Residency of the Owner / Key Persons
Affects personal taxation, control over foreign companies (CFC) and ownership logic.
STRUCTURAL MODEL
Structural Model of an International Structure
Not a choice of country, but a system for allocating functions, assets and decisions — where tax/VAT/PE, governance and the bank’s reading do not conflict with each other
A defensible international structure starts with business reality — not tax outcomes. Legal structure should reflect economic reality. Governance should reflect where decisions are actually made. Substance should support governance. Tax consequences should follow the business model, not replace it. Banks, tax authorities and regulators should all see the same coherent picture. Any disconnect between these layers increases tax, banking and regulatory risk.
HOW THE MODEL IS BUILT
Key Nodes of the Structural Model
These are the nodes through which PE, VAT and banking risks most often materialise.
Group Structure
The centre of the model: company roles, ownership, governance, assets, flows and documents.
PE risk
Arises where activity is actually carried out: people, negotiations, authority and performance of key functions.
VAT Logic
Follows the operations: warehouses/fulfilment, supply chains, marketplaces and fixed establishment.
Readiness for Bank Review
Shows how coherent and explainable the structure appears to a bank or payment service provider (PSP).
HOW TO READ THE MODEL
What This Model Shows in Practice
Where value is created, tax reality arises. If
management/key functions are in one country while profit “lives” in another, that is almost always a
trigger.
Documents must support one and the same logic.
Ownership, governance, contracts and processes must not contradict each other.
One weak node pulls the others with it. An error
in residency or in the allocation of functions often appears first at the bank, then in PE/VAT, and then in
tax consequences.
Review starts from the outside. Banks and
counterparties read the structure through payments, contracts, roles and the narrative — this must be built
in advance.
Practical rule: if 2–3 nodes are active at the same time (people + flows + operations), this is not a local fix, but a task for rebuilding the model or conducting a structural audit.
RELATED ELEMENTS
How This Connects to Other Parts of the System
FAQ
In Brief
What is a structural model of international business?
A structural model is not a choice of country. It is a system for allocating functions, assets, management decisions and risks so that tax/VAT/PE logic, governance, substance and banking readiness form one coherent configuration. The model shows the pillars of a robust international structure and where its key nodes sit.
What pillars support a robust structure?
A robust structure rests on three pillars: allocation of functions and assets, governance and control, and economic reality supported by substance. If even one pillar diverges from the others — for example, management is in one country while functions are in another without a defensible logic — the structure becomes indefensible under external review.
What are the nodes of a structural model?
Nodes are the points through which PE, VAT and banking risks most often surface: where decisions are made, where people and functions are located, how money and contracts move, and where taxable presence arises. The model is analysed through these nodes because this is where the structure either holds as a system or begins to diverge from reality.
What does the structural model show in practice?
In practice, the model shows how far the stated structure matches the actual activity and whether it can withstand review by a bank, tax authority or regulator. It connects tax logic, governance, substance and flows, making visible where the model is robust and where it needs review before growth, a transaction or entry into a new market.
STRUCTURAL REVIEW
Need a system-level review of the structure?
We assess the model as one system, not as separate elements.
Request a Structural Review