How we coordinate international tax planning with licensed advisers: tax residence, controlled foreign companies, substance, treaties, Pillar Two and reporting.

Desk with a laptop, calculator and papers in soft daylight
Corporate services · Tax

International tax planning.

Sound international tax planning is about clarity rather than secrecy: knowing where each person and company is taxable, keeping the structure defensible and filing everything on time.

ResidenceThe starting point
SubstanceBehind every structure
TreatiesRelief from double tax
LicensedAdvisers sign off
Overview

Planning that stands up to scrutiny.

Tax authorities now exchange information routinely and examine cross-border structures closely. The best plan is one you would be comfortable explaining to any of them.

We coordinate international tax planning for business owners, investors and families, working with licensed tax advisers and accountants in each country involved. Our role is to bring the corporate, banking and residence pieces together, so that the advice you receive reflects the whole picture rather than one country in isolation.

AT Express is headquartered in Cyprus, with offices in the United Kingdom, Hong Kong, China, Vietnam and Singapore, which allows us to coordinate advice across Europe and Asia under one engagement.

Key principles

The questions that matter most.

  • Where are you tax resident? Personal residence usually determines where worldwide income is taxed, and changing it requires real changes in where you live.
  • Where is the company managed? Many countries treat a company as resident where its board meets and decisions are taken, regardless of where it is registered.
  • Do controlled foreign company rules apply? Many countries tax residents on the undistributed profits of low-taxed companies they control.
  • Is there substance? Structures without staff, premises or decision-making in the right place are increasingly challenged.
  • Can a treaty help? Double tax treaties can reduce withholding taxes and prevent the same income being taxed twice, subject to anti-abuse provisions.
Private consultation

Reviewing your structure?

We can arrange a coordinated review with licensed advisers in each country involved, and set out the scope and fees in writing first.

Headline rates

Corporate tax rates in the centres we cover.

JurisdictionHeadline corporate taxNote
Hong Kong8.25% / 16.5%Two-tier profits tax; first HK$2 million at the lower rate
Singapore17%Partial exemptions on the first S$200,000 of normal chargeable income
United Kingdom19% to 25%Marginal relief between £50,000 and £250,000 of profits
United Arab Emirates0% / 9%9% on taxable income above AED 375,000
Cyprus15%From the 2026 tax year
United States (federal)21%For corporations; LLCs are often treated differently

Headline rates are only a starting point. Exemptions, the tax base and the owner’s personal position usually matter more.

Global standards

A changing international framework.

  • Global minimum tax. Under the OECD/G20 Pillar Two rules, large multinational groups pay a minimum level of tax on profits in each jurisdiction where they operate, through top-up taxes where the effective rate is too low.
  • Automatic exchange. Under the Common Reporting Standard and, in the EU, the Directive on administrative cooperation, tax authorities exchange information on financial accounts and certain cross-border arrangements.
  • The EU list. Jurisdictions on the EU list of non-cooperative jurisdictions face defensive measures in member states.
  • Economic substance. Many low-tax centres now require companies carrying on relevant activities to demonstrate real activity locally.

Our articles on economic substance and the EU list of non-cooperative jurisdictions explain these rules in more depth.

Process

How we proceed.

01

Fact-finding

We gather the facts: residence, family, assets, companies and plans.

02

Scoping

We agree the questions to be answered and the advisers to be instructed.

03

Advice

Licensed advisers in each country prepare their advice, which we coordinate into one picture.

04

Implementation

We implement the agreed steps: companies, banking, residence and registrations.

05

Review

We revisit the structure as rules and circumstances change.

Questions

Frequently asked questions.

Do you give tax advice yourselves?
We coordinate the work, and formal tax advice is given by licensed tax advisers and accountants in each country concerned. This keeps the advice accountable and properly regulated.
Can moving my company abroad reduce my taxes?
Not on its own. Your personal tax residence, where the company is managed and controlled foreign company rules usually matter more than where the company is registered.
What is the global minimum tax?
The OECD/G20 Pillar Two rules ensure that large multinational groups pay a minimum level of tax on profits in each jurisdiction, through top-up taxes. Most smaller private businesses fall outside their scope.
Will tax authorities know about my foreign company?
Increasingly, yes. Financial account information is exchanged automatically under the Common Reporting Standard, and many countries require residents to declare foreign companies they control.
Is tax planning legal?
Arranging your affairs within the law is legitimate. Structures that lack commercial substance or rely on concealment are not, and we do not take part in them.
Sources

Official sources.

  1. OECD, Global Anti-Base Erosion Model Rules (Pillar Two).
  2. OECD, Global Forum on Transparency and Exchange of Information for Tax Purposes.
  3. European Commission, Directive on administrative cooperation (DAC).
  4. European Commission, EU list of third-country jurisdictions for tax purposes — Annex I and Annex II as revised on 9 October 2026.
  5. Inland Revenue Department, Two-tiered profits tax rates regime.
  6. Inland Revenue Authority of Singapore, Corporate income tax rate, rebates and tax exemption schemes.
  7. GOV.UK, Corporation tax rates and allowances.
  8. Federal Tax Authority, Corporate Tax general guide.
  9. Tax Department, Ministry of Finance, Tax reform 2026.
  10. Council of the European Union, EU list of non-cooperative jurisdictions for tax purposes.
  11. OECD, International standards on tax transparency, including the Common Reporting Standard.
  12. Internal Revenue Service, Foreign Account Tax Compliance Act (FATCA).
Please note. This page is a general summary for information only and does not constitute legal, tax or financial advice. Every company formation and bank account is subject to know-your-customer (KYC) and anti-money-laundering (AML) checks by the registered agent, registry and bank, and no outcome or timescale can be promised. Companies may be subject to economic substance rules, and their accounts and owners may be reported to tax authorities under the OECD Common Reporting Standard (CRS) and the US Foreign Account Tax Compliance Act (FATCA). Check whether any jurisdiction involved appears on the EU list of non-cooperative jurisdictions for tax purposes, and take independent tax and legal advice in each country concerned. AT Express works with licensed corporate service providers, lawyers and accountants and is not affiliated with any government, registry or bank. Last reviewed: 30 October 2026.
How we work

Four calm steps.

A simple, transparent process. The scope of our work and our fees are set out in writing before anything begins.

  1. 01

    A first conversation

    We discuss what the company will do, who will own and run it, and where its customers and people are.

  2. 02

    A written proposal

    We compare suitable jurisdictions and set out the documents, timetable and fees, so you can decide calmly.

  3. 03

    Formation and banking

    We coordinate due diligence, incorporation and bank applications with licensed providers in each jurisdiction.

  4. 04

    Ongoing compliance

    We keep track of renewals, filings and reporting each year and remain your single point of contact.

Begin with a conversationConfidential and without obligation
From our insights

Further reading

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Let's talk

Begin with a conversation.

Tell us a little about your plans. An adviser will reply personally with an initial view of the options available to you — confidentially and without obligation.

Arrange a consultation

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  • One dedicated adviser
  • Scope and fees in writing
  • Confidential, without obligation