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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

  1. 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.

  2. 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.

  3. 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.

  4. 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.

  5. 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.

  6. 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.

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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

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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.