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LegAIchain

Tax Structuring & Planning

Practical structuring for groups, founders and investors that keeps the overall tax position efficient and defensible. We design holding and financing structures around real substance and commercial purpose, not just headline rates.

What this covers

  • Group and holding structure design and review
  • Choice of legal form and tax regime for new ventures
  • Financing structure and intra-group debt planning
  • IP ownership and licensing structure design
  • Profit repatriation and dividend flow planning
  • Substance and economic-purpose assessment against GAAR
  • MDR (mandatory disclosure) reporting analysis for arrangements
  • Reorganisation planning: mergers, divisions, contributions in kind
  • Founder and shareholder tax planning ahead of exit or investment
  • Cross-border relocation and redomiciliation analysis
  • Effective tax rate modelling for alternative structures
  • Coordination of structuring with corporate and regulatory constraints
  • Documentation of business rationale to support the structure

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