Tax Structuring & Advisory

Facts before jurisdictions

We map people, functions, intellectual property, contracts, customers, wallets, payment accounts, treasury decisions and management locations before discussing a preferred jurisdiction. The tax result may depend on whether an entity is a principal, agent, custodian, broker, technology provider or issuer.

The proposed structure is coordinated with licensing, banking and substance. We consider director control, employment, premises, outsourcing, intercompany funding, transfer pricing, withholding, VAT, permanent establishment and information exchange together.

The outcome is a decision matrix and implementation file rather than a headline tax rate: a sustainable, explainable structure that can operate in reality.