International tax planning — where does doing it myself start to cost money?
Some of it, yes — and we will say so on the call if that is the honest answer. The parts that are worth paying for are the ones where a missed election, a missed deadline or an unverified threshold costs more than the fee: the framework is residence, source, treaty entitlement and substance, applied to a real business plan.
What if I have already filed and got it wrong?
That is a common starting point. We re-derive the position, identify whether an amendment or a disclosure route is the right vehicle, and tell you which one preserves the relief that is still available. The order matters more than the speed.
How long will it take?
It depends on the documents rather than on us. Once the pack is complete most filings turn around inside a fortnight; anything that needs a certificate from a tax authority runs on that authority's timetable, which we tell you at the start rather than at the end.
Will moving my company to a low-tax country actually lower my tax bill?
Only if the people, the decisions and the risk move with it. A rate comparison tells you what a jurisdiction charges a company that genuinely belongs there. It tells you nothing about whether your company will be treated as belonging there. Residence, source and treaty entitlement are decided on facts, and the facts are where management meets, who negotiates the contracts, who carries the commercial risk, and who can be shown to have done so. A structure that moves the registration and leaves the substance behind produces two authorities each taxing the same profit, plus the cost of arguing about it. Start from where the business actually operates, then ask what is available.
What does substance mean when a tax authority looks at my structure?
In practice it means people who make real decisions, in the place the entity claims to be. Not a registered office, not a director who signs what is sent to them, and not a board meeting minuted in a city nobody flew to. An examiner tests substance by asking who decided, where they were, what they were competent to decide, and what the entity would have done differently if the decision had gone another way. The documents follow from that rather than substituting for it. If the answer to every question is a person sitting in a different country, the structure is describing something that is not happening.
Can a holding company claim treaty benefits if it has no employees?
It has to get past the anti-abuse tests first, and those now ask whether obtaining the benefit was a main purpose of the arrangement. That question is answered with commercial reasoning, which makes the business rationale part of the tax analysis rather than something separate from it. A holding company that exists to group operating subsidiaries, with people who exercise real ownership functions, can usually explain itself. One inserted into a payment route shortly before the payments began, with nobody in it, generally cannot. The test is not whether an employee exists but whether the arrangement would make sense if the treaty benefit were removed from it.
Another adviser designed my structure — how do I get it checked?
By having the framework applied to it again from the beginning, independently: residence of each entity, source of each income stream, treaty entitlement where one is claimed, and substance where it is required. A second opinion is worth most before implementation, because unwinding a structure costs more than choosing a different one. Ask for the review to state, in writing, which positions depend on facts that have not yet happened, because those are the ones that quietly fail later. A structure that survives an examination is one whose commercial rationale was written down at the time, not reconstructed afterwards when somebody asks.
When should I get tax advice before selling my business?
Earlier than feels necessary, because the useful options close as the transaction approaches. Once a buyer is identified and heads of terms exist, most of what could have been done to the ownership structure now looks like it was done for the transaction, which is exactly the question anti-abuse tests ask. Planning that has commercial reasons of its own, put in place while the sale is still hypothetical, reads differently from the same steps taken weeks before signing. A review a couple of years ahead of an expected exit also surfaces the filing and residence problems that a data room will find anyway, while there is still time to fix them quietly.
Does my company pay tax where it is registered or where I live?
Potentially both, which is the problem. Registration establishes one connection; where the company is actually managed establishes another, and many systems treat the second as decisive for residence. If you make the real decisions from your kitchen table in another country, that country has an argument that the company is resident there too. A treaty may resolve the conflict, but only if the company is entitled to it, and entitlement is itself tested against substance and purpose. The honest answer is that residence is a conclusion drawn from facts about people and decisions, not a choice made on an incorporation form.
Is double taxation illegal?
It is legal. Two countries can each have a valid claim on the same income — one because the income arose there, the other because you live there — and nothing prohibits both from exercising it. What exists instead is relief: tax treaties allocate the claim, and domestic law gives a credit for foreign tax paid. The relief is not automatic, though. It is claimed on a return, and unclaimed relief is simply lost. See how double taxation is relieved.
How does the treaty tie-breaker work when both countries say I am resident?
As a sequence, stopping at the first test that gives an answer: where you have a permanent home available; if in both or neither, where your centre of vital interests is; then habitual abode; then nationality; and if all of those tie, the two tax authorities decide by agreement. It is evidential rather than elective — you do not choose your treaty residence, you demonstrate it, which makes the record of homes, family and time the substance of the claim. See tie-breaking dual residency.
