Tax · Advisory
The structure is in place, and the tax position is still unclear.
Advisory work deals with the questions that survive incorporation: which country has the taxing right, what happens on departure, how digital assets are characterised, and whether an offshore entity will be looked through.
Positions That Have to Withstand Review
Cross-border tax rarely fails on the rate. It fails on facts: a residence never properly ended, a company managed from somewhere other than where it is registered, a self-certification given years ago that no longer matches reality, a cost basis nobody recorded. Automatic information exchange means those facts are usually already visible to the authority before any return is filed.
LTB reconstructs the position from the evidence, states which treatment is defensible and from what date, and remedies what is still fixable. Filings, amended returns, treaty claims, and disclosures are prepared and submitted by the licensed tax professionals in the practice's network in each jurisdiction, so that both authorities in a cross-border matter receive a consistent account.
Advisory Matters
Two countries taxing the same income
Residence established in the new country and never ended in the old one. The treaty tie-breaker only helps where the facts support it.
Crypto tax and residency
Property, currency, instrument, or inventory: the classification decides the rate, the timing, and whether a swap is taxable at all.
CRS and FATCA reporting
Accounts are reported automatically each year. Most enquiries come from a mismatch between what was reported and what was filed.
Exit tax on departure
Emigration treated as a deemed disposal, taxing gains never realised. Deferral is often available, and sequence decides the size of it.
Controlled foreign company rules
A home country attributing an offshore company's income to its shareholder where substance and genuine activity are absent.
Questions
Frequently Asked
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