When can the tax authority challenge a holding structure? The CJEU’s judgment in “Neo Group” (C-203/25)
28 October 2026
Read MoreDeal Structuring
The execution of significant transactions - whether an acquisition or disposal of a business, an investor entry, a corporate reorganisation, or a cross-border investment project - demands carefully designed structures that are legally sound, tax-efficient, and commercially workable.
Our team provides comprehensive transaction structuring support, combining legal, tax, and financial expertise. We assist clients in designing and implementing transaction structures and models that align with their business objectives, minimise risk, and ensure full compliance with applicable regulations.
At the outset of any significant transaction, a clear-eyed analysis of the available structural alternatives is essential. We examine competing transaction models in depth, identifying the tax consequences, legal constraints, and key risks associated with each approach. This enables clients to enter negotiations and planning processes with a well-informed view of their options and a clear basis for decision-making.
Drawing on the analysis of alternatives, we develop a tailored solution that delivers efficiency, regulatory compliance, and strategic alignment. The structure we recommend will reflect the client's commercial objectives and risk appetite, incorporate the relevant tax and legal considerations, and be practically implementable within the applicable jurisdictions - whether domestic or cross-border.
Transactions spanning multiple jurisdictions introduce additional complexity in areas including corporate law, tax treaty application, substance requirements, and regulatory approvals. We assist clients in planning and implementing cross-border structures, including cross-border reorganisations and group restructurings, holding company structures, intellectual property holding and licensing structures, and cross-border financing models.
Before any transaction is concluded, a thorough examination of the target is indispensable. We conduct rigorous due diligence across all relevant dimensions to identify risks and assess their financial impact in a timely manner.
A well-designed structure is only as effective as its implementation. We prepare the full suite of transaction documents and ensure that the agreed structure is executed correctly and efficiently in practice.
