The owner-side analysis changes
Personal tax residence, CFC exposure, remuneration and distributions may need to be reassessed against the new facts.
When a founder, owner or director moves country, the business can move with them in ways that are not visible in the corporate documents. We review the personal and corporate consequences as one cross-border transition — before the move, during restructuring or after issues have already appeared.
Relocation is not only a personal tax-residence question. The same move can change where decisions are made, how companies are managed, what banks see and which parts of the structure need to be reconsidered.
Personal tax residence, CFC exposure, remuneration and distributions may need to be reassessed against the new facts.
If strategic decisions, authority or control follow the owner, company-residence and permanent-establishment questions may also change.
KYC, CRS, Source of Funds / Source of Wealth, governance and the explanation of control must remain consistent with how the business actually operates.
The purpose is to understand the transition as a system before separate local conclusions are applied.
Where the owner lives, what they control, how ownership is exercised and which facts require jurisdiction-specific tax analysis.
Where strategic decisions are made, who controls accounts and contracts, and whether the management model still matches the corporate structure.
Where directors, employees and contractors work, what authority they have and whether the move changes presence-related risk.
How owner payments and cross-border flows connect with treaty, withholding-tax and beneficial-ownership questions for specialist review.
How the new residence affects KYC narratives, account structures, ownership explanations and evidence of funds and wealth.
Whether authority, decision trails, company functions and the legal structure need to be aligned or reorganised after the move.
Relocation is not one fixed service. Before the move the priority may be bounded diagnosis; after the move the same facts may require a systemic audit, a defined restructuring project or ongoing monitoring.
Use before the move or at an early stage to map residence, control, management, team and banking facts and identify what needs specialist confirmation.
Open format →Use when the move has already affected several entities, management, ownership, banking or evidence and the existing model needs a whole-system review.
Open format →Use when a defined outcome must be delivered: restructuring, governance changes, banking remediation, evidence preparation or implementation coordination.
Open format →Use after the baseline is clear when residence, governance, banking or group facts need continuing monitoring after relocation.
Open format →Residence, ownership, control, management, team locations and relevant cash-flow facts in one current-state picture.
The interfaces that require attention across CFC, PE, banking, governance, distributions and restructuring.
A prioritised order for decisions and implementation rather than separate local fixes.
A focused set of facts and questions for appropriately qualified tax and legal specialists in the relevant jurisdictions.
LEXONYX maps the facts, structure and dependencies of the relocation. Jurisdiction-specific legal and tax conclusions are provided or confirmed by appropriately qualified specialists in the relevant jurisdictions.
Send the current ownership structure, countries involved, where the owner and directors live, where decisions are made and what has triggered the review. We will identify the smallest sensible starting point.