Exit tax
Shareholdings, hidden reserves, timing and deferral options must be reviewed before residence changes.
Tax Risks
Three tax traps often decide whether a foundation or holding structure is robust.
A structure may look elegant in an organisation chart but fail if exit tax, transfer of functions, withholding tax or treaty limitations are not reviewed before implementation.
Risk areas
Transfer of functions and assets
Moving functions, IP, management or value drivers may trigger taxable exit or transfer-pricing issues.
Withholding tax and treaty-shopping
Dividends, interest, royalties and management fees require beneficial ownership, substance and treaty analysis.
Why early review matters
- Late corrections are often more expensive than an early implementation sequence.
- Banking, tax filings and legal documents must not tell different stories.
- A binding ruling or local opinion may be useful where the legal position is material and uncertain.
- Documentation should distinguish assumptions, facts, legal conclusions and open risks.
Practical output
- Risk matrix with likelihood, impact and next step.
- Sources and treaty map for payments.
- Implementation sequence before relocation or transfer.
- Document list for advisers and local professionals.