Core Structuring

Offshore & Onshore Planning

We advise on the integration of offshore and onshore structures — designing a cohesive planning framework that aligns your assets across jurisdictions for tax efficiency, regulatory compliance and long-term resilience.

Planning Scope

  • Offshore structure selection & jurisdiction design
  • Onshore wrapper & holding entity advisory
  • Tax treaty network & residency alignment
  • Substance planning for offshore entities
  • CRS/FATCA & transparency compliance
  • Onshore-offshore capital flow design
What We Deliver

Our Advisory Services

Jurisdiction Architecture

We design the combination of offshore and onshore entities that best serves your tax residency, asset location and succession objectives — with each jurisdiction selected for a specific, documented reason.

Substance Planning

We advise on economic substance requirements for offshore entities — real presence, decision-making, local directors — to ensure your structure withstands regulatory and tax authority scrutiny.

Tax Treaty Alignment

Positioning your holding and personal structures to benefit from tax treaty networks — withholding tax reduction, capital gains treaty protection, double tax relief — without aggressive positions that attract challenge.

CRS & FATCA Compliance

Mapping your structure against Common Reporting Standard and FATCA reporting obligations — ensuring you are compliant, informed and not surprised by automatic information exchange disclosures.

Onshore Wrapper Design

Advisory on onshore holding entities — UK companies, UAE mainland entities, EU operating structures — that sit above or alongside offshore vehicles to satisfy local regulatory and banking requirements.

Capital Flow Architecture

Designing how capital moves between onshore and offshore entities — dividends, loans, service fees, capital repatriation — with documentation that satisfies banks, regulators and tax authorities in every jurisdiction.

Our Approach

Built for Real Outcomes

The distinction between "offshore" and "onshore" has blurred significantly in the past decade. The real distinction today is between compliant and non-compliant — between structures that are disclosed, substantive and transparent, and those that are not.

We design offshore and onshore structures for the world as it is today: with automatic information exchange, beneficial ownership registers and global minimum tax. Every structure we advise on is built to withstand scrutiny.

Jurisdictions We Advise On

  • UAE — zero income tax, ADGM and DIFC regulated structures
  • BVI — flexible offshore holding, VISTA trust capability
  • Cayman — preferred for complex fund and trust structures
  • Jersey & Guernsey — established common law wealth planning
  • Luxembourg — EU-compliant holding and SICAV structures
  • UK — non-domicile planning, LLP and company structures

Why Clients Use Offshore Structures

  • Tax treaty access and withholding tax reduction
  • Asset protection from home country creditors
  • Currency and political risk diversification
  • Privacy within CRS-compliant frameworks
  • Succession planning across multiple jurisdictions

What We Deliver

  • Offshore-onshore structure design memo
  • Jurisdiction rationale matrix
  • CRS/FATCA compliance map
  • Substance planning checklist
  • Capital flow design document
100+
CRS-participating countries — full compliance by design
UAE
Zero-tax hub at the centre of most structures
BVI
Cayman & BVI — most flexible offshore jurisdictions
100%
Transparent & compliant — no evasion, ever
Process

How We Work

01

Residency & Domicile Review

We map your tax residency, domicile and the jurisdictions in which you hold assets or have obligations.

02

Structure Mapping

We design the offshore-onshore architecture with jurisdiction rationale for each entity.

03

Compliance Assessment

We map CRS/FATCA, substance and reporting obligations across the full structure.

04

Documentation & Coordination

We coordinate with legal and tax counsel in each jurisdiction to document the structure correctly.

Common Questions

Frequently Asked

Yes — offshore planning is entirely legal when properly structured and disclosed. The key principles are transparency (declaring offshore assets and income to your tax authority), substance (genuine presence and decision-making in the offshore jurisdiction) and treaty compliance (following the rules of applicable tax treaties). Avoidance and evasion are different things — we always advise on the former, never the latter.
Common Reporting Standard means that bank account information, entity ownership and financial data is now automatically exchanged between 100+ countries. Offshore structures designed for secrecy no longer function as such. Modern offshore planning is about legitimate efficiency and substance — not opacity. We design structures that are CRS-transparent and built for the current regulatory environment.
Economic substance rules require that entities conducting certain activities (holding, financing, fund management, etc.) have genuine presence in the jurisdiction — real office, local directors, relevant employees or expense. The BVI, Cayman, Guernsey, Jersey and UAE all have substance legislation. We map substance requirements at the design stage and advise on how to satisfy them.

Ready to Align Your Offshore and Onshore Structures?

Our team designs integrated planning frameworks across UAE, BVI, Cayman, Jersey, Luxembourg and UK — compliant, efficient and built to last.