Tax structuring is not about minimisation at any cost - it is about aligning commercial flows with the rules in a way that withstands audit scrutiny. We
Tax Law & Tax Structuring covers legal assessment, document preparation and implementation support in Europe. It is typically relevant to businesses, investors and organisations operating or transacting in one or more countries. The precise rules, competent authority and procedure depend on the subject matter, jurisdiction and facts, with EU and national law considered together.
The applicable framework depends on the subject of the service, governing law and countries in which the structure or transaction has effect. EU law and current national legislation are assessed together.
Tax structuring is not about minimisation at any cost - it is about aligning commercial flows with the rules in a way that withstands audit scrutiny. We advise multinational groups, investment funds, and private clients on corporate-income tax, withholding tax, VAT, and transfer pricing, ensuring every structure satisfies substance-over-form tests and anti-abuse provisions.
We analyse how domestic tax codes interact with applicable double-taxation treaties and EU instruments - Parent-Subsidiary Directive, Interest & Royalties Directive, ATAD I & II - to design holding, financing, and IP-migration structures that are both efficient and defensible.
When disputes arise, we represent clients through tax audits, advance-ruling requests, mutual-agreement procedures, and court proceedings, drawing on deep familiarity with how tax authorities in the relevant jurisdictions approach aggressive or novel structures.