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01 — Legal

International tax planning

Build a tax-efficient structure that can stand up to review.

We help founders, investors, companies and private clients plan international business and asset structures with tax, legal, banking and compliance risks in mind.

Our work covers jurisdiction analysis, corporate structuring, tax residency issues, double taxation, cross-border payments, dividend planning, substance requirements, reporting obligations and coordination with local tax advisers.

The objective is not only to reduce unnecessary tax exposure where legally possible, but also to create a structure that is practical, documented and defensible before banks, auditors, tax authorities, investors and regulators.

Tax risk follows the real business, not just the company registration

Registering a company in a low-tax jurisdiction does not automatically create a safe or efficient tax structure. Tax authorities, banks and auditors increasingly look at the real substance of the business:

  • Where management decisions are made
  • Where directors and owners are tax resident
  • Where clients and suppliers are located
  • Where revenue is generated
  • Where employees and contractors work
  • Where intellectual property is created and used
  • Where bank accounts and payment flows are located
  • Whether the structure has commercial logic
  • Whether reporting obligations are properly fulfilled

We help clients design structures that take these factors into account from the beginning.

What a well-designed structure delivers

Tax planning is about more than rates — it is about certainty, defensibility and readiness for the next stage.

01

Lower unnecessary tax friction

A well-designed structure may reduce avoidable tax costs, withholding tax, double taxation, inefficient dividend routes and poorly documented cross-border payments.

02

Improve legal and tax certainty

International tax planning helps clarify where taxes may arise, which company earns which income, how profits are distributed and what documents support the structure.

03

Avoid double taxation

Where several jurisdictions are involved, the same income may be exposed to tax more than once. We help analyze treaty access, withholding tax, tax residency and reporting obligations.

04

Support banking and compliance

Banks and payment providers often ask why a company is registered in a particular jurisdiction, where it operates, where tax is paid and why payments flow through specific entities. A clear tax structure makes this easier to explain.

05

Prepare for growth, investment or relocation

Tax planning becomes especially important before scaling internationally, opening new entities, bringing in investors, relocating founders, distributing dividends or selling a business.

When clients ask for this service

Typical moments where an international tax structure needs design or review.

The company operates internationally

The business receives income from several countries, pays contractors abroad, works with international clients or uses foreign banks and payment providers.

The founder is changing tax residence

A move to another country can affect personal income tax, dividend taxation, corporate tax residence, controlled foreign company rules and reporting obligations.

The company needs a holding structure

A business may need a holding company for shares, intellectual property, investments, real estate or international expansion.

The business pays dividends or royalties

Dividend, royalty, licence fee, management fee and intercompany payment flows need careful tax and documentation review.

The company has banking or compliance questions

Banks may request tax explanations, source-of-funds information, business model descriptions or confirmation of the company's economic substance.

The structure is outdated

A company created several years ago may no longer match current tax rules, banking expectations, substance requirements or the owner's residence status.

Our international tax planning work

From structure review to implementation — covering corporate tax, personal tax, treaties, VAT, substance and documentation.

01

International tax structure review

We analyze the current company structure, ownership chain, tax residence, management location, revenue sources, expenses, payment flows and reporting obligations. This helps identify tax risks, inefficiencies and areas where the structure may need improvement.

02

Jurisdiction selection

We help compare jurisdictions based on tax treatment, corporate law, reporting requirements, banking access, substance expectations, treaty network, reputation and practical maintenance costs.

We do not recommend jurisdictions based only on headline tax rates. The structure must work legally, commercially and operationally.

03

Corporate tax planning

We help design or improve the tax logic of international company structures. This may include:

  • Operating company structures
  • Holding company structures
  • IP ownership structures
  • Trading structures
  • Service company models
  • Investment vehicles
  • Dividend routes
  • Intercompany agreements
  • Management and control considerations
  • Permanent establishment risk review
04

Personal tax and founder planning

For business owners, corporate tax planning is only part of the picture. We also consider the founder's personal tax position, including:

  • Tax residence
  • Dividend taxation
  • Capital gains
  • Director fees
  • Shareholder loans
  • Controlled foreign company rules
  • Relocation plans
  • Family and succession planning
  • Reporting obligations in the country of residence
05

Double-taxation analysis

We help assess whether tax treaties may apply and how cross-border payments should be structured. This may include:

  • Dividends
  • Interest
  • Royalties
  • Service fees
  • Management fees
  • Capital gains
  • Withholding tax
  • Treaty eligibility
  • Beneficial ownership issues
  • Substance requirements
06

VAT and indirect tax coordination

For international businesses, VAT, GST, sales tax or similar indirect taxes may become more important than corporate tax. We help coordinate analysis of:

  • Place of supply
  • B2B and B2C sales
  • EU and non-EU customers
  • Digital services
  • Marketplace sales
  • Import-export transactions
  • Reverse charge mechanisms
  • Registration thresholds
  • Invoicing requirements
07

Substance and management review

Many jurisdictions require more than formal company registration. We help assess whether the structure has enough substance and management logic, including:

  • Directors
  • Office or registered presence
  • Employees or contractors
  • Decision-making process
  • Board minutes
  • Accounting records
  • Contracts
  • Local reporting
  • Business purpose
  • Economic activity
08

Documentation of tax position

A tax structure is stronger when it is properly documented. We help prepare or coordinate:

  • Tax structure memoranda
  • Business model descriptions
  • Intercompany agreements
  • Board resolutions
  • Dividend documentation
  • Loan agreements
  • Royalty or licence agreements
  • Management service agreements
  • Substance files
  • Source-of-funds explanations
  • Supporting documents for banks or auditors
09

Implementation support

Tax planning should lead to practical steps, not just a written opinion. We help coordinate implementation, including:

  • Company formation
  • Restructuring
  • Bank account preparation
  • Contract updates
  • Accounting coordination
  • Reporting calendar setup
  • Communication with local tax advisers
  • Communication with corporate service providers
  • Preparation of supporting files

Where we coordinate tax planning

We coordinate international tax planning across a wide range of jurisdictions — grouped here by region for orientation.

Middle East & Asia

United Arab Emirates

Corporate tax planning, substance review and treaty analysis for mainland and free zone structures.

Hong Kong

Tax planning for trading and holding companies, including territorial taxation and treaty access.

Singapore

Corporate structuring, holding company planning and treaty coordination for companies operating across Asia.

Qatar & Bahrain

Tax and substance planning for companies operating in the Gulf region.

China & Malaysia

Cross-border tax coordination for subsidiaries and operating entities in major Asian markets.

Europe

United Kingdom

Corporate tax planning, holding structures and treaty analysis for UK companies in international groups.

Cyprus

Holding company planning, dividend routing, IP structures and treaty network access.

Estonia, Lithuania & Latvia

Baltic corporate tax planning, distributed-profit taxation analysis and EU treaty coordination.

Spain, Portugal, Italy & France

Tax residence, dividend and relocation-linked planning for founders and companies in Western and Southern Europe.

Monaco

Personal tax and residence planning for private clients, family structures and international entrepreneurs.

Serbia & Montenegro

Regional corporate tax planning and structuring for companies serving international clients.

United States

United States

Federal and state tax structuring for US companies and subsidiaries used in international trade, IT and investment structures.

Caucasus & Central Asia

Turkey

Tax and substance planning for companies operating between Europe and Asia.

Armenia

Corporate and personal tax planning for companies, founders and relocation-linked structures.

Kazakhstan, Kyrgyzstan & Uzbekistan

Tax planning and structuring coordination for companies operating across Central Asia.

Offshore

Seychelles

Tax and substance review for offshore companies used in holding or investment structures.

British Virgin Islands

Structuring and substance analysis for BVI companies within wider international groups.

The right jurisdiction depends on the business model, client geography, tax residence, payment flows, banking needs, asset type and regulatory profile.

Lawful, cross-border and built to last

Four principles guide every international tax planning engagement.

01

Lawful planning, not artificial schemes

We focus on legally sustainable tax planning that can be explained and documented. We do not build structures whose only purpose is to hide income, mislead authorities or create artificial profit shifting without commercial substance.

02

Cross-border perspective

A tax structure must be aligned with company law, banking, accounting, reporting, immigration, asset ownership and compliance requirements.

03

Practical implementation

We help clients move from analysis to documents, registrations, accounting setup, contracts, reporting calendars and banking support.

04

Long-term defensibility

We design structures that can survive future review by banks, auditors, tax authorities, investors, buyers or counterparties.

How an engagement runs

Four structured stages from initial consultation through to implementation.

01

Initial consultation

We review the client's goals, current structure, countries involved, tax residence, business model, revenue sources and key concerns.

At this stage, we identify whether the matter requires full tax structuring, a targeted review or coordination with local tax advisers.

02

Analysis

We assess the current structure and identify tax risks, inefficiencies, reporting gaps and possible improvements.

This may include corporate tax, personal tax, withholding tax, VAT, double taxation, permanent establishment risk and substance issues.

03

Strategy

We prepare a practical tax planning strategy.

The strategy may include jurisdiction selection, restructuring steps, company formation, dividend planning, contract updates, substance measures, reporting obligations and implementation priorities.

04

Implementation

We help implement the approved strategy.

This may include company registration, restructuring documents, intercompany agreements, accounting setup, bank preparation, reporting calendar, communication with local advisers and ongoing tax coordination.

Expected outcome

A clear international tax planning roadmap

By the end of the process, the client receives a clear international tax planning roadmap. This may include analysis of the current structure, identification of tax risks, recommended jurisdictions, a proposed company or holding structure, dividend and payment flow logic, reporting and accounting requirements, substance recommendations, implementation steps, a list of documents to prepare and a coordination plan with local tax advisers. The result is a structure that is more tax-aware, better documented and easier to maintain.

Compliance note

Lawful tax planning only

International tax planning must comply with applicable tax, corporate, reporting, AML, sanctions and anti-avoidance rules. We do not assist with tax evasion, false reporting, concealment of beneficial ownership, artificial transactions, sanctions circumvention or structures designed to mislead banks, tax authorities, courts or regulators. Where a proposed structure creates legal, tax, regulatory or reputational risk, we may recommend a safer alternative or decline the matter.

Need to review your international tax structure?

Tell us where your company is registered, where you live, where your clients are located and how payments move through the business. We will review the key tax, legal, banking and reporting issues and propose a practical structure.

International legal advisory for founders, investors, and businesses operating across borders.

Contact

Office 2001-72 Prime Tower,
Business Bay,
Dubai, UAE

+971 4 000 0000

Mon–Fri, 10:00–19:00 (GMT+4)