International structuring

Approach

International structuring is only viable when each entity has real economic substance. We structure groups around the business itself — operations, people, geography — and not around tax minimisation as an end in itself.

Solutions are built to hold up against international transparency standards: FATF and OECD requirements, CRS reporting and the arm's length principle in transfer pricing.

Scope

• Holding structures for asset consolidation and group management.
• Jurisdiction selection weighing substance requirements, reputation and applicable tax treaties.
• Tax planning within the law, where the structure has economic substance.
• International compliance: CRS, FATCA, DAC6, transfer pricing and KYC.

Contact

Arasari & Partners — Rodovia José Carlos Daux 4190, Florianópolis, Santa Catarina, Brazil. Email: info@arasari.com.br. Working languages: Portuguese, English, Spanish, Russian.

Engagements are non-discretionary advisory: we structure, coordinate licensed providers and track deadlines; decisions remain with the client.