, wealth planning and preservation goals, the nuances of investing in specific countries and asset types, and the tax consequences to the family’s private business enterprises. Back to top Family office services Effective family wealth management encompasses a range of issues related not only to business aims, but also personal and family goals. Wealthy families often consider establishing a family office to manage their many investments, reporting, philanthropic, and financial planning responsibilities. Properly structuring and staffing a family office requires an analysis of tax and governance considerations, as well as a deep understanding of the family’s short and long range business and professional goals and objectives. Deloitte professionals can assist 20 with family office design and set-up, family education and communications, charitable planning and private foundations, and structuring business investments. Our approach addresses both the family office as a business and the private client’s family wealth as an ongoing enterprise. Back to top 21 Research & development and government incentives Many countries offer generous grants, credits and incentives in areas such as the digital economy, energy efficiency, environment, globalization, innovation, sustainability and training. More than 30 countries also offer specific research and development (R&D) tax incentives that apply to development activities related to manufacturing process improvements, production trials and software integration issues in addition to laboratory research. Taking advantage of incentives creates an immediate cash benefit, often reducing effective tax rates and increasing EPS. Our services include: Research & development claims preparation (text should be anchor-linked down to corresponding subheading further down page) Government incentives application support (text should be anchor-linked down to corresponding subheading further down page) Tax controversy related to R&D or government incentives (text should be anchor-linked down to corresponding subheading further down page) Research & Development claims preparation Identifying eligible R&D activities and preparing robust supporting documentation is often unfamiliar territory or you may not have the resources to complete the paperwork required to file a claim. Deloitte can assist with the whole process from scoping through document preparation and submission. Deloitte combines deep tax technical expertise with highly experienced scientists and engineers to help ensure all aspects of an incentive claim are fully understood and considered. We utilize technology based solutions worldwide to ensure a smooth process with increased transparency and compliance with all regulatory changes. Back to top Government incentives application support Ensuring that you equitably receive your fair share of the numerous grants, credits and incentives available requires time and effort. The Deloitte team is highly experienced in the practicalities of preparing, negotiating and agreeing such applications including all aspects from initial feasibility reviews to document submission. Deloitte’s knowledge in this specialized area ensures that we understand and evaluate all the nuances and details of specific opportunities and allows you to be confident you have realized your potential benefits for the least amount of time, effort and expense. Back to top Tax controversy related to R&D or government incentives R&D claims and Government Incentive applications often receive intense regulatory scrutiny. Deloitte provides assistance in audit resolution as well as support related to claims and information requests or objections from relevant government bodies. This team includes former officials with various regulatory agencies who have an in depth understanding of the regulatory processes for approval. Deloitte delivers an inside out perspective and you can be confident you are receiving sound advice. Back to top Business Process Services Incentive We can help you to derive an investment grant from The Department of Trade and Industry’s Business Process Services Incentive – set up to attract investment and create employment in South Africa, through off-shoring activities Read more 22 BPS Investment Incentives The South African government’s up-scaled Industrial Policy Action Plan (IPAP) has identified the Business Process Services (BPS) as a key sector for investment attraction and job creation. The BPS Investment Incentives comprises a base incentive and a graduated bonus incentive. The base incentive grant is calculated on projected offshore jobs to be created based on a tapering scale, and the grant is awarded on actual offshore jobs created. The grant ranges from R112 000 per offshore job created within the DTI’s 2011/12 financial year, R104 000 per offshore job created within the DTI’s 2012/13 financial year and R88 000 per offshore job created within the DTI’s 2013/14 financial year. The bonus incentive is available to applicants who create more than 400 offshore jobs. It is divided into two components: Greater than 400 but less than or equal to 800 - Incentive amount is the base incentive for all jobs, plus 20% bonus for the number of jobs that exceed 400 Greater than 800 - Incentive amount comprises of the base incentive for all jobs, plus 20% bonus for the number of jobs that exceed 400; and an additional 10% bonus for the number of jobs that exceeds 800 The objective of the incentives is to attract and create employment in South Africa, through off-shoring activities. The BPS Investment Incentives are effective from 01 January 2011 up to 31 March 2014. How you could qualify for BPS investment Incentives Mandatory requirements: The applicant must be a registered legal entity in South Africa. The applicant must be a taxpayer in good standing and provide a valid tax clearance certificate The applicant must be performing BPS activities The applicant must submit an application for the BPS incentive prior to the commencement of operations Other requirements which the DTI will use to determine whether an applicant is eligible to benefit from the BPS incentive Our services Deloitte has built up a reputation as the most comprehensive service provider in South Africa as we offer advice on all the incentives currently on offer by the South African government. Our experience ranges from: Assisting with the initial design of the incentives, Providing advisory opinions to new investors (local and foreign) on the incentives, Assisting clients to access the funding by completing the application, auditing claims and submitting various claims. Dealing with disputes on the incentives in respect of the interpretation of the criteria Private Sector Infrastructure Grants We’ll help you to optimize available incentives for investment in physical infrastructure required to service a new investment or the expansion of an existing investment. Read more 23 Private Sector Infrastructure Grants When you embark on new or expanded operations, our services can assist you to secure and maximize the various infrastructure grants on offer from national, provincial and local government in South Africa. We have proven ourselves to be a recognized leader in providing these grant and tax incentive services to various sectors. We are currently the only one of the “Big Four” professional services organizations in South Africa with a dedicated incentives division. Our proven methodology gives us the capability to streamline your processes to successfully address your infrastructure grant and incentive potential. The scope of possibility for your company The Critical Infrastructure Program (CIP) is a cash grant incentive that covers between 10% and 30% of the construction cost for the development of critical infrastructure to support strategic investment projects in South Africa. CIP funding is available to private sector enterprises, local or provincial government authorities, public enterprises, or a combination of the above through Private Public Partnerships. Key services that we offer you We are able to assist you in deriving benefits from the CIP in the following ways: Advisory opinions on the various manufacturing grants, R&D incentives and other incentives on offer Preparation of claims and progress reports Submission and liaising with Department of Trade & Industry or other relevant authorities. Our approach We take an in-depth approach to this with you, starting with initial meetings and interviews to assess your infrastructure grant opportunities, and ways in which you can maximize grant funding. We do detailed assessments of the feasibility of your new investment projects in terms of opportunities and risks, and provide you with recommendations. Once all of this has been identified, we assist you with the preparation of grant funding applications. And then we go a few steps further… We advise you on how to develop management capacity and design systems for effective monitoring and reporting, to help ensure that all statutory requirements continue to be met. We provide you with ongoing project management support to help ensure effective project implementation. We also help you with the preparation of claims and progress reports. Public Sector Infrastructure Grants In this sector we assist local and provincial government to optimize available incentives for investment in physical infrastructure. Read more Public Sector Infrastructure Grants 24 If you’re a government organization that is expanding your infrastructural investment or making a new investment in infrastructure, we are able to help you to derive maximum benefit from the various infrastructure grants that will be available to you. We have proven ourselves to be a recognized leader in providing these grant and tax incentive services to various sectors. We are currently the only one of the “Big Four” professional services organizations in South Africa with a dedicated incentive division. We are able to help you streamline your processes so that you can realize your infrastructure grant potential, using our proven methodologies. Grants that can be available to you The Critical Infrastructure Program (CIP) is a cash grant incentive that covers between 10% and 30% of the construction cost for the development of critical infrastructure to support strategic investment projects in South Africa. CIP funding is available to local or provincial government authorities and public enterprises, or a combination of these when partnered with private sector enterprises through Private Public Partnerships. Other infrastructure grants available to municipalities include: Municipal Infrastructure Grant (MIG); National Electrification Program; Critical Infrastructure Program; Public Transport Infrastructure and Systems Grant; Neighbourhood Development Partnership Grant (NDPG). The services that we can offer you We can help you to obtain benefits from the CIP and other infrastructure grants in the following ways: Advisory opinions on the various manufacturing grants, R&D incentives and other incentives on offer Preparation of claims and progress reports Submission and liaising with Department of Trade & Industry or other relevant authorities. Specialized project management ensuring effective project implementation and accounting Our approach We take an in-depth, full-cycle approach, beginning with initial meetings and interviews with key people in your organization to assess the infrastructure grant opportunities available to you, and to discover how you can maximize grant funding. We undertake detailed feasibility studies of your new investment projects to identify opportunities and risks, and generate recommendations for you. We then help you with preparing your grant funding applications. We continue to work with you throughout the life-cycle of your projects. This includes providing advice on developing management capacity and design systems to enable to you effectively monitor and report on the projects, so that you can be confident of meeting the regulatory requirements. We also assist you with preparing progress reports and grant claims. Industrial Policy Tax Incentive We have a full service offering to assist you to optimize the tax deductions available from government’s proposed Industrial Investment Allowance and employee training allowances. These include an additional tax allowance of up to 55% of the cost of your manufacturing assets that you use in a qualifying industrial policy project. Training allowances up to R30 million will also become available. 25 Read more Industrial Policy Tax Incentive Government has allocated a new tax investment incentive - the Industrial Policy Tax Incentive - to encourage investment in large projects. This takes the form of an Industrial Investment Allowance, plus additional employee training allowances for Greenfield or Brownfield industrial policy investment projects. Projects can be allocated points based on certain criteria, and you can claim tax incentive benefits based on these points. Project points are adjudicated by a committee made up of representatives from the Department of Trade and Industry (DTI), SARS and the National Treasury. How you could qualify for Industrial Policy Tax incentives Industrial Policy Tax Incentive points are allocated to projects that: Upgrade an industry in South Africa by using innovative processes or new technology resulting in improved environmental protection Generate general business linkages by acquiring goods and services from small, medium and micro enterprises Create direct employment Promote skills development Are located in an IDZ Companies can derive an additional tax allowance of 55% of the cost of any manufacturing asset that is used in a qualifying industrial policy project that is determined to have preferred status; or 35% of the cost of any manufacturing asset used in any other qualifying industrial policy project. The latter can amount to up to R900 million for a Greenfield project and R550 million for a Brownfield project. Our services We can help you derive these tax incentives by teaming with you on all steps of the process. This can include providing advisory opinions on the various incentives (for both local and international investors), assisting you to access funding by completing applications and claims, auditing and submitting claims, and liaising with the DTI or other relevant authority on your behalf. The process we follow involves initial meetings and interviews with appropriate people in your organization to assess the Industrial Policy Tax Incentive grant opportunities available to you and to develop a strategy to maximize your grant funding. This is followed by detailed assessments of your new investment projects, from which we generate recommendations on how to optimize your grants. Once the projects are underway, we help you to set up processes and systems to manage, monitor, and report on the projects in terms of the grant requirements. We also assist you with preparing and submitting progress reports and claims. Enterprise Investment Program This will help you to optimize opportunities available under the Manufacturing Investment Growth Program and the Tourism Investment Growth Program. Read more Enterprise Investment Program 26 We can assist you with a wide range of incentive services around the government Enterprise Investment Program (EIP). These include securing and maximizing all incentives and grants on offer from various authorities, especially from the Department of Trade and Industry (DTI). The EIP incentives comprise two different investment programs: the Manufacturing Investment Program and the Tourism Support Program (TSP). The MIP covers all manufacturing sectors, with separate regulations for the textiles and clothing industry. The main qualifying criteria for projects are that they promote substantial investment, increase employment opportunities, and sustain growth. The incentives are a tax exempt cash grant of up to 30% towards qualifying investment costs over 3 years (for investments from R5 million to R30 million), or up to 15% up to a maximum of R30 million for investments from R30 million to R200 million, payable over 2 years. Foreign Investment Grant (FIG) Foreign investment projects may qualify for an additional grant for the cost of transporting qualifying machinery and equipment into South Africa. This grant covers the lower of 15% of the value of qualifying imported machinery and equipment or the actual transport costs of relocating the machinery, to a maximum of R10 million. What we’ll do for you Our specialist tax incentive expertise and our good relationship with the DTI and other authorities make it possible for us to provide you with advice that can help you to identify qualifying projects and successfully claim grants for these. We help you with the full cycle, from initial assessment through to the submission of applications and claims. We’ll also assist you in setting up monitoring and reporting processes for your projects, to help ensure that they remain in compliance of the regulations so that you actually get the grants that you have targeted. We will also team with you in liaising with the DTI on your applications. National Industrial Participation Program This is a comprehensive package that will assist you in managing your obligations under the National Industrial Participation Program, which arise from the provision of imported goods and services to governmental organisations. Read more National Industrial Participation Program We will assist you in structuring your operations so as to minimize your costs of compliance with the National Industrial Participation Program (NIPP). Your company will be subject to NIPP regulations under certain specific conditions. These are if you have won a government or parastatal contract to supply or lease goods that have an imported content of US$10 million or more, or if you have won such contracts to the same cumulative value over a 2-year period. What we’ll do for you We will assist you with the design of significantly oriented investment projects and help you to package them in ways that are attractive and relevant to the Department of Trade and Industry (DTI). We do this in a way that minimizes your cost of compliance. We can go further than that, however. We’ll help you to align your company strategy as a whole with the NIPP strategy. This will go a long way to ensuring that your NIPP investment projects are congruent with your normal business operations. We’ll help you with the administrative aspects of your NIPP investments. This includes updating the Industrial Participation Secretariat of the Department of Trade and Industry on the progress of your NIPP projects. We will also audit these, which is an intrinsic NIPP requirement. If you prefer, we will also accept the management or outsourcing of your entire NIPP project. 27 Tax management consulting In an increasingly demanding global environment, managing tax responsibilities and planning for tax issues is becoming more complex. With tax technical, technology, and consulting experience, Deloitte helps businesses meet the challenges of multijurisdictional tax operations, including compliance, reporting and risk management for direct and indirect taxes. We help clients transform processes and technology to enhance efficiencies, align data, and improve transparency from ERP systems all the way through the reporting and documentation process. This allows more time for tax planning and value-add activities. Our services include: Tax accounting and reporting (text should be anchor-linked down to corresponding subheading further down page) Global compliance outsourcing (text should be anchor-linked down to corresponding subheading further down page) Risk, strategy and operations (text should be anchor-linked down to corresponding subheading further down page) Tax-enabled enterprise resource planning (ERP) (text should be anchor-linked down to corresponding subheading further down page) Compliance process automation (text should be anchor-linked down to corresponding subheading further down page) Tax data analytics (text should be anchor-linked down to corresponding subheading further down page) Learn more at www.deloitte.com/movetaxforward. Tax accounting and reporting Overreliance on spreadsheets, outdated technology, and lack of integration between tax and finance systems hamper tax departments’ ability to obtain and analyze the data they need for timely and accurate tax accounting and reporting. Deloitte provides tax application consulting related to the selection and implementation of software supporting financial accounting for tax (provision) for global and local financial operations. We help tax departments with tax accounting and reporting processes, provision-to-return reconciliations, mitigation, and process improvement to correct or avoid material weaknesses and significant deficiencies. In addition, we advise on tax policies and procedures as well as technical aspects related to provision and the review of internal controls to enhance governance and address compliance and reporting risk. We can develop management reporting desktops and tax database repositories. Back to top Global compliance outsourcing Organizations with operations in multiple jurisdictions face tremendous challenges in keeping pace with each jurisdiction’s tax laws. For this reason, they often turn to Deloitte for global and local tax outsourcing of direct and indirect tax compliance, as well as statutory accounting and report processing. With shared services and data management skills, our team can support local, near shore and offshore compliance activities. We also assist in special situations, such as post-merger integration, which requires substantial system, process, and technology support for newly created organizations in addition to the outsourcing of tax compliance. Back to top Risk, strategy and operations Risk intelligent tax departments integrate business strategy and risk management into their operations. Deloitte helps organizations’ tax departments align tax operations to the business strategy often times in conjunction with their finance transformation efforts. Services include evaluation of organizational models, roles and responsibilities; skills assessment; performance measurement; and analysis of governance and controls within a tax department. We also assist with the integration of processes among tax planning, tax compliance and tax audit, which can include determining whether appropriate key performance indicators for performance management are in place. Back to top Tax-enabled enterprise resource planning (ERP) 28 Integration of tax data requirements into enterprise resource planning (ERP) systems is increasingly critical for tax departments to operate effectively and obtain the tax-sensitized data needed for accounting and tax reporting purposes. With tax technical and technology experience, we help organizations tax enable their ERP systems, based on the data and information requirements for the entire record-to-report cycle for tax. Our consulting encompasses direct and indirect tax requirements and the related data to support tax planning, compliance and tax audits on a global basis. We also assist with data retention, document management, and the prioritization of controls. Back to top Compliance process automation Tax departments face significant resource constraints, requiring an increased focus on efficiency and effective use of software and technology to streamline their compliance process. Our team consults on design, vendor selection, and implementation of tax software for global and local purposes for both direct and indirect taxes. Services include integrating software and technology through the entire record-to-report business cycle for tax. Solutions include enterprise systems, middleware, tax applications and management reporting dashboards. Back to top Tax data analytics Tax information is increasingly important to management’s ability to plan and forecast. Our Tax Management Consulting team can help your organization leverage data analytics for tax and assess the data and information required to support these efforts. In addition, we can help your organization gain insights into past tax performance and how tax technologies, applications, and leading practices can help your tax department plan and executive tax strategy more effectively. Back to top 29 Transfer pricing Multinational organizations are operating in an environment of unprecedented complexity. The rising volume and variety of intercompany transactions and transfer pricing regulations, accompanied by increased enforcement activities worldwide have made transfer pricing a leading risk management issue for global businesses. The goal of the Deloitte globally-managed transfer pricing network is to help companies reduce risks by aligning practical transfer pricing solutions with their overall global business operations and objectives, assist with strategic documentation to support their transfer pricing practices, and resolve disputes efficiently. Deloitte has a well-earned reputation for quality and delivering results. Our services include: Transfer pricing planning and documentation (text should be anchor-linked down to corresponding subheading further down page) Dispute avoidance: Advance pricing agreements (text should be anchor-linked down to corresponding subheading further down page) Dispute resolution: Examination defense and mutual agreement procedure/competent authority (text should be anchor-linked down to corresponding subheading further down page) Business model optimization (text should be anchor-linked down to corresponding subheading further down page) Transfer pricing planning and documentation Multinational businesses are expanding the volume of related-party transactions and continuously improving supply chains. This coupled with increased tax authority collaboration across borders presents both risks and opportunities. Deloitte provides practical solutions such as strategically approaching transfer pricing documentation requirements, which enable global businesses to achieve operational and international tax planning objectives. For multi-country projects Deloitte has a Global Transfer Pricing Center, that includes economists, tax professionals and MBAs who have on-the-ground international transfer pricing experience and specialize in Europe, the Americas or the Asia Pacific region. This centralized, global approach facilitates uniformity of reporting and eliminates internal inconsistencies which can arise from multiple service providers, thereby making the process more effective and efficient and easier to successfully defend. Back to top Dispute avoidance: Advance pricing agreements (APAs) Transfer pricing presents many tax, legal and operational challenges. To many taxpayers the magnitude of uncertainties – including the potential commitment of management time to successfully defend a transfer pricing examination – is not an acceptable business risk. APAs allow taxpayers to proactively achieve greater certainty via advance agreements on their transfer pricing methods with one or more tax authorities. Deloitte’s experience with the APA process spans the entire history of all the national programs. Our historical knowledge of how to achieve successful results helps companies manage their transfer pricing issues – particularly the risk of double taxation – on a prospective basis. Back to top Dispute resolution: Examination defense and mutual agreement procedure/competent authority (MAP/CA) Missteps that affect the course or outcome of a transfer pricing examination often occur in responses to the initial tax authority enquiries and interviews. The most effective and efficient defenses include early involvement of an experienced global team that has successfully resolved examinations at all possible levels of the process, from proposed adjustments by field agents, through Advance Pricing Agreement, administrative appeals, litigation and the MPA/CA process. Deloitte takes an integrated approach to resolving transfer pricing disputes in the MAP/CA process. Our teams include transfer pricing MAP/CA specialists from both countries teamed with professionals who specialize in local country requirements for indirect taxes, taxes imposed by local or state/provincial jurisdictions, international tax and interest calculations for late payment that invariably affect the outcome. Back to top Business model optimization (BMO) 30 The global economic environment is characterized by continuous improvements in technology, urgency to adopt and implement best practices and processes, and the potential for legislative changes. Assessing a multinational’s global business model is no longer an optional exercise. Business Model Optimization (BMO) is the process of balancing the demands of operations and tax law and integrating them into the business model. This helps ensure tax planning does not curtail the bottom line and that the business model does not surrender some or all of the value it creates. Deloitte provides high quality, customized tax and BMO services that focus on helping multinationals integrate operational and tax planning in a scalable and sustainable way in order to enable business leaders to make more effective decisions on an after-tax basis. Back to top 31