Cross-Border Structuring
Practical guides to structuring holdings, SPVs and multi-jurisdiction arrangements — covering the design principles, documentation requirements and compliance obligations for international structures.
Cross-Border Guide Topics
- Multi-entity holding structure design principles
- SPV architecture for specific use cases
- Jurisdiction combination guides
- Intercompany agreement documentation
- Beneficial ownership & substance compliance
- CRS, FATCA and transparency mapping
Topics & Content Areas
Holding Structure Design Guide
A practical guide to designing multi-entity holding structures — covering the layers of a typical holding structure, how to allocate assets and activities across layers, and the governance framework that should accompany each layer.
SPV Use Case Guides
Specific guides to SPV design for common use cases — real estate holding, co-investment, project finance, IP holding and joint venture — covering entity type, jurisdiction, governance and documentation requirements for each.
Jurisdiction Combination Guides
Practical guides to common jurisdiction pairings — UAE + BVI, UAE + UK, Luxembourg + Cayman, ADGM + Jersey — covering why these combinations work, how they interact and what compliance is required to maintain them.
Intercompany Agreements
Guide to the intercompany agreements required in a multi-entity structure — loan agreements, management fee agreements, service agreements, IP licensing — covering standard terms, transfer pricing considerations and documentation standards.
Substance & Beneficial Ownership
A guide to economic substance requirements across key jurisdictions — BVI, Cayman, UAE, Jersey, Guernsey — and beneficial ownership registration obligations, covering what is required, who must comply and what the consequences of non-compliance are.
CRS & FATCA Compliance Map
A practical mapping guide to Common Reporting Standard and FATCA obligations — who reports what, to which authority, and how a multi-entity holding structure is treated under each framework.
How to Use These Resources
Cross-border structuring guides are most useful when they help you understand the design logic — not just the mechanics. A structure that is mechanically correct but architecturally wrong will create problems that no amount of documentation can fix.
We write these guides to transfer the analytical frameworks we apply in advisory practice — so that you approach structuring decisions with the right questions before you commission the structure.
Structure Types Our Guides Cover
- Family holding company — UAE/BVI or UAE/Cayman
- Real estate holding structure — UK property, offshore ownership
- Fund structure — LP, LLC, Unit Trust with SPV layer
- Operating group holding — trade business with investment layer
- JV structure — two or more parties in a shared holding vehicle
- Pre-IPO restructure — founder and investor ownership layers
Guide Contents
- Design principles for the structure type
- Typical entity and jurisdiction architecture
- Intercompany relationship map
- Documentation requirements
- Compliance and reporting obligations
- Common structuring errors to avoid
Compliance Areas We Map
- Economic substance by jurisdiction
- CRS/FATCA reporting obligations
- Beneficial ownership registration
- Transfer pricing documentation
- Annual filing requirements by entity
How to Navigate
Identify Your Structure Type
Find the guide most relevant to your structure — holding company, SPV, multi-jurisdiction or specific use case.
Understand the Design Principles
Each guide explains not just what to do but why — giving you the framework to apply to your specific situation.
Check Compliance Requirements
Use the compliance mapping sections to identify what ongoing reporting and registration obligations your structure creates.
Review with Your Adviser
These guides are designed to complement, not replace, professional advisory. Use them to brief your advisers effectively.
Frequently Asked
Need a Bespoke Structure Design?
Guides provide frameworks — our advisory team provides bespoke design. Speak with us about your specific holding or investment structure.