Corporate Structuring
Multi-jurisdictional holding groups, IP-routing structures, JV vehicles and re-domiciliations.
Corporate structuring is what happens before a single company is incorporated. We map the operating entities, holding layers, IP vehicles and financing conduits a group actually needs — matched to its counterparties, its treaty network and the tax residency of its ultimate owners.
The output is a written structure memorandum: an entity diagram, a substance map for each layer, a treaty and withholding analysis, and a step-plan for implementation or re-domiciliation. It is the document your auditor, your bank, your tax counsel and any future acquirer will read.
We are independent. We do not sell licences, banking products or funds. That means the structure we recommend is the structure we would build for a family member — not the one that pays the largest commission.
Scope of engagement
- Treaty-network mapping
- Substance modelling
- Cross-border re-domiciliation
Typical clients
- Founders preparing for a Series B, cross-border expansion or an exit
- Groups consolidating twenty-plus entities into a coherent holding tree
- Families relocating tax residency and needing the corporate stack to follow
- Managers migrating a fund or operating group between jurisdictions
A named director on the file, from first call to handover.
Two-week review of existing entities, IP, contracts and tax residency footprint.
Two or three structure options with tax, substance, banking and reputational trade-offs written out.
Full structure memorandum signed by a director, with a step-plan and gantt for implementation.
Incorporations, migrations, share transfers, IP assignments and intra-group agreements executed under one project manager.
Board packs, group policies and an annual compliance calendar for the new structure.
What you receive.
Every engagement closes with a director-signed handover pack — retained on file for thirty years.
- Structure memorandum with entity diagram
- Treaty-network and withholding analysis
- Substance model for each layer
- Intra-group agreements and IP assignments
- Board resolutions and shareholder consents
- Implementation project plan
Jurisdictions in active use for this service.
Questions we hear on every intake call.
- How long does a full restructuring take?
- A typical group restructuring — diagnostic, design and implementation — runs four to ten weeks. Cross-border re-domiciliations and IP migrations can extend that to three to four months.
- Can you work alongside our existing tax counsel?
- Yes. Most of our structuring engagements are run alongside a Big Four or Magic Circle tax team. ASJ Group owns the corporate design; your tax counsel signs off on the tax opinion.
- Do you help implement, or only design?
- Both. The design memorandum is only useful once it is built. We run the implementation — incorporations, migrations, share transfers, agreements — under a single project manager.
Start with a twenty-minute call. Leave with a written scope.
Every engagement begins with a director — not a junior, not a chatbot. Fixed fees, quoted in writing, before any work begins.
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Every engagement begins with a twenty-minute director-led call. Fixed fees, in writing, before any work begins.