International Tax Planning & Structuring
Cross-border tax architecture for multinational groups headquartered in or operating through the GCC. Designed for the BEPS Pillar Two world, not the world before it.
What this service is
International tax planning is structural work, not seasonal compliance. Kaelo Advisory designs and reviews the architecture an enterprise will live inside for the next decade: where the holding company sits, where profit attaches, which treaties protect which flows, and how repatriation works when the operating businesses generate the cash they were built to generate. The framework we operate inside has been rewritten by the OECD’s BEPS programme; the architectures we design today have to meet the substance requirements being applied now, not the substance requirements that were enough five years ago.
“International tax architecture is not a tax decision. It is a structural decision about where the operating business will live for the next decade — and the only person qualified to make that call is someone who has lived through one.”
— An Operating Council principal, Kaelo Advisory
What we are accountable for
Where the work lands.
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01
Jurisdictional architecture
Selection and documentation of the holding, intermediate and operating jurisdictions for the group. Built for substance, not for slide decks. Where the UAE figures in the architecture, we work within the framework set by the UAE Federal Tax Authority and the regulated free zones, including the DIFC where applicable.
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02
Treaty network optimisation
Mapping the treaty positions that protect dividend, interest and royalty flows — and the positions that would expose them after Pillar Two. Treaty work is reviewed against the multilateral instrument and the principal-purpose test, not against a legacy bilateral position.
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03
Foreign tax credit management
Where credits are usable, where they expire, and how the group’s claim history reads to a foreign tax authority. Documented annually; defensible under audit.
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04
Repatriation strategy
Cash and capital movement from operating jurisdictions back to the group, structured to survive scrutiny from both ends. Withholding-tax positions, anti-conduit rules and beneficial-ownership tests considered as a unit, not as separate problems.
How we engage
From first email to standing review.
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01
Bilateral diagnostic, in writing
A two-to-three-week initial review of the group’s current tax architecture, with a written diagnostic document. No fee, no commitment beyond a non-disclosure framework. The diagnostic surfaces the highest-leverage structural questions before we agree what (if anything) to engage on.
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02
Engagement letter, fixed scope
If the diagnostic surfaces work we are the right people for, we write a fixed-scope engagement letter: deliverables, timeline, fee, and the named principals on both sides. We do not run open-ended retainers on initial mandates.
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03
Working in writing, alongside your team
The work runs in writing — written analysis, written recommendations, written audit-defence positions — alongside your finance, legal and tax teams. No off-the-record verbal advice that disappears at year-end. See our Compliance & Ethics posture.
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04
Standing review on annual cycle
Where the group wants ongoing tax-architecture oversight, the engagement converts to an annual standing review. Reviewed in writing, fee documented, no automatic renewal.
Where this applies
The sectors this service is shaped for.
When to call us
The shape of the moment this work usually arrives in.
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01
You are restructuring a group across more than two jurisdictions, and your current advisor’s recommendation depends on assumptions you cannot cross-check.
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02
You are preparing for a Pillar Two effective date and the current documentation will not defend the position under the global minimum-tax regime.
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03
You are migrating a holding company and need the migration designed, sequenced and pre-cleared with both regulators.
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04
You are entering a new operating jurisdiction at scale, and the structural decision today decides what the business looks like in five years.
Engagement profile
Multi-jurisdiction architecture for a privately held industrial group.
A written design, a written transition plan, and a written defence position prepared in advance of any future audit. Reviewed annually as part of the standing engagement.
Recent mandate, anonymised
Migrated a multi-jurisdiction holding architecture ahead of the Pillar Two effective date.
The diagnostic identified two structural exposures the incumbent had not flagged. The migration was sequenced over fourteen months; both jurisdictions were pre-cleared; the year-end position closed in line with the written engagement plan, with the audit-defence file already on the shelf.
For clarity
What we will not do here.
- We do not file tax returns. Filings sit with your finance team and locally licensed tax practitioners; we can recommend partners where Kaelo does not hold the licence.
- We do not provide international tax advice in jurisdictions where we lack locally licensed counsel; in those cases we work alongside your existing counsel.
- We do not offer aggressive structures that depend on regulatory interpretations we cannot defend in writing.
- We do not work on engagements where the structural conclusion has been pre-decided before our review begins.
Frequently asked
The questions that arrive first.
- 01 Do you handle tax filings for our group?
- No. We design and review international tax architecture; we do not file tax returns. Filings sit with your finance team and locally licensed tax practitioners. We can recommend partners where Kaelo does not hold the licence directly.
- 02 Are you a regulated tax advisor?
- Kaelo Advisory is not a financial-services-regulated tax adviser in any single jurisdiction. The advisory work we conduct is provided by Kaelo principals working alongside locally licensed practitioners, under engagement structures that respect the licensing regime of the jurisdiction in question. Our full regulatory position is on Regulatory Disclosures.
- 03 How does your work interact with OECD BEPS and Pillar Two?
- BEPS Pillar Two — the global minimum tax — has fundamentally changed the calculus of international tax planning. We design architectures that meet the substance requirements being applied today, not what was enough five years ago. Where Pillar Two applies to a client’s group, the engagement starts from that constraint, not from a preferred outcome. Reference: OECD BEPS framework.
- 04 Can you work alongside our existing tax advisors?
- Yes — that is often how the work runs. Many of our engagements are structured as second-opinion or architecture-review work conducted alongside the client’s incumbent tax counsel or in-house team. We do not require exclusivity, and we will say in writing where we agree or disagree with the incumbent view.
- 05 How long does an international tax architecture engagement take?
- The diagnostic phase is two to three weeks. A typical written-recommendation engagement runs six to twelve weeks. A migration or full restructuring runs six to eighteen months. Standing annual review engagements run year-on-year. All scopes are documented in writing before work begins.
- 06 What jurisdictions do you concentrate on?
- Kaelo operates from five offices — Dubai, Delhi, Singapore, Seychelles and Bermuda. The international tax architecture we are deepest on is GCC + UAE, India, ASEAN, Bermuda holding structures, and the EU/UK as a counterparty market. Outside those, we work with locally appointed counsel.
- 07 How does international tax planning interact with the other Tax & Structuring services?
- Architecture decisions cascade. Holding & Domicile decides where the entities sit; Transfer Pricing decides how the intra-group flows are priced; Free Zone advisory handles the UAE-specific licensing; VAT & indirect tax handles the transaction layer. The international tax architecture is the umbrella those four sit under.
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