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Tax structuring service

International tax structuring

The international dimension of taxation is becoming increasingly important to global multinationals, family offices, trusts and HNWIs as they seek to expand into new jurisdictions and might have multiple tax residence . We assist clients in optimising their global tax structures, managing global tax risks and capitalising on tax planning opportunities. Our services span a broad range of issues, including tax-efficient ownership, competitive cross-border financing and treasury solutions, profit repatriation and loss utilisation, in-bound and out-bound structuring, and developing efficient management structures, etc. The following are areas which we have found increasingly valuable to clients. 

International group reorganisations

With jurisdiction-specific taxation and corporate-regulatory developments continuously occurring, multinational groups must remain flexible and able to adapt promptly to the changes in the worldwide marketplace that are outside their control. Our global reach and expertise in the fields of tax planning and corporate structuring enable us to design the group structure most beneficial to each client and their business.
 

International trading structuring

Globalisation in international trade has increased competition but also provided new opportunities for entrepreneurs to structure their trading businesses efficiently. We are well positioned to advise clients on optimum and tax efficient structures to make the best of their trading businesses.
 

Analysis of clients’ businesses and markets, looking at individual country corporate tax rates and using international Double Taxation Agreements effectively is all part of the initial assessment we will make for every client.

The use of respected, well-regulated and tax-favoured jurisdictions in international trading to open branches, subsidiaries or stand alone trading companies offer opportunities for the international trading needs of today’s businesses. We will seek optimum solutions and tax efficiency for its clients. This is essential for competitiveness in a global marketplace where competitors constantly seek out every cost and strategic advantage.
 

Investment holding & wealth management structures

A key component for effective investment and holding structures for wealth management is the establishment of companies, partnerships and/or trusts. These are commonly established for asset protection purposes but, if properly implemented, can also serve to mitigate tax liabilities. Holding companies for equity investments can be particularly tax efficient if the optimal jurisdiction is chosen to eliminate withholding taxes on income and taxes on gains derived from shareholdings.

Whether a client requires advice on how to structure an investment in a foreign trading company, a holding structure for liquid assets, a portfolio of real estate or luxury yachts and aircraft, we bring our experience to advise on the most suitable and efficient structure. Tax consultancy expertise and a commitment to providing the highest level of quality and personalised service are skills we deliver to each client’s unique scenario.

From advice on investment holding to implementation and execution. 
 

Intellectual property structuring & exploitation

We have extensive experience in the structuring of intellectual property management activities. Whatever the intellectual property is and wherever it is utilised, we design and implement the most efficient structures for the effective management of the products of our clients’ ingenuity. Our advice often focuses on structuring cross-border royalty flows to ensure minimal tax leakage. Our knowledge of tax-favoured intellectual property regimes in various jurisdictions is combined with expertise in tax treaty planning to produce a highly tax-efficient structure tailored to each client’s specific circumstances.

Image rights are an individual’s proprietary rights in the use of their image and other unique characteristics of their personality. These rights can be of enormous financial value to celebrities such as sportspeople and actors, as well as to the businesses who would wish to use the image of such recognisable persons to market their products. We have assisted many clients with tax planning to ensure the most efficient flow of revenue from their image rights. This may include the licensing of image rights to a dedicated corporate structure capable of protecting those rights as well as tax treaty planning to minimise the burden of withholding taxes in cross-border transactions.

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