Services

International Structuring

We design holding, financing and operating structures across jurisdictions — with international tax coordination built in from the start.

  • 18Structuring matters
  • Holding · financing · operatingStructures
  • Treaties & PETax coordination
  • UAE · EU · CIS · offshoreCoverage
Overview

Structures that fit the whole map

Holding, financing and operating structures rarely fail in one country — they fail at the seams between several. We design and rebuild cross-border structures with international tax coordination built in: choosing holding jurisdictions, applying double-tax treaties correctly, managing permanent establishment, thin capitalisation and substance, and keeping the structure defensible as the rules change.

Holding and tax coordination across the UAE, the EU, the CIS and beyond — in English and Russian.

Why Cardinals

Why clients choose us

  • Tax built in

    Tax sits inside the design, not after

    Double-tax treaties, permanent establishment, thin capitalisation and substance are considered as the structure is built.

  • Cross-border

    We design for the seams

    Where holding, financing and operations meet across borders — that is where we focus.

  • Defensible

    Built to survive a challenge

    Substance and documentation that hold up to tax authorities and counterparties.

Solutions

How we help

  • Holding

    Choose and build the holding structure

    Jurisdiction selection, incorporation, redomiciliation and group reorganisation.

  • Tax coordination

    Apply treaties and manage exposure

    Double-tax treaties, permanent establishment, thin capitalisation and participation exemption.

  • Operating

    Structure financing and operations

    Intra-group financing, IP and operating arrangements across jurisdictions.

Structuring across jurisdictions?

Tell us the picture — a partner will come back to you, in confidence.

Discuss your structure
Experience

Selected matters

Port of Vistino

Advising on the construction of a port in Vistino. Structuring of a $19 billion deal, corporate structuring of the investment and assistance in the implementation of the project at all stages.

Russia

Acquisition of AI start-up

Acting for a Swiss investor in the acquisition of an AI start-up with an enterprise value of EUR 100 million.

Application of double tax treaties

Advising a Cypriot, Swiss and Luxembourg group entities on the correct application of double tax treaty withholding tax rates, tax residency rules and residency confirmation formalities.

Switzerland

Further matters

  • Russian Depository

    India · Russia

    Advising one of Russia's leading specialised depositories on securities transactions on Indian exchanges and over-the-counter transactions in the Indian securities market, including bankruptcy and regulatory risks for custodian status under SEBI regulations and the Insolvency and Bankruptcy Code, 2016.

  • UAE corporate guarantee opinion

    India · UAE

    Providing a capacity and enforceability opinion to an Indian lender in respect of a corporate guarantee issued by a UAE-based entity, covering corporate authority under UAE company law, civil-law enforceability, and cross-border security structuring.

  • UK-based business structuring

    UK · Bulgaria

    Advising a UK client on the acquisition of properties in Bulgaria, including setting up a UK holding, incorporating a Bulgarian subsidiary and facilitating the acquisition of the properties through it. English and Bulgarian law.

  • Withdrawal from Russia

    Russia

    Advising a multinational retailer on the tax structuring of a withdrawal from Russia.

  • Acquisition of hotel properties

    Greece

    Advising a Bulgarian client on the acquisition of hotel in Greece, including setting up a company for the acquisition, liaising with Bulgarian banks and Greek authorities, notaries, sellers, third parties financing the project.

  • Blockchain Startup

    India

    Advising a blockchain start-up on the financial and regulatory framework applicable to a tokenised-assets arbitrage model, including cross-jurisdictional contract structuring.

  • EAEU import/export restrictions and duties

    Russia

    Advising a European pharmaceutical company, a medical equipment manufacturer and a South American meat producer on EAEU import/export restrictions and import duties.

  • Fintech IPO

    European Union

    Advising a Southeast European consumer finance and fintech business on its restructuring in anticipation of a prospective London IPO.

  • International tax and witholding tax rules

    Italy

    Advising a top-3 natural gas producer and an Italian construction company on international tax and withholding tax rules.

People

The structuring team

Anton Garmoza
Partner in charge

Anton Garmoza

Managing Partner

Managing Partner of Cardinals. He oversees international structuring and tax coordination — cross-border corporate and holding structures across multiple jurisdictions.

  • Attorney at Law (New York, USA)
  • Lawyer (Russia)
View full profile

The wider team

Kamen Shoylev Kamen Shoylev Partner View profile Konstantin Galkin Konstantin Galkin Partner View profile Reena Choudhary Reena Choudhary Counsel View profile Artem Lavrov Artem Lavrov Managing Associate View profile Ilya Kholopov Ilya Kholopov Associate View profile
Speak with Cardinals

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