Tax robustness
Residence, exit tax, CFC rules, permanent establishments, withholding tax, treaties, transfer pricing and follow-up taxation.
Services
Services for international corporate and wealth structures.
The work combines tax analysis, formation coordination, banking preparation and ongoing structure maintenance. Recommendations must remain understandable, bankable and practically usable.
Service areas
Preparation
Structure Review Documents
Information typically needed before relocation, formation, foundation planning, holding structures, banking or KYC.
AnalysisTax Structuring
Exit tax, CFC rules, permanent establishments, place of effective management, treaty questions and documentation.
ImplementationCompany Formation
UAE Free Zone, Mainland, holding, SPV, offshore and selected international company structures.
WealthFoundations & Succession
DIFC Foundations, Liechtenstein foundations, charitable foundations, trusts and family governance.
BankingBanking, KYC & Bankability
Preparation of bankable KYC, source-of-wealth and source-of-funds materials.
OrderSubstance, Governance & Compliance
Economic substance, UBO/AML requirements, corporate housekeeping and documentation.
Special mattersDigital Assets & Crypto
Structural and tax analysis of digital assets, crypto setups and bankability.
When a review is useful
- Before formation, relocation, sale, contribution, foundation setup or bank onboarding.
- Where several jurisdictions, entities, beneficiaries, family members or asset classes are involved.
- Where an existing structure works formally but is not sufficiently documented for tax, banking or governance purposes.
- Where banks, advisers, tax authorities or service providers do not describe the same structure in the same way.
What is reviewed
Structure and control
Ownership, control, management, beneficiaries, veto rights, organisation chart and decision routes.
Bankability
Source of wealth, source of funds, beneficial ownership, purpose of the structure and plausibility for banks.
Documentation
Resolutions, contracts, register documents, tax papers, valuations, funds flow and ongoing records.
Outcome
- A clear view on whether the structure is generally robust or should be adjusted.
- Prioritised risk list for matters to resolve before implementation or bank contact.
- Document list for tax advisers, local counsel, banks and service providers.
- Implementation or review roadmap with responsibilities, open questions and next decision point.
Specialist topic library
Additional long-form pages provide the kind of topic depth expected by entrepreneurs and advisers before they ask for a confidential review.
Concept logic
Foundation, Holding and GmbH & Co. KG
Why partnership interests, holding layers, functional allocation and foundation governance must be reviewed together.
Review pathTax Risks in Foundation and Holding Structures
Exit tax, transfer of functions, withholding tax and treaty-shopping risks as practical decision areas.
Inheritance taxRelief, Linked Assets and Valuation
How administrative assets, valuation and retention periods shape succession and foundation planning.
ResidenceGlobal Tax Analysis for Relocation
Zero-PIT, territorial and special regimes assessed from a German tax perspective.
DocumentationBinding Ruling and Risk Matrix
When a risk matrix, sources matrix, document list or binding ruling is useful before implementation.
VisualsDiagrams and Review Paths
Tax maps, foundation structures, reorganisation paths, exit tax, asset protection and legal structures.
Service boundaries
- The review does not sell standardised offshore packages or isolated register products.
- A recommendation is only useful if it remains explainable to tax advisers, banks, local counsel and family decision makers.
- Where professional admission is required in a jurisdiction, the relevant tasks are handled by admitted professionals there.
- Confidentiality is part of the service: public client names, logos and identifiable case studies are not used.