Pay the tax you owe. Not a point more.
International tax structuring for digital businesses doing €1M–€100M+. Built to survive audits. Signed by lawyers — not sold by offshore brokers. We work alongside your Big-4, not around them.
- ◆AVG EFFECTIVE RATE REDUCTION11 pts
- ◆CLIENT TAX SAVED YTD 2026€62M
- ◆JURISDICTIONS COVERED23
- ◆AUDITS LOST IN 9 YEARS0
You're in the right place — probably.
- 01
Your group does €1M–€100M+ revenue across two or more countries.
- 02
Your effective rate is north of 25% and your accountant says that's 'just normal.'
- 03
You've heard 'Dubai / Malta / Delaware' from every peer and don't know which advice is real.
- 04
You have IP worth migrating, or remote employees in jurisdictions you can't name.
- 05
You're 12–24 months from an exit and worried about the tax hit on sale.
- 06
If you're looking for a 3% rate from a PO box in a tax haven — we're the wrong firm.
— If you want to legally keep 8–15 points you're currently overpaying, keep reading.
Before and after. Rates, flows, delta.
Two anonymised client archetypes. Same people, same revenue, different structure. Every rate is documented in the assumptions below each view.
Illustrative only. Not tax advice. Assumes post-ATAD2 / post-Pillar Two compliance. Your mileage depends on substance, facts, and timing.
The four ways this goes sideways
Not hypotheticals. Each of these is a file we've closed for a client who found us late.
Transfer pricing, unflagged.
Intercompany royalty flows set by your 2019 accountant. No contemporaneous documentation. Finanzamt opens a file.
IP migrated too late.
You wait until Series B to move the IP out of the operating entity. Exit tax triggers on market value, not book value.
R&D credits forgotten.
Four years of SaaS development. No claim filed. Statute of limitations closes windows one year at a time.
Audit lost on documentation.
Not because the structure was wrong — because nobody could produce the board minutes, benchmarking study, or intercompany agreements.
Substance, WHT, and CFC exposure at a glance.
Toggle columns to focus on what matters for your structure. Export to CSV and send to your accountant.
| Market | Corp rate | Min local directors | Substance test | WHT dividend (to EU) | WHT royalty | CFC exposure |
|---|---|---|---|---|---|---|
NLNetherlands | 25.8% | 1 | Local economic (ATAD) | 0% (PSD) | 0% | Low |
IEIreland | 12.5% | 2 | Management + control in IE | 0% (treaty) | 0–20% | Low |
LULuxembourg | 24.9% | 1 | Resident directors + local office | 0% (PSD) | 0% | Low |
MTMalta | 35% / 5% eff. | 1 | Trade carried on in MT | 0% | 0% | Medium |
CYCyprus | 12.5% | 1 | Management + control in CY | 0% | 0% / 10% | Medium |
DEGermany | ~31% (incl. trade) | — | N/A (home) | 25% (5–15% treaty) | 15% | High |
CHSwitzerland | 12–21% cantonal | 1 (resident) | Resident director + office | 0–35% (treaty) | 0% | Low |
UKUnited Kingdom | 19–25% | — | Central mgmt & control in UK | 0% (domestic) | 20% (reduced by treaty) | Medium |
SGSingapore | 17% | 1 (resident) | Local director + office | 0% | 10% | Low |
AEUAE | 9% (0% free zone) | 1 | ESR: full local test | 0% | 0% | Medium |
USUnited States (DE) | 21% fed + state | — | N/A (home for US cos.) | 30% (5–15% treaty) | 30% | High (GILTI) |
PTPortugal (NHR/IFICI) | 21% / founder NHR | — | Individual residency: 183 days | 25% (0% treaty) | 25% | Medium |
Six things. Done right. Documented for audit.
International tax structuring
Your holding chart benchmarked against your revenue, geography, and exit horizon. We model three scenarios, you pick the defensible one.
- Treaty-driven entity placement (not 'tax haven' placement)
- Substance tests stress-tested before implementation
- 5-year forward model including exit
Transfer pricing
OECD-compliant intercompany pricing, documented the way auditors read it. The goal is boring files that close fast.
- Master file + local file + CbCR where triggered
- Benchmarking studies with live comparables
- Advance pricing agreements where volume justifies it
R&D tax credits
Most SaaS founders leave 4–7% of engineering spend on the table. We file, defend, and document — not just generate the paperwork.
- UK R&D, French CIR, German Forschungszulage, US §41
- Technical narratives written by people who read your repo
- Retroactive claims within statute windows
Holding & IP strategy
Where your IP lives determines 30% of your effective rate and 100% of your exit math. We get this right once.
- Ireland / NL / LU / CY / MT — honest comparison
- CFC rule modeling (GILTI, ATAD, Hinzurechnungsbesteuerung)
- IP migration with defensible valuation
Withholding tax + treaty planning
Royalty, dividend, and interest flows structured to use treaty rates instead of statutory ones. Documentation that survives beneficial ownership challenges.
- Treaty network mapping across payment flows
- Beneficial ownership + principal purpose test defense
- DAC6 / MDR reporting where required
Exit planning
The structure that was right at founding is wrong at exit. We fix it 18–36 months before the bankers are in the room.
- Pre-sale restructuring without triggering exit tax
- Participation exemption qualification
- Seller-side tax diligence pack
Where we structure, not just advise.
Flagship jurisdictions with full in-house depth. Active structuring across 12 more. Treaty and advisory coverage on request. One invoice, one point of contact.
Four phases. Scoped upfront. No hourly fog.
A typical structuring mandate runs 3–6 months from first call to steady-state. Quarterly reviews thereafter.
Discovery & map
Full read of your structure, filings, intercompany agreements, IP position. We produce a risk heatmap before proposing anything.
Structure design
Three scenarios modeled: aggressive, balanced, conservative. Rate, substance cost, audit exposure quantified for each. You pick.
Implementation
Entity formation, IP migration, intercompany agreements, substance build, rulings where available. Single point of contact throughout.
Ongoing review
Legislative change tracking, documentation refresh, pre-audit readiness. Because the rules change twice a year.
Range across active clients post-implementation
Cumulative savings logged in 2026
Direct counsel + vetted network
140+ defended positions across 9 years
Two files we closed.
Anonymised by client request. Every number is real.
Operating company in Germany, IP in Germany, customers in 14 countries. Effective rate 31.2%. Founder was a German tax resident with no plan for the next raise, let alone exit.
Migrated IP to a substance-backed Irish entity over 9 months — local directors, office, board meetings, contemporaneous valuation. Restructured intercompany royalties with OECD-compliant benchmarking. Filed 4 years of retroactive R&D credits across DE / FR / UK. Founder relocated to Portugal under NHR with full audit trail.
Post-structure effective rate 19.8%. Retroactive R&D recovery €1.1M in year one. Annual cash improvement ~€1.9M at current ARR.
“They told us which of the three options would survive an audit. The other two firms we talked to just pitched the cheapest rate.”
Six operating entities, Cayman holdco that looked great in 2018 and terrible to a German strategic buyer in 2025. 14 months before LOI. Baseline sale structure would have cost the sellers ~€9.4M in tax leakage. The buyer had flagged the offshore layer in early diligence.
Collapsed the Cayman layer into an EU holding (NL) qualifying for participation exemption. Repapered intercompany flows. Closed a formal ruling with the German tax authorities confirming no exit-tax trigger on the migration. Built the seller-side tax diligence pack before the buyer asked.
Clean participation exemption on close. Seller-side tax cost reduced by ~€9.4M vs. baseline. Buyer's tax counsel asked three questions on the restructure and moved on.
“We walked into diligence with a clean pack. The buyer's tax counsel asked three questions and moved on.”
Three ways to work together. All flat-fee.
We coexist with your Big-4. We don't replace them. Pick the commitment level that matches the mandate.
Structure Review
Fixed-scope diagnostic
Full read of your current structure, filings, and risk heatmap. Deliverable: written opinion + recommended next steps. Use this to decide whether to go deeper.
- ◆Current-state risk heatmap
- ◆3 scenario outlines with rate & cost estimates
- ◆Audit readiness check on existing structure
Implementation Project
Lead advisor, end-to-end
We design, implement, and document. Entity formation, IP migration, intercompany agreements, substance build, rulings. Your Big-4 stays in the loop; we're the lead.
- ◆Three-scenario model, you pick the path
- ◆Single point of contact across jurisdictions
- ◆Post-implementation audit-readiness pack
Ongoing Advisory
Supplement your Big-4
Quarterly review, legislative change tracking, on-call for Finanzamt / HMRC / IRS questions. The work your Big-4 either won't sign off on or prices at 4x.
- ◆Quarterly documentation refresh
- ◆Legislative alert feed for your jurisdictions
- ◆Priority escalation on audits + inquiries
We've co-piloted with EY, PwC, KPMG, and Deloitte on 60+ mandates. Your relationship stays.
International tax counsel.
Every structure we sign is reviewed by qualified counsel in each relevant jurisdiction. No outsourcing to 'local correspondents' you've never met.
Robert Babić
Founder & Managing Partner
Robert is the founder of Kiroptera Consulting, bringing over a decade of experience in corporate law, blockchain regulation, and international business structuring. He specializes in guiding crypto and Web3 projects through complex legal landscapes.
Maja
Legal Consultant
Maja specializes in international e-commerce law and tax optimization for digital businesses. Her expertise helps clients navigate cross-border regulatory challenges with confidence.
Petra
Legal Consultant
Petra focuses on SaaS and AI business law, helping tech companies structure their contracts, comply with data protection regulations, and navigate the evolving AI regulatory landscape.
Why CFOs pick us over Big-4 or their generalist.
We're not accountants. We're tax lawyers.
Your accountant files. We structure, defend, and sign.
Different job, different training, different liability. Your accountant stays; we handle the work they flag as outside scope.
Defensible, not aggressive.
Substance-backed structures that survive audits.
No PO-box Dubai. No paper-thin Cayman holdcos. Everything we design is defensible on written opinion and passes ATAD / GILTI / beneficial-ownership tests.
We work alongside your Big-4.
EY / PwC / KPMG / Deloitte — they stay.
We've co-piloted on 60+ mandates. You keep your accountant. We give them a better chart to work with.
Flat fees. Scoped upfront.
No 6-minute increments. No hourly surprises.
You see the number before we start. Scope changes? New number in writing, approved before work begins.
What CFOs actually ask on the call.
No legalese. If the answer is 'it depends,' we'll tell you exactly what it depends on.
Accountants file returns against the structure you already have. We design the structure. Most of our clients keep their accountant — we just give them a better chart to work with.
Structure review: flat €12K–€25K depending on complexity. Implementation: scoped per project, typically €40K–€180K. Ongoing retainers from €2,400/mo. You see the number before we start.
Discovery and design: ~6 weeks. Implementation: 2–6 months. Most clients see rate reduction in the first full fiscal year post-implementation.
No. They stay. We handle the advisory and structuring work Big-4 firms either won't sign off on or price at 4x. We've co-piloted with EY, PwC, KPMG, and Deloitte on 60+ mandates.
In-house counsel across 23 jurisdictions spanning EU, UK, US, UAE, CH, SG. If we don't cover it directly, we have a vetted network relationship. We'll tell you honestly on the call.
No. Everything we design is defensible on written opinion, survives CFC / ATAD / GILTI rules, and passes beneficial-ownership tests. We've lost zero audits in nine years. That's the bar we hold.