Our purpose

Our fiscal structuring services ensure compliance for Armenia’s regulatory environment in 2025. Tailored for businesses, we optimize tax efficiency. We design tax-efficient, scalable structures to ensure compliance and support growth. Our services deliver resilient fiscal solutions for MNEs, investors.

Legal entity structuring and jurisdiction strategy

Analyzes domestic, offshore incorporation options

Designs holding, sub-holding structures

Optimizes LLC, CJSC, branch models

Plans permanent establishment avoidance

Tax-efficient group structuring

Plans group consolidation, cost allocation

Structures dividend, royalty flows

Applies treaty-based tax relief

Eliminates double taxation risks

Capital structure and financing strategy

Balances debt, equity for tax shields

Navigates thin capitalization rules

Structures intercompany loans, hybrids

Optimizes financing tax efficiency

Substance and anti-avoidance planning

Ensures BEPS, ATAD compliance

Structures local economic presence

Prepares transfer pricing documentation

Aligns with global tax standards

Exit and succession planning

Minimizes capital gains taxes

Structures pre-exit share sales

Reduces tax leakage risks

Optimizes MNE exit strategies

Who we advise

We serve clients for whom efficiency is a trust function:

Business owners: Scaling multi-entity operations.
Investors, family offices: Seeking tax efficiency.
Foreign corporations: Entering Armenian markets.
M&A participants: Structuring share, asset deals.
Tech startups: Building scalable tax models.
PE/VC funds: Designing SPV vehicles.

Real-world impact: what our clients achieve

The challenge

Complex multi-jurisdictional taxes

Double taxation risks

Anti-avoidance compliance gaps

Inefficient exit structures

Our strategic response

Tailored fiscal architectures

Treaty-based tax optimization

BEPS-compliant substance planning

Strategic exit designs

Achieved results

Tax-efficient structures

Compliant global operations

Minimized tax liabilities

Scalable business models

Delivery models

Entity structuring: Jurisdiction and legal form planning

Group optimization: Profit, cost allocation strategies

Financing design: Debt and equity tax planning

Exit planning: Capital gains minimization

Why partner with us

Strategic defense

Evaluate your benefits.

Structuring expertise

Deep OECD, EAEU knowledge.

Proven designs

Scalable, audit-resistant models.

Compliance assurance

Aligns with Tax Code.

Global alignment

Leverages treaty exemptions.

FAQ

Frequently asked questions

Explore our frequently asked questions to learn more about TML’s features, security, integration capabilities, and more

What is fiscal structuring?

We design legal, tax-efficient business architectures for compliance, scalability, and efficiency.

How does structuring help tax efficiency?

We optimize entity forms, profit flows to minimize taxes, align with treaties.

What’s fiscal structuring vs. tax planning?

Structuring builds legal, financial frameworks; tax planning focuses on liability minimization.

Can structuring reduce dividend taxes?

Yes, we use treaty-based planning, holding structures to optimize dividend flows.

Is this only for large corporations?

No, we support SMEs, startups with scalable, compliant tax-efficient structures.

What’s involved in exit planning?

We structure share sales, minimize capital gains for tax-efficient exits.

What deliverables do you provide?

We deliver entity designs, TP documentation, financing plans, and exit strategies.

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Fiscal structuring and tax architecture