01 · GROUP
Group architecture
Functions, risks and assets by layer. HoldCo / OpCo / ServiceCo logic. Alignment with the actual operating model.
FORMATS · STRATEGY
Strategic Structure Audit
For an existing cross-border structure that needs a system-level review before scaling, financing, restructuring or a sensitive banking or tax event. We map the current model, identify the material cross-border gaps and turn them into a prioritised implementation plan.
WHY
When a system-level audit is useful
Use the strategic audit when separate local decisions have accumulated and no single view shows how ownership, management, PE and VAT interfaces, CFC, banking and regulatory dependencies interact. The output is a current-state map, risk priorities and an implementation sequence, with jurisdiction-specific specialist conclusions integrated where required.
Misalignment of functions
Documents and legal form do not match how the business actually operates: people, sales, management.
PE / VAT “suddenly”
An operational footprint in the EU/UK starts creating obligations where they were “not planned”.
Banks and explainability
There is no coherent logic for ownership and flows: the bank does not understand the economic rationale of the structure.
PERIMETER
What the strategic audit includes
The content depends on the model, but the perimeter is always systemic: we review how the elements reinforce or break one another.
02 · PE / TEAM
PE risk and operational footprint
People, authority, negotiations, management and contracts. Where an actual “taxable footprint” arises.
03 · VAT
VAT and supply chains
OSS / IOSS, fixed establishment, marketplaces, warehouses and supply-chain logic, including through contractors.
04 · PERSONAL RISKS
Tax residency and CFC
Personal tax residency, control tests, CFC, dividend logic and the “spillover” of risks to the owner. Separately — treaty access (DTT), the withholding tax (WHT) position, beneficial ownership and the principal purpose test (PPT).
05 · BANKS
banking readiness
KYC logic, source of funds, explanation of ownership/flows and the “explainability” of the structure for onboarding and monitoring.
06 · REGULATOR
Regulatory alignment
Licensing perimeter, compatibility of the model with compliance requirements and with growth/investors.
PROCESS
How the audit works
No “hours of consultation for the sake of consultation”. We structure the work so that the output is a system map and an implementation plan.
01
Qualification and perimeter
Short session + structured intake: we record the objective, geography, current scheme and constraints. We confirm the scope.
02
Fact collection and mapping
Functions/risks/assets, the “people footprint”, supply chains and governance. We build the “as is” position — without idealisation.
03
Stress test and gaps
PE/VAT/CFC/banks/regulation. We identify points of misalignment and the domino effect: one error → several risks.
04
Model map and action plan
We deliver a structural map, prioritisation, target logic for “how it should be” and an implementation roadmap.
What you receive as output
- Structural map of the model: links between blocks and risks
- List of misalignments and prioritisation: quick improvements / systemic changes
- Recommended architecture and logic for allocating functions/risks
- Banking “explainability” package: logic and list of documents for KYC
- Implementation plan and list of questions for local counsel
WHO IT FITS
When a strategic audit is the
right format
Scaling
Entry into the EU/UK, team growth, new markets, new logistics.
Bank / payment providers
Onboarding, enhanced review, preparation for monitoring.
Investor / transaction
Review before a round, M&A, restructuring of ownership and IP.
The logic has “drifted apart”
Local decisions have accumulated — the system has become internally inconsistent.
RELATED SECTIONS
Useful links
FAQ
Briefly, to the point
What is a Strategic Structure Audit?
It is a comprehensive analysis of the international model as a system: group structure, PE risk, VAT, personal tax residency, CFC, banking readiness, regulatory alignment and governance — within one perimeter, not as separate tasks. The audit shows how coherent, defensible and ready the model is for growth, review or a transaction.
Why does the audit cover all elements at once?
Because the elements of an international structure are connected: tax residency affects PE risk, which in turn affects VAT and banking clarity. A siloed analysis misses conflicts at the interfaces. A strategic audit brings everything into one perimeter to show where the model is aligned and where its parts contradict one another and create risk.
When is a strategic audit the appropriate work format?
An audit is appropriate when the model is complex or changing: several jurisdictions, team growth, preparation for a transaction, investor or bank, or entry into new markets. It is needed when the priority is not to close one question in isolation, but to make sure that the whole structure can withstand external review and remain robust as it develops further.
How does the audit work and what do I receive?
The audit proceeds as a sequential review of the model across all elements of the system, identifying risk zones and their interconnections. The output is a coherent picture of the structure, a vulnerability map, priorities and aligned logic in which tax, banking and regulatory components are assembled into one defensible model, ready for growth and review.
If the structure needs to be redesigned
When the audit shows that the model requires not a targeted correction but a new route, we design the structure strategy: jurisdiction roles, ownership, governance, banking and KYC logic. Registration and local actions are coordinated through local counsel and specialist professionals. We design the architecture — we do not replace the registrar.
If the matter requires local legal, tax or regulatory action in a specific jurisdiction, LEXONYX coordinates work with local counsel, tax advisers and registration agents. LEXONYX does not replace local regulated advice where it is mandatory and does not guarantee account opening, licensing or any specific tax outcome.
HOW TO ENGAGE
Choose the work format by the stage of the task
For an investor, financing, sale or major structural change, the Strategic Structure Audit is often the natural starting point when the existing model must withstand external review. A defined remediation or restructuring mandate can move directly into a project.
Express Risk Review
Use only when the transaction perimeter is still unclear and a bounded triage is needed before committing to a wider mandate.
Open format →Strategic Structure Audit
Use when the existing international structure must be reviewed as one system before investor due diligence, financing, sale or a major change.
Open format →Project-Based Advisory
Use for defined pre-transaction restructuring, remediation, evidence preparation, due-diligence response or implementation of agreed changes.
Open format →Ongoing Advisory
Use after the transaction only where continuing cross-border coordination, integration or monitoring has a defined recurring scope.
Open format →NEXT STEP
If what is needed is not an answer to one question, but a coherent map of the model
Describe the current structure, geography, team and main question.
We will define the relevant scope and confirm whether a strategic audit is the appropriate work format for the task.