Structuring · Governance
Cross-Border Structure
- Does the structure match the actual allocation of functions?
- Where are key management decisions made?
- Is the group’s economic rationale documented?
- Is the tax model aligned with governance?
Practical format
Checklists
Applied screening tools for assessing an international structure: tax risks, PE, VAT, banking readiness and regulatory alignment.
Checklists help assess the level of risk and identify areas requiring structural analysis. They do not replace legal advice and are not a ready-made solution.
PE · People · Remote Teams
Permanent Establishment and People
- Are there employees or agents in other jurisdictions?
- Who conducts negotiations and signs contracts?
- Where is effective management carried out?
- Could a dependent agent PE arise?
VAT · E-commerce
VAT and Fixed Establishment
- Are warehouses or fulfillment centres used in the EU?
- Are there staff involved in the supply of goods?
- Is the OSS regime sufficient?
- Do local VAT obligations arise?
Banking · KYC · Regulatory
Banking Readiness
- Is the ownership structure consistent?
- Is the source of funds documented?
- Is there a narrative explaining the economic rationale?
- Does governance meet bank expectations?
What next?
If a checklist produces several “red zones”, the structure requires systemic analysis. International models rarely have only one issue: tax, governance, banking and regulatory logic are interconnected.
Need a structural analysis?
Start with an initial request — this helps determine priorities and the level of risk.
Request a ReviewThe checklists are for informational purposes and do not constitute legal advice. International structures require individual analysis.