Operators reviewing an existing cross-border structure
Problems we solve
Resolve the gaps before they become application risk.
Company, payment and tax decisions were made without a unified residence and substance analysis.
Bookkeeping, reporting and adviser responsibilities are fragmented across countries.
A proposed structure is being treated as a tax shortcut without enough facts or professional review.
Service scope
A coordinated, reviewable workstream.
Current-structure and fact-pattern mapping
Accounting responsibility and reporting calendar coordination
Residence, substance and cross-border issue identification
Professional tax and legal adviser question preparation
Implementation and recordkeeping handoff
Delivery process
From operating facts to a clear handoff.
Every step creates a documented work product. Timelines and third-party decisions depend on the facts, responsiveness and provider review.
01
Fact pattern
Map owners, tax residence, management, people, entities, customers, income sources and transaction flows.
02
Obligation map
Identify known accounting, filing, substance and cross-border questions requiring confirmation.
03
Professional review
Coordinate clearly framed questions with qualified advisers in the jurisdictions that actually matter.
04
Compliance handoff
Document responsibilities, decisions, open advice and the agreed recordkeeping or implementation plan.
What you leave with
Documented outputs, not guaranteed provider results.
These deliverables are supported by the defined service scope. They are not claims about approval, savings, account continuity or future outcomes.
01
Cross-border fact map
A documented picture of the people, entities, control, income and transaction relationships under review.
Supported by current service scope02
Obligation calendar
A coordinated record of known accounting, filing and professional-review responsibilities.
Supported by current service scope03
Decision record
A traceable record of assumptions, adviser input, unresolved questions and implementation responsibilities.
Supported by current service scope
Engagement boundaries
Clear responsibilities protect the operating model.
We prepare and coordinate the agreed work. Banks, payment providers, authorities and qualified advisers remain responsible for their own decisions and professional opinions.
No webpage or general consultation replaces individual legal or tax advice.
We do not promote concealed income, sham substance, false invoicing or non-disclosure.
Tax outcomes depend on the actual facts, elections, residence rules, treaties and continuing compliance.
Regional applicability
Global access. Rules tested where they apply.
European depth does not turn EU rules into universal rules. The legal analysis follows the people, entities, activity, data, providers and countries actually involved.
GLGlobal applicability
Tax planning begins with the actual people, control and activity.
Applicable rules depend on tax residence, management and control, permanent establishments, source of income, entity classification, beneficial ownership, treaties and disclosure regimes in the countries involved.
Owner and management tax residence
Permanent-establishment and CFC exposure
Entity classification and income source
Treaty, beneficial-owner and disclosure rules
EUEuropean focus
European anti-abuse and disclosure rules require factual testing.
ATAD measures operate through Member State rules, while DAC6 concerns reportable cross-border arrangements meeting defined criteria. Neither label alone determines a client's outcome or filing duty.
Member State ATAD implementation
CFC, exit-tax and anti-abuse questions
DAC6 hallmarks and reporting responsibility
GDPR where advisers process personal data
Applicability sequence
Four facts determine which rules need review.
This is a scoping framework, not an automated legal or tax conclusion. One client can have more than one relevant country.
01
Client and activity location
Where are the owners, team, customers, decision-makers and day-to-day activity located?
This can affect operating licences, permanent-establishment exposure, VAT, data rules and local filing duties.
02
Tax residence
Where are the owners and relevant entities treated as tax resident?
Residence can determine worldwide-income reporting, CFC rules, treaty access and personal or corporate disclosure duties.
03
Service entity and substance
Which entity contracts, earns revenue, employs people, holds assets and makes decisions?
The legal entity, place of management and operating substance shape accounting, beneficial-ownership and anti-abuse analysis.
04
Target financial institution
Where is the bank, payment provider or account-issuing entity that will review the application?
Provider location, licence perimeter, risk policy and local AML/KYC rules can change evidence and onboarding requirements.
European rule map
Check only when an EU/EEA nexus exists.
For non-European arrangements, begin with the relevant local law. GDPR, DAC6 and ATAD are not global defaults.
GDPR
Personal-data scope
When to check
Check when an EU/EEA establishment processes personal data in its activities, or when a non-EU organisation offers goods or services to, or monitors, people in the EU/EEA.
Facts to review
Map the people, data, purposes, controller and processor roles, vendors, transfers and relevant national requirements.
Boundary
A global business is not automatically in scope for every GDPR obligation; the establishment, targeting, processing and risk facts matter.
Check when an EU-based intermediary or, in certain cases, a taxpayer is involved in a cross-border arrangement that may meet the geographic scope and specified hallmarks.
Facts to review
Identify the parties, residences, business operations, intermediaries, hallmarks, reporting person, national implementation and deadline.
Boundary
A cross-border structure is not automatically reportable; the DAC6 criteria and the relevant Member State rules must be assessed.
Check when EU corporate-tax exposure or a Member State implementation may engage interest limitation, exit tax, CFC, general anti-abuse or hybrid-mismatch measures.
Facts to review
Test the entity, tax residence, financing, asset movements, controlled companies, hybrid features, commercial rationale and local transposition.
Boundary
ATAD is not a global tax code and does not make every non-EU arrangement subject to EU corporate-tax rules.