What does international tax structuring actually involve?

Averites advises businesses, investors and private clients on the tax structuring of cross-border operations, investments and ownership arrangements, including holding and operating structures, acquisition vehicles, intercompany financing, intellectual property arrangements, dividend, interest and royalty flows, withholding taxes, treaty access, corporate residence and permanent establishment.

Where does international tax planning actually begin?

It begins with understanding where the business is actually operated, where management decisions are made, where assets and employees are located, how capital is financed and how profits are expected to move through the structure.

Is a structure with a low headline tax rate automatically a good structure?

No. A structure that appears efficient based only on headline tax rates may become ineffective if it does not reflect the underlying commercial reality. We consider corporate substance, beneficial ownership, management and control, transfer pricing, anti-avoidance rules, reporting obligations and the commercial purpose of the arrangement.

How does Averites structure a group operating across several jurisdictions?

We help determine how the different parts of the group should interact and how contractual arrangements should reflect the functions, assets and risks actually located in each entity.

Does Averites work with accountants and foreign tax advisers?

Yes. Our lawyers work with accountants, tax advisers and foreign counsel where specialist local advice is required and coordinate the legal documentation necessary to implement the intended tax structure.

Does Averites help restructure an existing international group, or only build new structures?

Both. We advise on restructuring existing international groups where an ownership or operating model has become inefficient, inconsistent with the current business or incompatible with a proposed financing, acquisition, investment or exit.

What is the ultimate objective of Averites' tax structuring work?

The objective is to create structures capable of supporting the business over time rather than arrangements designed around a single transaction or tax period.

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Tax and Private Wealth
International Tax Structuring

International Tax Structuring

Structures Built for Commercial Reality, Not Just Headline Rates

Averites advises businesses, investors and private clients on the tax structuring of cross-border operations, investments and ownership arrangements.

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OUR APPROACH

How We Advise on International Tax Structuring

Starting With the Commercial Reality

International tax planning begins with understanding where the business is actually operated, where management decisions are made, where assets and employees are located, how capital is financed and how profits are expected to move through the structure.
What We Advise On

We advise on holding and operating structures, acquisition vehicles, intercompany financing, intellectual property arrangements, dividend, interest and royalty flows, withholding taxes, treaty access, corporate residence, permanent establishment and the repatriation of profits and investment proceeds.
Why Headline Tax Rates Alone Are Not Enough

A structure that appears efficient based only on headline tax rates may become ineffective if it does not reflect the underlying commercial reality. We therefore consider corporate substance, beneficial ownership, management and control, transfer pricing, anti-avoidance rules, reporting obligations and the commercial purpose of the arrangement.
Coordinating Multi-Jurisdictional Group Structures

Where businesses operate through entities in several jurisdictions, we help determine how the different parts of the group should interact and how contractual arrangements should reflect the functions, assets and risks actually located in each entity.
Working With Specialist Advisers

Our lawyers work with accountants, tax advisers and foreign counsel where specialist local advice is required and coordinate the legal documentation necessary to implement the intended tax structure.
Restructuring Existing International Groups

We also advise on restructuring existing international groups where an ownership or operating model has become inefficient, inconsistent with the current business or incompatible with a proposed financing, acquisition, investment or exit.

Precision across borders. Book a Meeting

New York c/o Chornous Law PLLC
30 Wall Street, 8 Floor
New York, NY 10005 Phone: +1 650 382 7764

London 124 City Road
London, England
EC1V 2NX Phone: +44 7405 138109

Kyiv 11 Panasa Myrnoho Street
Office 1/1
Kyiv, 01011 Phone: +380 63 148 27 37

Email:

info@averites.com

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FAQ

Frequently Asked Questions

Averites advises businesses, investors and private clients on the tax structuring of cross-border operations, investments and ownership arrangements, including holding and operating structures, acquisition vehicles, intercompany financing, intellectual property arrangements, dividend, interest and royalty flows, withholding taxes, treaty access, corporate residence and permanent establishment.

It begins with understanding where the business is actually operated, where management decisions are made, where assets and employees are located, how capital is financed and how profits are expected to move through the structure.

No. A structure that appears efficient based only on headline tax rates may become ineffective if it does not reflect the underlying commercial reality. We consider corporate substance, beneficial ownership, management and control, transfer pricing, anti-avoidance rules, reporting obligations and the commercial purpose of the arrangement.

We help determine how the different parts of the group should interact and how contractual arrangements should reflect the functions, assets and risks actually located in each entity.

Yes. Our lawyers work with accountants, tax advisers and foreign counsel where specialist local advice is required and coordinate the legal documentation necessary to implement the intended tax structure.

Both. We advise on restructuring existing international groups where an ownership or operating model has become inefficient, inconsistent with the current business or incompatible with a proposed financing, acquisition, investment or exit.

The objective is to create structures capable of supporting the business over time rather than arrangements designed around a single transaction or tax period.