Structure guides

How structures actually work, drawn out.

Each guide sets out one structure tier by tier — who owns what, where the cash and the reporting go, what the tax drivers are, and the points at which these structures fail in practice. Diagrams first, prose second.

The library

8 structures, mapped.

Written by directors, sourced from primary legislation and regulator guidance, and dated so you know how current they are.

Holding · Europe

The Luxembourg SOPARFI holding structure, explained

How a SOPARFI sits between an operating group and its shareholders, why the participation exemption is the whole point, and the conditions that decide whether a European exit is taxed or not.

9 minUpdated February 2026
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Holding · Gulf

UAE free zone company under a holding, mapped

How DIFC, ADGM and DMCC entities sit under a UAE holding or foundation, what the 0% Qualifying Free Zone Person status actually requires, and how groups lose it.

8 minUpdated February 2026
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Funds

The Cayman master-feeder fund, drawn out

Why there are two feeders, what the master actually does, where the manager sits, and which entity in the chart carries the economic substance obligation.

8 minUpdated February 2026
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Asset holding

BVI holding company with asset SPVs

The segregation logic behind one holding company and several single-asset SPVs, the reduced substance test for pure equity holding, and what the 2025 beneficial ownership access reforms changed.

7 minUpdated February 2026
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Private wealth

Discretionary trust with a private trust company

Where the PTC sits, who controls it, how reserved powers work without collapsing the trust, and why Guernsey's 2025 perimeter guidance matters to families who thought they were unregulated.

9 minUpdated February 2026
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Licensing · Fintech

How an EU e-money institution is structured

Holding company, licensed EMI, safeguarding accounts and passporting — where client money actually sits, what capital is required, and what PSD3 will change.

8 minUpdated February 2026
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IP · Tax

IP holding and royalty structures after BEPS

Cyprus, Ireland and the Netherlands compared through the modified nexus fraction, plus the DEMPE question that decides whether the royalty is respected at all.

8 minUpdated February 2026
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Real assets

Yacht ownership: company, flag and VAT

How the owning company, the flag and the lease interact, and why the pre-2020 Malta VAT percentage tables that still circulate are the fastest way to create a problem.

7 minUpdated February 2026
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Is your structure still the right one?

Most of the structures we review were correct when they were built and wrong by the time we saw them. Send us the current chart; we will tell you what we would change and what we would leave alone.