Tax Law & International Tax Structuring

International tax structuring for cross-border entities requires balancing tax efficiency against substance requirements, anti-avoidance rules, and

Tax Law & International Tax Structuring covers comparative legal assessment, documentation and coordination across international jurisdictions. It is typically relevant to businesses, investors and families considering a cross-border structure or activity. There is no single offshore regime: legal effects, disclosures, taxation and permissions depend on the selected jurisdiction, relevant residence rules and the facts of each case.

Key points

  • There is no single international or offshore legal regime.
  • Rules are verified for every jurisdiction considered.
  • Beneficial ownership, tax residence and reporting are assessed separately.
  • No tax result, confidentiality, licence or timeline is guaranteed.

Jurisdiction and applicable framework

The law and competent-authority requirements of the selected jurisdiction apply, together with rules in relevant tax-residence and operating jurisdictions. Comparison precedes selection and implementation.

Official sources

Last reviewed: 22 September 2026

International tax structuring for cross-border entities requires balancing tax efficiency against substance requirements, anti-avoidance rules, and automatic exchange-of-information obligations. We advise on holding structures, inter-company pricing, and the interaction between international jurisdictions and onshore tax systems.

We design structures that take advantage of treaty networks and preferential regimes while ensuring genuine substance in each jurisdiction and compliance with CRS/FATCA reporting. Every structure is tested against the OECD BEPS framework and applicable anti-abuse provisions.

What this includes

  • International holding-structure design
  • Transfer-pricing & inter-company arrangements
  • Treaty-access & anti-abuse analysis
  • CRS/FATCA compliance integration
  • Tax-authority defence & dispute resolution

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