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Tax & Structuring

International tax, transfer pricing, holding architecture, free-zone strategy and indirect tax — under one roof, written, defensible.

What this service is

Tax architecture is the discipline that decides whether a multi-jurisdiction enterprise actually keeps what it earns. Kaelo Advisory runs the practice as five linked specialisms with one shared standard: every recommendation goes out in writing, every position is defensible under audit, and every structure is one we would deploy on the group’s own balance sheet. The pages below describe each specialism in detail; this page is the entrance.

“Tax architecture is the layer most enterprises only review once a decade. The five jurisdictions you are choosing today will shape every operating decision you make until the next time you open the file.”

— An Operating Council principal, Kaelo Advisory

What we are accountable for

Where the work lands.

  1. 01

    01. International tax planning

    Cross-border tax architecture for multinational groups. Treaty optimisation, repatriation, foreign-tax credits.

  2. 02

    02. Transfer pricing advisory

    Intra-group pricing policy, master and local file documentation, audit defence.

  3. 03

    03. Corporate holding & domicile

    Where to hold the operating businesses, and why. Substance, governance, migration.

  4. 04

    04. Free-zone & SEZ advisory

    UAE free zones and SEZs — which one fits the business, what the licence costs over five years, where the substance has to sit.

  5. 05

    05. VAT, customs & indirect tax

    Supply-chain structuring for indirect tax, registration discipline, e-invoicing readiness.

How we engage

From first email to standing review.

  1. 01

    Written diagnostic across the five specialisms

    Two-to-three-week review covering international tax architecture, transfer pricing, holding structure, free-zone fit and indirect-tax footprint. Written, no fee for the diagnostic phase.

  2. 02

    Scope letter on the right specialism

    Most groups need one or two of the five; we tell you which, and we write the engagement on that scope rather than bundling the whole tax practice.

  3. 03

    Delivered by specialists, not by generalist bench

    Each specialism inside Tax & Structuring is run by a named principal. The mandate is delivered by the principal, not by junior staff briefed for the call.

  4. 04

    Annual review built in

    The five specialisms move every year — OECD updates, UAE regulatory changes, treaty network shifts. Standing engagements include an annual update review.

Where this applies

The sectors this service is shaped for.

When to call us

The shape of the moment this work usually arrives in.

  1. 01

    You are restructuring or migrating a group across more than two jurisdictions and need an architecture review across all five specialisms in one engagement.

  2. 02

    You are preparing for a tax authority audit and the existing documentation will not hold up across the relevant specialisms.

  3. 03

    You are entering the UAE at scale and need the free-zone, holding, treaty, transfer pricing and VAT layers designed as a single architecture, not as five separate decisions.

  4. 04

    You inherited a structure from another advisor and want an independent written review before committing to the next operating cycle.

Recent mandate, anonymised

Redesigned a four-jurisdiction holding and intra-group flow.

Structural cost cut sharply; substance retained; documentation built to defend the position in audit.

Family office · 4 jurisdictions · 8 weeks

Engagement profile

Standing annual tax-architecture review for a consumer group operating across five markets.

Each year, a written review across all five Tax & Structuring specialisms. The architecture has remained defensible through three regulatory cycles since the engagement began.

Consumer group · Multi-market · Standing annual engagement

For clarity

What we will not do here.

  • We do not file tax returns. Filings sit with locally licensed practitioners; we will recommend partners where Kaelo does not hold the licence.
  • We do not provide standalone tax-residency advice for individuals — the practice is enterprise- and family-office-led.
  • We do not market structures based on regulatory grey areas. Every architecture we recommend is one we can defend in writing under audit.
  • We do not work on engagements where the structural conclusion has been agreed before our review.

Frequently asked

The questions that arrive first.

01 Is Tax & Structuring a single engagement or five separate ones?
Either. Most groups need the diagnostic across all five specialisms, and one or two specific work-streams afterwards. The scope letter is written against what you actually need, not bundled. The five specialisms are International Tax Planning, Transfer Pricing, Corporate Holding & Domicile, Free Zone & SEZ, and VAT, Customs & Indirect Tax.
02 Where does Kaelo work geographically on tax architecture?
GCC and the UAE specifically, India, ASEAN, Bermuda holding structures, and the EU/UK as counterparty markets — matching the five offices. For jurisdictions outside this footprint we work with locally licensed counsel.
03 Do you advise on individual tax residency, wealth or estate planning?
No. The Tax & Structuring practice is enterprise- and family-office-led. Individual residency, wealth and estate planning are out of scope; we can refer to specialist practices where appropriate.
04 How does your work respect local regulatory regimes?
Where Kaelo does not hold a local tax-advisory licence, the work is delivered alongside locally licensed counsel under engagement structures that respect the licensing rules of the jurisdiction. Full position on Regulatory Disclosures.
05 How is fee structure agreed?
Fixed fee for the diagnostic phase. Fixed-scope fee for each subsequent work-stream. Annual fixed fee for standing-review engagements. No hourly billing, no contingent fees, no scope creep without a written addendum.
06 Reference points for the framework you operate inside?
The OECD BEPS framework — particularly Pillar Two on the global minimum tax — sets the perimeter of most modern international tax architecture. UAE-specific work operates under the UAE Federal Tax Authority rules. We design within those frameworks; we do not work around them.
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