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hardware sellersenergy providersdata centerscloudsinfrastructure capital

A tax intelligence
layer for compute

Combine rigorous tax logic with compute aware financial modeling. Get source-linked, expert-reviewed decisions to optimize your tax position.

Start with one real transaction

Invite-only while we build with design partners.

Worked examples · Anonymized

Three engagements, reduced to the result.

Equipment manufacturer

Operating rate cut through treaty.

  • ETR −65% · operating tax
  • R&D credits generated
  • PE risk caught & ring-fenced

Energy provider

Reduced effective rate, credits retained.

  • ETR ~11% on gross revenue
  • Dividends 0% — no withholding
  • Spread capped to stay defensible

Alternative investment fund

Ring-fenced assets, tax-neutral financing.

  • Tax-neutral securitisation
  • WHT 0% on note interest
  • Substance kept to ring-fence PE

Anonymised and simplified for illustration; figures indicative and not advice. Underlying authorities, jurisdictions, and full workings shared under NDA.

Four data assets

What a matter leaves behind, kept apart so each can be read on its own.

Compute Operating Graph
The operating shape of a matter — entities, sites, equipment, contracts and movements — as verified facts rather than as extracted text.
Authority Graph
The passages that govern, effective-dated, with what each source permits: whether it may be stored, shown or cited.
Compute Tax Rule Graph
Approved rules, versioned and effective-dated, each pinned to the authority it rests on so an evaluation can be replayed.
Outcome Ledger
The record of what followed a decision: the actions taken, and the outcomes identified and realized, kept apart.

Areas of work

These are the areas we work in. They are not a claim of verified coverage in any jurisdiction; what a matter can answer depends on the authority and rules approved for it.

  • property & equipment
  • energy & carbon
  • corporate tax
  • transfer pricing & PE
  • withholding & treaties
  • incentives & capital recovery
  • emerging AI taxes

Start with one real transaction

Drellon is invite-only while it is being built with design partners. Tell us about one transaction you are considering now and we will come back to you.

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