Expertise
International Structuring
Permanent establishment risk, substance requirements, tax treaty optimization, operational implantation.
Expanding into a new jurisdiction, whether the UAE, Europe, the United States or beyond, is not simply a matter of company registration. Without careful structuring, you risk creating a permanent establishment, triggering full local taxation or anti-abuse rules, or losing the very tax position that motivated the move.
Key Services
Permanent Establishment
A fixed place of business, a dependent agent, or even regular contract negotiations abroad can create a permanent establishment, subjecting your profits to local corporate tax. We carry out thorough PE assessments and design structures that provide genuine commercial presence without triggering PE risk.
Place of Effective Management
If key management decisions are made in a country other than where your company is incorporated, for instance in Europe for a UAE company, tax authorities may deem it tax-resident there, regardless of where it is registered. We ensure your governance framework withstands scrutiny.
Economic Substance
Tax authorities worldwide increasingly look beyond legal form to actual substance. Under EU anti-avoidance rules, CFC regimes, the principal purpose test of tax treaties or the substance conditions of UAE free zone regimes, an entity without adequate people, premises and decision-making on the ground can be requalified as a shell, denied treaty benefits, or have its profits taxed in its parent's jurisdiction. We help our clients build and document genuine operational substance wherever they operate.
Tax Treaty Optimization
Bilateral tax treaties can offer powerful benefits, including reduced or zero withholding tax on dividends, interest and royalties. The UAE alone has concluded more than 130 of them, and European hubs such as Luxembourg, Switzerland or the Netherlands offer equally extensive networks. But accessing these benefits requires meeting specific conditions that must be built into your structure from day one. We advise on treaty application across all relevant corridors with general international expertise and trusted partners in every main jurisdiction.
Main Flows We Work On
Transatlantic structuring, treaty optimization, and permanent establishment management across EU member states and the United States.
Substance requirements, economic presence, and treaty benefits for businesses bridging the EU and the Gulf.
Cross-border investment flows, withholding tax optimization, and compliant structuring between the US and the Emirates.
Global Reach
Our expertise is not limited to the corridors above. Backed by a network of trusted correspondents built over two decades, we coordinate tax advice in virtually every country in the world, from Russia to Asia (China, Singapore, Vietnam and Japan), Africa and Latin America, notably Brazil and Argentina. Wherever your operations lead, we structure accordingly.
Our Approach
We combine deep international tax expertise with practical structuring experience. Every recommendation is grounded in the specific treaty provisions and domestic laws that apply to your situation.
