We design and build cross-border corporate structures that are efficient, defensible and made to last — holdings, investment platforms and international groups, structured around real substance rather than paper.
A corporate structure is not a diagram — it is a set of decisions about ownership, tax, risk and jurisdiction that has to hold up years later, under scrutiny. Our work is to get those decisions right at the outset, and to build structures that do what they are meant to do without falling foul of the rules that govern them.
Designing holding companies and group structures to consolidate ownership, channel dividends and support clean exits.
Choosing the right jurisdiction — Netherlands, Luxembourg, Belgium and beyond — for the role each entity plays.
Structuring flows across borders under treaties, EU directives and the participation exemption, with anti-abuse in mind.
Building SPVs, platforms and fund-adjacent structures for investors and sponsors.
Establishing the real economic function that treaty and directive benefits depend on.
Reconciling US tax rules — LOB, check-the-box, GILTI — with European structuring.
What the structure must achieve — the assets, the investors, the flows, the exit — before any jurisdiction is chosen.
Model the position across every relevant system — local tax, EU directives, treaties, and any US overlay.
Select jurisdictions and entities, define the layers, and set the financing and ownership architecture.
Design the real economic function — governance, people, decision-making — that makes benefits defensible.
Incorporate, operate and keep the structure and its documentation current against evolving rules.
Structuring holdings to qualify for exemption of dividends and capital gains across European regimes.
Ensuring structures qualify for reduced withholding under treaties and EU directives.
Building for the PPT, LOB and beneficial-ownership tests so benefits survive scrutiny.
Reconciling US and European rules in structures that span both.
We do not sell structures off a shelf. We build the one that fits — and we build it to survive a look-through.
Every structure is built around genuine economic function. Form without substance is a liability, not an asset.
We design for the rules as they are heading, not just as they are — structures that hold up over time.
The right jurisdiction and vehicle for the actual objective — not whatever is in vogue.
Whether the task is a European holding, an investment platform, a cross-border group or a transatlantic structure, the discipline is the same: understand the objective, model every system that touches it, choose the right jurisdiction and vehicle, and build in the substance that makes it defensible. Explore the underlying topics — the participation exemption, treaty networks, the Principal Purpose Test — or start a conversation.
Choosing between Europe’s core holding jurisdictions.
Compare → ReferenceIncorporating across Europe — entities, capital, timelines.
Explore → ReferenceRing-fenced vehicles for investment structuring.
Explore →