International Tax Planning – Structuring for Efficiency, Compliance and Growth

Where you locate your holding company, how you structure your intellectual property and how you price intercompany transactions determines your global tax burden. We design tax-efficient multinational structures that adapt to regulatory change—minimizing liabilities while keeping you compliant in every jurisdiction.

Get Started Today

Tax Strategy That Travels Across Borders

International expansion creates immense opportunities—and immense tax complexity. Different regimes, overlapping treaties and evolving anti-avoidance rules (BEPS, Pillar Two) mean that yesterday’s structures may no longer work today. Our International Tax Planning practice helps you design and implement tax-efficient structures that stand up to scrutiny, adapt to change and support your global ambitions. From holding company location and IP migration to transfer pricing and permanent establishment risk management, we provide the expertise to keep your global business both profitable and compliant.

Comprehensive International Tax Solutions

Holding Company Structuring – Choose the Right Jurisdiction

The location of your holding company affects everything: tax on dividends and capital gains, access to treaty networks, withholding tax on outbound payments and substance requirements. We help you choose and structure the optimal holding jurisdiction for your global operations.

What we cover for holding structures:

Jurisdiction selection: Netherlands (participation exemption), Luxembourg (financing vehicles), Ireland (IP and trading), Switzerland (holding regime), Malta (full imputation), Singapore (territorial system), UAE (0% corporate tax)
Multi-layer structures: Holding companies, financing vehicles, IP companies, operating subsidiaries
Dividend and capital gains optimization: Participation exemption, substantial shareholding exemption
Treaty access: Limitation on Benefits (LOB) clauses, principal purpose test (PPT)
Substance requirements: Real economic presence, board meetings, decision-making

Key jurisdictions we advise on:

Europe: Netherlands, Luxembourg, Ireland, Switzerland, Malta, Cyprus
Middle East: UAE (Dubai, ADGM), Bahrain
Asia: Singapore, Hong Kong
Americas: Delaware, Cayman, Bermuda

IP Structuring – Migrate and Monetize Your Intangibles

Intellectual property is often a company’s most valuable asset—and the most mobile. Structuring IP ownership correctly can generate significant tax savings through royalty income, cost sharing and exit strategies.

What we cover for IP structuring:

IP migration: Legal and tax-efficient transfer of IP to holding companies
Royalty optimization: Withholding tax analysis, treaty relief, EU Interest and Royalties Directive
Cost sharing arrangements: Shared development costs across group companies
IP box regimes: Preferential tax treatment for IP income (Netherlands Innovation Box, UK Patent Box, Irish Knowledge Development Box, Swiss IP Box)
Exit strategies: IP monetization, sale, licensing or contribution to JVs
BEPS 2.0 alignment: Ensuring IP structures comply with Pillar Two and substance requirements

Transfer Pricing – Defend Your Intercompany Pricing

Transfer pricing is the most scrutinized area of international tax. Regulators worldwide require that transactions between related parties be priced at arm’s length. We help you establish, document and defend your transfer pricing policies.

What we cover for transfer pricing:

TP policy development: Intercompany agreements for services, goods, financing, royalties
Benchmarking studies: Comparable searches to support arm’s length pricing
Documentation: Master file, local file, Country-by-Country (CbC) reporting
APA (Advanced Pricing Agreements): Binding agreements with tax authorities for future years
Risk assessment: Identifying and mitigating TP risk areas
Defense and dispute resolution: Supporting tax audits, mutual agreement procedures (MAP), arbitration

Common intercompany transactions we cover:

Management and advisory fees
Financing and treasury (loans, cash pooling, guarantees)
Royalties and license fees
Goods and raw materials
Cost contribution arrangements

PE Risk Management – Avoid Unintended Tax Presence

Operating in a foreign country without establishing a taxable presence is increasingly difficult. Digital activities, remote workers and service providers can all create a permanent establishment (PE), exposing you to local taxation.

What we cover for PE risk:

PE risk assessment: Identifying activities that could create a PE (sales, services, construction, agency, digital)
Digital PE: Navigating the challenges of remote work, ecommerce and digital services
Agency PE: Avoiding unintended agency relationships with local partners
Service PE: Managing service delivery across borders
Mitigation strategies: Contract restructuring, activity segregation, substance planning
Treaty protection: Applying PE exemptions and thresholds

BEPS 2.0 & Pillar Two – Prepare for Global Minimum Tax

The OECD’s BEPS 2.0 project introduces a global minimum tax (Pillar Two) of 15% for multinational groups with revenue above €750M. Even if you’re below the threshold today, understanding and preparing for these rules is essential.

What we cover for BEPS 2.0:

Impact assessment: Does Pillar Two apply to your group now or in the future?
GloBE rules: Income inclusion rule (IIR), undertaxed profits rule (UTPR), qualified domestic minimum top-up tax (QDMTT)
Transition planning: Structuring to minimize top-up tax
Safe harbors: Transitional and permanent safe harbors
Reporting and compliance: Preparing for GloBE information returns

How We Build Your Tax Structure

1. Diagnostic Review

We analyze your current structure, cross-border flows, intellectual property, and growth objectives to identify inefficiencies and risks.

2. Strategy Development

We design an optimal structure: holding jurisdiction, IP ownership, financing vehicles, operating entities. We consider treaty access, substance requirements and BEPS compliance.

3. Implementation

We implement the new structure: company incorporation, IP migration, intercompany agreements, financing.

4. Documentation

We prepare all the necessary documentation: transfer pricing policy, master file, local file, intercompany agreements.

5. Ongoing Management

We monitor ongoing compliance, update TP analyses, manage local compliance, and provide support in the event of tax audits.

Direct & Action-Oriented

Professional & Efficient

Taking the first step toward a secure financial future can be the most daunting. This quick form is designed to make that step simple. By sharing a few details, you’ll initiate a confidential, no-obligation conversation with a dedicated Lincoln Wealth specialist. We’ll listen to your aspirations, answer your pressing questions, and help you map out a clear, confident path forward. There is no pressure, only a commitment to providing you with the clarity you deserve.