Cross-border structuring
Turning a fiscal plan into a set of entities in more than one country: holding companies, operating companies, foundations and the agreements between them.
- Line
- Design
- Works with
- Holdings, foundations, trusts, LLCs
- Key test
- Substance and reporting
- Jurisdictions
- Monaco · UAE · USA · Panama · Paraguay
01What it is
A cross-border structure is only as strong as its weakest link. Each entity has to be resident where it is managed, carry real substance where the law requires it, and be visible to the authorities that are entitled to see it.
We design structures that keep operating risk apart from family assets, make succession possible without disputes, and remain understandable to banks and tax authorities.
02Typical structures
A holding above operating companies
Dividends, sale proceeds and reinvestment handled in one place.
Separating risk from family wealth
Operating companies on one side, property and portfolios on the other.
Succession and continuity
A foundation or trust that holds the shares and survives the founder.
International real estate
Property in several countries held through the right vehicle for each.
03What we test
Residence of each entity
Where it is effectively managed decides where it is taxed.
Substance
Office, people and decisions where the law expects them.
Treaties and flows
Double tax treaties, withholding taxes and transfer pricing between related entities.
Reporting
CRS, FATCA and beneficial ownership registers, planned from the start.
04Across our jurisdictions
| Monaco | No personal income tax for residents, French nationals excepted. Companies need prior government authorisation. |
|---|---|
| United Arab Emirates | Corporate tax of 9% above AED 375,000 since June 2023; 0% on qualifying free zone income with adequate substance. |
| United States | US persons are taxed on worldwide income. FATCA applies; the US is outside CRS. |
| Panama | Territorial system: foreign-source income is generally not taxed; 25% corporate tax on Panamanian income. |
| Paraguay | Territorial system: 10% corporate income tax; residents are not taxed on foreign-source income. |
Headline rules only, from public sources as of October 2026. Every case depends on nationality, residence and facts, and is reviewed with local counsel.
05What you receive
- Entity chart with jurisdictions
- Flow and treaty analysis
- Substance plan per entity
- Reporting map (CRS, FATCA, registers)
06Questions
Why not one company in one low-tax country?
Because banks, counterparties and tax authorities test where a company is really managed. A structure without substance tends to fail exactly when it is needed.
Foundation or trust?
It depends on the family’s nationality, residence and assets. Civil-law families often prefer foundations; common-law families are used to trusts.
Can an existing structure be fixed?
Yes. Many mandates start with a review of structures set up years ago.
This page describes our services in general terms. It is not tax or legal advice.