Service 03 — Cross-Border Corporate Structuring
A Structure That Holds
Across Every Market
Expanding into new markets raises questions that go beyond registering a local entity. Where should the holding company sit? How should intercompany arrangements be documented? What does withholding tax look like across your specific jurisdictions? This service works through those questions and delivers the answers in writing.
← Back to HomeWhat This Delivers
A Written Memorandum on
How to Structure Your Expansion
At the conclusion of this engagement, you receive a structured written memorandum that sets out a recommended corporate structure for your multi-country operations — the reasoning behind it, the jurisdictions involved, and the steps required to put it in place.
This isn't a generic overview of international holding structures. It's an analysis of your specific business — where it currently operates, where it's heading, and what arrangement best serves those circumstances from a tax and structural standpoint.
Holding Company Jurisdiction Analysis
Candidate jurisdictions evaluated against your specific operational footprint, treaty access, and ownership requirements.
Intercompany Agreement Framework
Recommended intercompany arrangements outlined with the rationale for each — loans, service agreements, IP licensing, and similar arrangements assessed in context.
Withholding Tax Implications Mapped
Withholding tax rates and treaty relief across each relevant jurisdiction identified as part of the structural recommendation.
The Challenge
Multi-Country Operations
Outgrow Ad-Hoc Structures Quickly
Many businesses enter new markets by registering whatever entity type is locally required and managing the cross-border pieces informally. That approach works up to a point — usually until the volume of intercompany transactions, dividends, or management fees reaches a level where the absence of a considered structure starts creating real costs.
Withholding taxes on dividends, interest, and royalties flowing between entities can add up quickly when they're not structured with treaty access in mind. Intercompany arrangements that weren't documented properly can draw scrutiny under transfer pricing rules — often in the jurisdiction where scrutiny is most costly.
Holding company location decisions made early tend to stick. Moving a holding structure once it's established involves costs — legal, regulatory, and tax — that can make an otherwise sensible reorganization difficult to justify. Getting it right the first time, or at least before scale makes change prohibitive, has a long tail of benefit.
This service is designed for businesses that are either planning their first multi-country expansion or reviewing a structure that has grown without a comprehensive review. Either way, a written analysis of the options and a recommended path forward is a useful thing to have.
Our Approach
Analysis Grounded in
Your Specific Situation
Cross-Border Corporate Structuring begins with a thorough review of your current structure — what entities exist, where they're located, how they interact, and where you intend to expand. That picture shapes everything that follows.
From there, holding company jurisdictions are evaluated against the specifics of your situation — treaty access to the countries you operate in, substance requirements, local tax treatment of dividends and capital gains, and the practical considerations of maintaining a holding entity in that jurisdiction.
Intercompany agreements are reviewed or recommended based on the nature of the transactions between your entities. Withholding tax implications are mapped across the relevant jurisdictions. All of this is captured in a written memorandum that outlines the recommended structure, explains the reasoning, and sets out the implementation steps.
Current Structure Review
Existing entities, jurisdictions, intercompany flows, and expansion plans reviewed in full to establish the baseline for analysis.
Holding Jurisdiction Evaluation
Candidate holding jurisdictions assessed against treaty access, substance requirements, and the specific profile of your operations.
Intercompany and Withholding Analysis
Intercompany agreement framework recommended. Withholding tax rates and available treaty relief identified across all relevant cross-border flows.
Written Memorandum
Recommended structure, rationale, and implementation steps documented in a structured memorandum — yours to act on directly or share with legal and local advisors.
Working Together
What the Engagement Involves
A methodical process designed to make good use of your time — most of the work happens on our side, between an initial conversation and delivery of the memorandum.
Structured Kick-Off
We begin with a focused conversation about your business — current structure, countries involved, planned expansion, and any specific constraints or preferences. This typically takes an hour and sets the scope precisely.
Analysis and Drafting
Holding jurisdiction options evaluated, intercompany framework developed, and withholding implications mapped. Draft memorandum prepared and shared with you for review and comment before finalization.
Memorandum Delivery
Final memorandum delivered with a walkthrough session to work through the recommendations. Implementation steps are explained clearly — you leave the engagement knowing what to do and in what order.
Investment
Fixed Fee for a Complete
Structural Analysis
Cross-Border Corporate Structuring is offered at a fixed fee of $3,200 USD. This covers the full engagement — kick-off consultation, current structure review, holding jurisdiction evaluation, intercompany framework development, withholding tax analysis, and the written memorandum.
The fixed fee means the scope is defined before work begins and the price doesn't change as the analysis develops. If the scope needs to expand significantly — for example, because additional jurisdictions emerge that weren't part of the original picture — that's discussed with you before any additional work is undertaken.
For businesses planning their first international expansion, this engagement typically pays for itself in the first year through more considered structuring decisions. For businesses reviewing an existing structure, the value is in identifying where the current arrangement could be improved — and having a documented recommendation to act on.
Service Fee
$3,200 USD
Fixed fee — complete structural analysis engagement
- Structured kick-off consultation
- Current structure and entity review
- Holding company jurisdiction evaluation
- Intercompany agreement framework recommendations
- Withholding tax implications mapped across jurisdictions
- Written memorandum with recommended structure and rationale
- Implementation steps outlined in sequence
- Delivery walkthrough session
Methodology
Engagement Timeline and Milestones
How the engagement moves from initial conversation to a delivered, actionable memorandum.
Week 1
Kick-Off and Intake
Consultation conducted, current structure documented, target jurisdictions confirmed, and any specific constraints or preferences recorded.
Week 2
Jurisdiction Analysis
Candidate holding jurisdictions assessed. Treaty access, substance requirements, and local tax treatment evaluated against your operational profile.
Week 3
Draft Memorandum
Draft memorandum covering structure recommendation, intercompany framework, withholding analysis, and implementation steps shared for your review.
Week 4
Final Delivery
Comments addressed. Final memorandum delivered. Walkthrough session conducted to ensure recommendations are clear and actionable.
Timeline applies to engagements where the existing structure is reasonably well documented. More complex multi-tier arrangements may require additional time for review.
Our Commitment
A Memorandum That Addresses
Everything in Scope
The memorandum delivered at the end of this engagement covers everything agreed in the scope at the outset — holding jurisdiction recommendation, intercompany framework, withholding tax implications, and implementation steps. If any of those components isn't addressed to the standard agreed, we continue until it is.
If you'd prefer to have an initial conversation before committing to the engagement, that's entirely welcome. We can discuss your situation, confirm whether the service is a reasonable fit, and answer any questions about scope or process — without any expectation on your part.
Complete scope commitment
Every component of the agreed scope is addressed in the final memorandum — structure recommendation, intercompany framework, withholding analysis, and implementation steps — before the engagement is closed.
Getting Started
The Path Forward
Is Straightforward
To begin, use the contact form to share a brief description of your business — where it currently operates, where you're planning to expand, and any specific structural questions you want addressed. That's enough to confirm whether this engagement is the right fit.
We respond within one to two business days. If the engagement fits your situation, we'll confirm the scope, send an engagement letter, and schedule the kick-off consultation. From that point, work begins and proceeds on the timeline described above.
Businesses that are already mid-expansion and working against a specific deadline are welcome to mention that. We'll let you know whether an expedited timeline is workable before the engagement begins.
Describe Your Business and Goals
Current structure, countries involved, and where you're looking to expand. A paragraph is enough to start.
We Confirm Fit and Scope
Response within two business days. Scope confirmed and engagement letter sent if we're a good match.
Kick-Off and Documentation
Consultation scheduled, existing structure documentation reviewed, and analysis begins within the first week.
Memorandum Delivered
Recommended structure, rationale, and implementation steps in writing — ready to act on or share with your legal and local advisors.
Cross-Border Corporate Structuring
Planning a Multi-Country Expansion?
If you're building or reviewing a structure that spans more than one jurisdiction, a written analysis of your options is a useful place to start.
Start a ConversationOther Services
Explore Our Other Engagements
Each service addresses a distinct cross-border tax need. You may find more than one relevant to your situation.
Service 01
International Tax Planning
Advisory support for businesses and individuals with cross-border financial activity — treaty analysis, foreign tax credits, and multi-jurisdiction reporting obligations.
Service 02
Expatriate Tax Preparation
Tax return preparation for individuals living and working abroad — foreign earned income, housing allowances, and coordinated domestic and foreign filing requirements.