Structuring · Service 01
Structure that makes sense across every border you operate in
When your business spans multiple countries, the way your entities relate to one another matters — for compliance, for clarity, and for the decisions you'll need to make as you grow. This is where a cross-border structuring engagement can bring real order to a situation that often feels opaque.
What this delivers
A clear picture of how your structure sits across jurisdictions — and what to do about it
Most businesses that operate internationally reach a point where the original structure no longer reflects the way the business actually works. Entities accumulate, intercompany arrangements evolve informally, and the relationship between them — from a tax perspective — becomes harder to articulate with confidence.
A structuring engagement with Margyn works through that complexity methodically. You come away with a documented picture of where things stand, identified areas where alignment with applicable frameworks can be improved, and a practical set of steps for moving forward.
Documented structuring memorandum
A written output covering your entity structure, intercompany arrangements, and treaty positions — with findings and recommendations in plain language.
Practical implementation steps
Not just analysis — a sequenced set of actions your team or local advisors can work from to move the structure toward better alignment.
Treaty position clarity
We review applicable tax treaties and identify where they interact with your structure in ways that are worth understanding before decisions are made.
A familiar situation
Operating across borders without a clear structural picture is more common than it should be
Businesses that expand internationally rarely do so in a straight line. A holding company is set up in one jurisdiction, operations start in another, a subsidiary is added later when entering a new market. Over time, the intercompany flows — fees, loans, dividends — follow patterns that made sense at the time but were never formally reviewed through a tax lens.
The result is often a structure that functions day-to-day but sits on unstated assumptions about where obligations fall and how transactions are characterised. When those assumptions are examined — by an auditor, by a new CFO, or simply by the business itself — they don't always hold.
The discomfort isn't usually about wrongdoing. It's about operating without a clear picture of how the structure relates to the tax frameworks across the jurisdictions where the business exists. That uncertainty compounds as the business grows.
This is the situation a cross-border structuring engagement is designed to address — not with alarm, but with methodical clarity about where things stand and what the practical options are.
The approach
How we work through cross-border structuring
Margyn's structuring work is built around your actual situation — not a template applied from outside. The engagement covers the jurisdictions, entity types, and transaction flows that matter to your business, reviewed against the applicable regulatory and treaty frameworks.
Entity and flow mapping
We begin by building a clear picture of your current structure — which entities exist, where they are incorporated, and how transactions flow between them. This becomes the reference point for everything that follows.
Regulatory and treaty review
We assess how the structure sits against the local tax rules in each relevant jurisdiction, and identify where applicable bilateral treaties affect the characterisation of payments or the allocation of taxing rights.
Structuring memorandum
Findings are consolidated into a written memorandum covering where alignment can be improved, what the options look like, and the implementation steps that follow from each path forward.
What working together looks like
A structured process with clear milestones and a defined outcome
The engagement is designed to be collaborative without being burdensome. We handle the analysis; you provide context. At the end, you have a document your team can actually use.
Intake conversation
We discuss your jurisdictions, entity types, and the specific questions you want the engagement to answer.
Document review
You share existing corporate and intercompany documents; we review them as the basis for analysis.
Analysis phase
We carry out the regulatory and treaty review, identifying alignment gaps and structuring options.
Memo and walkthrough
You receive the structuring memorandum and implementation steps, with a session to work through the findings together.
Investment
Transparent pricing for defined scope
The engagement is priced at a flat fee following a brief scoping conversation. Because cross-border structures vary considerably in complexity, we confirm the final scope — and confirm the fee — before work starts.
Service investment
$6,000 USD
Flat fee · Defined scope · Confirmed before engagement starts
For businesses with more extensive structures spanning a larger number of jurisdictions, scope and fee are agreed following the initial review. Nothing starts until both are confirmed in writing.
What's included
Scoping conversation
Initial session to establish the jurisdictions, entities, and questions in scope.
Entity and intercompany flow review
Analysis of your existing corporate structure and transaction flows across relevant jurisdictions.
Treaty position analysis
Review of applicable bilateral tax treaties and their interaction with your structure.
Written structuring memorandum
Documented findings, alignment gaps, and options — in plain language your team can act on.
Implementation steps
A sequenced action plan for moving from current state to improved structural alignment.
Findings walkthrough
A review session to work through the memorandum and answer questions about next steps.
Methodology
What makes this engagement effective
Built from your actual documents
We work from your existing corporate records and intercompany agreements, not from abstract assumptions. The analysis reflects what's actually in place.
Jurisdiction-specific, not generic
Each jurisdiction in scope is reviewed against its own regulatory framework. We don't apply a one-size approach to rules that vary meaningfully from country to country.
Plain-language output
The memorandum is written to be read and used — not filed away. Findings are explained in a way that works for non-specialist readers as well as legal and finance teams.
Realistic timelines
Engagements of this type typically run four to eight weeks from confirmed scope to final deliverable, depending on the number of jurisdictions and complexity of the structure.
Our commitment
You'll know exactly what you're getting before we start
Scope is confirmed in writing before the engagement begins. You'll have a clear description of what will be covered, what the deliverable looks like, and what the fee is. Nothing starts until you're comfortable with all three.
Written scope confirmation
Scope and fee agreed and documented before work commences.
Access throughout
Questions during the engagement are addressed as they come up, not left for the end.
Usable deliverable
The memorandum is reviewed with you and revised if any aspect of the analysis needs clarification.
How to get started
Getting in touch is the first step — and the only one you need to take right now
Send a brief description of your situation — the jurisdictions involved, the nature of your structure, and the questions you're trying to answer. We'll review it and come back to you about whether and how we can assist, and what a scoping conversation would look like.
Send your message
Use the contact form to describe your situation. A paragraph is enough to start the conversation.
Initial conversation
We'll discuss your structure, jurisdictions, and what you need the engagement to answer.
Confirmed scope
We agree scope and fee in writing. Work begins once both are confirmed — no earlier.
Cross-Border Tax Structuring
Ready to bring clarity to your cross-border structure?
Describe your situation — jurisdictions, entity types, the questions you need answered — and we'll take it from there.
Start the conversationOther services
Explore related service areas
Documentation
Transfer Pricing Documentation
Functional analyses and local-file reports that support the arm's-length nature of your intercompany transactions.
From $8,000 USD
Learn moreIndividual
Expatriate Tax Services
Compliance and advisory for individuals living and working across borders — coordinated filings, foreign tax credits, and treaty-based relief.
From $3,500 USD
Learn more