Approach

How an engagement works

We start with one real transaction and work it the way a cross-border tax lawyer would, whichever countries it involves.

01
The facts
Who owns, operates, contracts, invoices, pays and controls each asset and service, where, and from when. Facts come from documents and are verified by a person before anything is calculated.
02
Every jurisdiction involved
The countries, states, provinces and special territories the facts touch, and how they touch them: residence, people, equipment, customers, payments and goods.
03
The law, from official sources
For each jurisdiction and each issue (indirect tax, customs, income tax and permanent establishment, withholding and treaties, transfer pricing, anti-avoidance), the law as it applied on the relevant dates, cited to the official text.
04
Today’s position
What is payable, recoverable, withheld and at risk now, line by line, before anything is changed.
05
Lawful alternatives
Structures built from real operating models: who buys, imports, owns, operates and contracts. Never a paper entity chosen for its rate.
06
Challenged as an authority would
Each alternative is attacked the way a tax authority would attack it, and the exposure is stated as a range under named positions, not as a probability.
07
What is worth doing, and by when
Structures ranked by consolidated after-tax value, with what must be true for each, the decision deadlines, and the cost of the substance it needs.
08
Controls
Once a structure is chosen, the checks that keep it true: purchase orders, invoices, asset locations, certificates and margins, monitored against the approved design.

How value is reported

Five kinds of benefit, never mixed

We never call a timing benefit a saving. Every figure we report carries one of these labels.

Permanent saving: Tax that is not paid at all, now or later.
Timing benefit: Tax paid later, valued as the present value of the delay.
Working-capital effect: Indirect tax or duty paid and later recovered, valued as the cost of the gap.
Avoided risk: A smaller exposure range, shown as a range and never added to the value.
Conditional opportunity: Value that depends on a fact or approval still to be confirmed, shown with what it depends on.

Tell us what you are planning and which countries are involved. We will reply from contact@drellon.com.