Structure Review
Documents needed for a reliable structure review.
A structure review should start with an orderly picture of the facts, not with a ready-made solution. Relocation, formation, foundations, holdings, banking and KYC require a combined view of persons, entities, assets, contracts, tax positions and funds flow.
Persons and residence
- Persons involved, including residence, citizenship, habitual abode and planned changes.
- Roles such as shareholder, director, founder, council member, protector, beneficiary and beneficial owner.
- Existing immigration, visa, tax residence or relocation documents.
- Family and succession context where relevant for foundations, beneficiaries or future distributions.
Companies and participations
- Organisation chart with shareholdings, voting rights, veto rights and control routes.
- Register extracts, articles, shareholders' agreements, constitutional documents and resolutions.
- Financial statements, tax filings, valuations and participation history.
- Information on management, actual decision locations, people, premises and service providers.
Assets and origin
- Overview of participations, real estate, bankable assets, securities, digital assets and loans.
- Evidence of wealth creation, including sale proceeds, dividends, salary, inheritance, gifts, business profits or investments.
- Evidence of specific funds movement, including bank statements, purchase agreements, loans, distributions, contributions or transfers.
- Documentation whether assets are held privately, through companies, through a foundation-related structure or on a fiduciary basis.
Tax and structure questions
- Relocation, exit tax, extended limited tax liability and continuing domestic interests.
- CFC matters, passive income, substance, effective management, permanent establishment and treaty issues.
- Contributions, share-for-share exchanges, holding structures, lock-up periods, valuation and evidence duties.
- Charitable status, asset dedication, use of funds, beneficiaries and ongoing governance.
Outcome
- Prioritised document list instead of broad document requests.
- Risk matrix with open tax, legal, banking and organisational points.
- Decision basis for formation, relocation, foundation planning, holding structures or bank contact.
- Clear line between general assessment and matters requiring local professional review.