International tax planning

Start with how the income is earned

International tax planning begins with the person, business and transaction. The country named on an invoice is one fact among many. Where people work, who controls the company, the nature of income and the owner’s residence can change the answer.

Our focus is the interaction between jurisdictions: relocating, establishing real foreign operations, investing internationally or reconciling advice from several countries. Purely domestic optimisation is not our speciality. We can analyse a defined question or include the work in a complete implementation engagement.

Understand the result before making the change

• An analysis of the relevant personal, company and cross-border tax questions.
• A comparison of viable options, including transition and continuing costs.
• Clear assumptions, sources and the implementation decisions needed to support the recommendation.

When this is a good fit

This fits owners, investors and people relocating whose decisions involve more than one country. It can also resolve a defined uncertainty before a larger project.

Why work with Offshore Capitalist

We compare jurisdictions against your circumstances rather than beginning with a destination to sell. The work explains why the proposed mechanism applies and how the operational facts must support it.

Follow the income through every layer

A useful model follows revenue into the operating business, through any related entities and ultimately to the owner. Retained earnings, salary, dividends, interest, capital gains and a future company sale need not have the same treatment. The plan should distinguish them.

The model also asks what happens if assumptions change: profit is lower, more money is distributed, the owner spends more time at home or a new customer market becomes material. A structure with a narrow best-case result may be less useful than one with a stronger range of outcomes.

Residence, source and attribution answer different questions

Residence identifies a connection between a taxpayer and a country. Source addresses the connection between income and a place. Attribution rules can bring specified foreign income into an owner’s calculation even before money is distributed. Treating these as one test is a common cause of incomplete advice.

For example, the IRS generally sources personal-service compensation to where the work is performed, rather than where the payer or payment is located. That is a US rule, not a universal rule for every income type; it illustrates why the legal character and location of the activity need to be identified before drawing conclusions.

Compare the complete cost of the alternatives

We compare realistic options, including retaining the current setup with improvements. The calculation should include tax at relevant levels, setup and exit costs, recurring administration, management or substance costs and practical constraints. Different objectives can justify different answers.

An owner planning to sell in two years may need a different arrangement from an owner reinvesting for a decade. A family who can move has different options from a founder who must remain close to a local team. These are design inputs, not details to ask about after selecting the country.

What the written work should explain

The analysis sets out the facts relied on, the applicable rules, the options considered and the assumptions that drive the preferred result. It should also identify open questions, decisions needing local confirmation and implementation dependencies.

The point is to make the reasoning inspectable. A conclusion such as “the income is foreign” is insufficient without explaining the relevant source rule and applying it to the activity. Equally, saying “there is a treaty” does not establish eligibility for its benefits.

Move from analysis to the agreed work

Once the strategy is understood and selected, the team can coordinate the implementation in scope. That may mean a company and accounts, residence applications, changes in contracts or introductions to independent management providers. Each step should be consistent with the reasoning.

A complete analytical engagement has historically taken four to eight weeks. A narrow question, a missing set of records and a multi-country restructuring have different workloads. We agree the scope and timing after reviewing the starting facts, and quote local opinions or regulated work only where expressly included.