Our purpose

Our international structuring services ensure compliance and efficiency for Armenia’s regulatory environment in 2025. Tailored for MNEs, we align with transfer pricing frameworks. We design cross-border structures to maximize value, minimize risk, and ensure compliance. Our services enable tax efficiency and support MNE transfer pricing strategies for global scalability.

Global entity structuring

Selects entities, branches, trusts

Maps multi-jurisdictional compliance

Designs corporate, equity flows

Aligns with MNE legal needs

Cross-border tax structuring

Analyzes double tax treaties

Mitigates PE, withholding risks

Structures intercompany services, IP

Supports MNE tax efficiency

Substance and governance

Ensures substance compliance

Builds governance architectures

Plans economic presence for BEPS

Enhances MNE control frameworks

Holding and IP structures

Designs IP, treasury structures

Routes licenses, cost-sharing

Consolidates for tax efficiency

Aligns with MNE financial goals

Exit and repatriation strategy

Models dividend repatriation

Plans tax-neutral exits

Mitigates expatriation taxes

Supports MNE exit readiness

Who we advise

We serve clients for whom global structuring is not just a task—it’s a trust function:

Multinational enterprises: Optimizing global operations.
High-net-worth individuals: Structuring wealth, assets.
Holding groups: Managing cross-border entities.
Private equity firms: Preparing for exits, M&A.
Tech startups: Scaling IP structures.
C-suite executives: Driving global strategy.

Real-world impact: what our clients achieve

The challenge

Complex tax, compliance risks

Inefficient entity structures

Limited substance, governance

High repatriation, exit costs

Our strategic response

Tailored entity, tax structures

Robust governance, substance plans

Efficient repatriation, exit strategies

Transfer pricing-aligned solutions

Achieved results

Full compliance, tax efficiency

Reduced legal, financial risks

Scalable global structures

Aligned transfer pricing outcomes

Delivery models

Entity planning: Legal structures, compliance maps

Tax optimization: Treaty analysis and PE mitigation

Governance and substance: Control, BEPS frameworks

Exit and IP strategies: Repatriation and licensing plans

Why partner with us

Structuring expertise

Deep tax, legal knowledge.

Compliance assurance

Aligns with Armenian laws

Global reach

Covers EU, EAEU, UAE, APAC.

Scalable impact

Drives efficient growth.

Tailored solutions

Fits MNEs, individuals.

FAQ

Frequently asked questions

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

What is international structuring?

It designs cross-border frameworks for tax efficiency, compliance, and scalability, aligning entities and operations with global goals.

What does entity structuring involve?

We select entities (e.g., LLPs, trusts), map compliance, and design corporate charts for MNEs and individuals.

How do you optimize cross-border taxes?

We analyze treaties, mitigate PE risks, and structure intercompany services to minimize withholding taxes for MNEs.

Can you support MNE global strategies?

Yes, we align structuring with transfer pricing for compliance and scalability across jurisdictions like EU, UAE.

What is substance compliance?

We ensure directors, offices, and economic presence meet BEPS and EU directives for robust MNE governance.

How do you plan exits and repatriation?

We model dividends, plan tax-neutral exits, and mitigate expatriation taxes for MNEs and investors.

What deliverables do you provide?

We deliver entity charts, tax structures, governance frameworks, IP licensing plans, and exit strategies.

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International structuring