Tax law
Group tax structure, CFC rules and the founder’s residency, VAT on digital services in the EU, Diia City, dividends through a holding. We calculate the burden under real models rather than describe the rules — and give you an annual calendar of what to pay, where and when.
Four strands of the practice
Group structuring
Where the holding, the operating company and the IP should sit so tax is not paid twice.
The founder’s taxes
CFC rules, residency, dividends and the sale of shares — for the person, not only the company.
VAT and indirect taxes
Digital services, goods and marketplaces in the EU, the UK and the US.
Preferential regimes and disputes
Diia City, IP Box, non-dom — and defending the position when the tax office disagrees.
The tasks clients came to us with
SaaS with EU customers: VAT OSS, Diia City and the founder’s dividends
Correct VAT in 27 countries through one return, the Ukrainian team in Diia City, an annual tax calendar for the founder.
A fiscal unit instead of a tax refund: 35% → an effective 5%
Holding and operator as a fiscal unit, the dividend route under the double-tax treaty, the first CFC report.
Changing residency after an exit: from plan to certificate
What to change in the Ukrainian ties, how many days in the UAE, how to obtain the certificate; a year later, residency confirmed.
Do I file a CFC report if the company paid no dividends?
Yes. The report is filed regardless of distributions; whether tax arises is a separate question. In most structures with an active business it does not, but the filing duty remains.
Estonia or Cyprus for a holding?
Estonia when profit is reinvested and dividends are rare; Cyprus when there is IP, active dividend flows or a treaty network is needed. We run both models on your numbers.
When is a Diia City company better than sole traders?
When the team is stable, foreign clients ask for a contract with a legal entity, or a round is planned. For two or three developers the difference often does not favour Diia City.
How many days do I need in the UAE to become resident?
For a UAE tax residency certificate, 183 days, or 90 under certain conditions. What matters more is cutting the ties with Ukraine: home, family, centre of interests.
What we have written about tax law
Cyprus at 15%: What the 2026 Corporate Tax Change Means for Existing Structures
Cyprus corporate tax in 2026 is 15%, not 12.5%. The Second Schedule to the Income Tax Law now charges companies […]
Read articleA tax question that drags three more behind it?
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