International tax, with Pillar Two in the foreground.
Cross-border structuring, treaty access, Pillar Two readiness and transfer pricing - coordinated from a single UK-led team.
International tax is now about substance, not structure.
The global tax environment has shifted from structuring games to substance tests, BEPS disclosures and Pillar Two top-up calculations. Our international tax work focuses on keeping clients defensibly compliant while preserving legitimate planning outcomes.
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.
Pillar Two readiness
- Top-up tax exposure modelling
- Transitional CbCR safe harbour
- QDMTT and UTPR planning
- Group accounting impact
Treaty planning
- Treaty eligibility reviews
- Withholding tax optimisation
- LOB and PPT considerations
- Tie-breaker planning
PE risk
- Permanent establishment reviews
- Dependent-agent analysis
- Virtual PE exposure
- Remote-work risk mapping
Transfer pricing
- Documentation files
- Benchmarking studies
- APAs and MAP procedures
- Intangible migration review
“Aureliant turned Pillar Two from a compliance crisis into a boardroom item with a scoped plan and a numeric answer.”
Pillar Two on your audit committee agenda?
A three-week scoping exercise will tell you whether you are in scope, where your top-up tax sits, and what you need to say to auditors.