Sustainability and defence of principal company structures

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Sustainability and defence of principal company structures

The concept of a principal company structure (PCS) is far from new, yet national tax regimes are increasingly targeting these structures for enhanced and aggressive scrutiny. While this increased scrutiny is not limited to Swiss-based PCSs, Carl Bellingham and John Lindstrom of PwC warn that tax authorities may focus on a Swiss-based PCS due to the sheer number of such structures in Switzerland.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login
more across site & shared bottom lb ros

More from across our site

The US president has softened his stance on tariffs over Greenland; in other news, a partner from Osborne Clarke has won a High Court appeal against the Solicitors Regulation Authority
Emmanuel Manda tells ITR about early morning boxing, working on Zambia’s only refinery, and what makes tax cool
Hany Elnaggar examines how AI is reshaping tax administration across the Gulf Cooperation Council, transforming the taxpayer experience from periodic reporting to continuous compliance
The APA resolution signals opportunities for multinationals and will pacify investor concerns, local experts told ITR
Businesses that adopt a proactive strategy and work closely with their advisers will be in the greatest position to transform HMRC’s relief scheme into real support for growth
The ATO and other authorities have been clamping down on companies that have failed to pay their tax
The flagship 2025 tax legislation has sprawling implications for multinationals, including changes to GILTI and foreign-derived intangible income. Barry Herzog of HSF Kramer assesses the impact
Hani Ashkar, after more than 12 years leading PwC in the region, is set to be replaced by Laura Hinton
With the three-year anniversary of the PwC tax scandal approaching, it’s time to take stock of how tax agent regulation looks today
Rolling out the global minimum tax has increased complexity, according to Baker McKenzie; in other news, Donald Trump has announced a 25% tariff on countries doing business with Iran
Gift this article