We build corporate structures the way they should be built — around real substance, for the long term, and honest about what each jurisdiction can and cannot do.
A structure is only as good as its substance — and only worth building if it still works the day it is examined, not just the day it is drawn.
Structures are built around genuine economic function — real people, real decisions. Form without substance is a liability, not an asset.
We design for the moment a structure is examined, not just the moment it is created. If it cannot survive a look-through, it is not finished.
The right jurisdiction and vehicle for the actual objective — not the one that is in vogue or the one we happen to sell.
There is no off-the-shelf structure. Two groups that look similar can need very different answers, because the right structure depends on the assets, the investors, the flows, the exit and the rules that touch each of them. Our work starts from the objective and reasons toward the structure — never the other way around.
That means we are willing to tell you when a simpler structure is better, when a different jurisdiction fits, or when the honest answer is that a structure you had in mind will not hold up. We would rather lose a fee than build something that fails when it matters.
We start with what you are actually trying to achieve — the commercial goal behind the structure, before any entity or jurisdiction is on the table.
We model the position across each relevant regime — local tax, EU directives, treaties, anti-abuse rules, and any US overlay — so nothing is discovered too late.
We choose jurisdictions and vehicles that fit the objective and will hold up over time — and we build the substance that makes the benefits real.
We put the structure in place and keep it — and its documentation — current as the rules evolve, so it stays defensible.
Clear advice on what works and what does not — including when the answer is “don’t.”
Tax, legal and substance considered together, not handed off in pieces.
Structures designed for your objective, not pulled from a drawer.
Advice framed for where the rules are heading, not only where they are today.
We would rather build one structure that survives a look-through than ten that merely look efficient on paper.
Our approach is not complicated: understand the objective, respect every rule that touches the structure, choose what genuinely fits, and build the substance that makes it defensible. It is how good structuring has always worked — and, in a world of tightening anti-abuse rules, the only approach that lasts. See where it leads in our corporate structuring advisory, or start a conversation.
What we advise on, and how an engagement works.
Explore → ReferenceThe anti-abuse rule our substance-first approach is built for.
Explore → ComparisonChoosing the jurisdiction that actually fits.
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