Advanced tax advisory
Tax cost is usually set before the business starts. We work from business substance, contract structure and the cash-and-invoice chain to design arrangements that can be explained, executed and evidenced.
Covering the transactions with the largest numbers
Each can be engaged on its own or combined into an annual advisory arrangement. Tax due diligence and ledger clean-ups are taken on a project basis.
Corporate & individual tax planning
- Review of the current tax position by business line
- Comparison of policy options with numbers
- Contract, pricing and invoicing alignment
- Implementation support and documentation
Equity transfer & holding structures
- Direct, partnership and corporate holding platforms compared
- Transfer pricing and net asset verification
- Individual income tax on transfers and deferral options
- Governance and exit flexibility
Listed-share disposals & flexible staffing
- Holding vehicle and disposal route comparison
- Cost base and allowable expense collection
- Timing of disposal and tax liability
- Substance testing for flexible staffing models
Real estate & construction
- Whole-project tax planning and cash flow modelling
- Cost collection and allocation between phases
- Land value-added tax clearance preparation
- Progress billing and subcontracting structure
Three ways to hold a business, compared
The right vehicle depends on how you will exit, not only on the tax rate today.
| Structure | Tax on dividends | On exit | Best suited to |
|---|---|---|---|
| Direct individual holdingShares held by natural persons | 20% individual income tax | 20% on transfer gains | Simple groups, early stage, founder-controlled |
| Partnership platformLimited partnership holding vehicle | Pass-through, 5%–35% by partner type | Taxed at partner level | Employee incentives, fund holdings |
| Corporate holding companyDomestic or offshore holding company | Exempt between qualifying resident enterprises | Enterprise income tax, treaty relief possible | Reinvestment, multi-business groups, overseas listing |
Indicative only. Rates, exemptions and treaty relief depend on residency, substance and the latest rules — modelling is done per case.
Four stages, documented at each
Diagnose
Read the current structure, contracts, ledger and filings; identify the exposures and the opportunities.
Model
Quantify at least two routes, including implementation cost and ongoing compliance burden.
Implement
Contracts, resolutions, registrations and accounting entries executed in the right order.
Evidence
Keep the substance file: why the arrangement exists, who decided, what was paid.
What we will not do
Tax planning that cannot survive an examination is not planning — it is deferred cost. We decline the following, regardless of the fee.
- Issue invoices without real transactions
- Keep two sets of books
- Move profits through shell companies with no substance
- Treat employees as contractors to avoid social insurance
- Use personal accounts to receive company revenue
- Backdate contracts to fit a retrospective story
Understand the problem before you commit
Tell us how you trade, where you sell and how the group is held. You get a written list of issues and realistic options — the first conversation is free.