International structures that work for a post-BEPS world.
Holding companies, IP structures and operational footprints designed around substance, treaty access and Pillar Two.
Structuring decisions are now substance decisions.
Tax-led structuring without substance rarely survives scrutiny in 2026. Our work leads with commercial substance - people, premises, decisions - and layers the tax outcomes on top. That makes structures robust to regulator, auditor and tax-authority review.
Before work begins, we clarify the operating context, governance expectations, and commercial pressures behind the brief. That gives the engagement a clear purpose before technical analysis starts.
The result is a more complete advisory view: what matters now, where risk may surface next, and how recommendations can be implemented without creating unnecessary hand-offs or ambiguity.
Scope
Clarify the decision, deadline, stakeholders, and evidence standard before work begins.
Delivery
Combine partner judgement, technical review, and practical implementation planning in one workstream.
Follow-through
Convert findings into owners, actions, and next steps that leadership can track after the session.
Structuring focal points
Cross-border reporting coordination
Entity charts, withholding, reporting calendars and OECD / local-file interfaces so structures remain operable in every jurisdiction where you file.
Citizenship & residency planning
Immigration and tax-residence planning framed around substance, treaty access and long-term compliance - not quick fixes.
Commercial analysis
Where the business actually operates, decides and creates value.
Tax overlay
Treaty access, withholding tax and Pillar Two modelling.
Substance design
People, premises, board composition and decision-making substance.
Implementation
Step plan, clearances where required, and post-implementation documentation.
Structures designed to survive scrutiny, not fashion.
We actively steer clients away from structures that rely on legal form without operational substance. The cost of defending them - or unwinding them in a future regulatory environment - almost always exceeds the short-term tax saving.
- Substance-first design
- Pillar Two modelled from day one
- Documented commercial rationale
- Auditor-ready explanation
About international structuring.
Where commercial substance supports it, yes. Where it does not, we'll advise against it.
Reviewing your group structure?
A three-week diagnostic produces a substance-first structure recommendation with quantified tax and compliance impact.