Substantive cross-border tax counsel for individuals, founders, family offices, and corporate groups operating across multiple jurisdictions.
Provided by Moore Law · CVR 43 57 76 70.
International taxation is the discipline where most cross-border commercial arrangements eventually meet their hardest questions. Whether a Danish company is expanding into the United Arab Emirates, a UAE-based founder is acquiring assets in Europe, a family office is restructuring its cross-border holding chain, or a senior executive is on multi-jurisdiction assignment, the tax position is rarely the sum of the domestic positions on each side.
The right approach to cross-border tax is structural: anticipating how the relevant treaties, domestic regimes, and substance requirements interact, choosing the right vehicles and jurisdictions at the outset, and documenting the position carefully enough that it withstands later examination by any of the tax administrations involved.
Moore Law advises on the full range of cross-border tax questions arising between Denmark, the United Arab Emirates, and the broader set of jurisdictions in which the firm's clients operate. The work is grounded in tax counsel and supported by the firm's working familiarity with the UAE corporate tax regime, freezone tax positions, and the application of the relevant double-taxation treaties.
Analysis of the relevant double-taxation treaties — including the Denmark–UAE treaty — to determine the right of taxation between the jurisdictions, the application of the relevant relief mechanisms (exemption, credit, or otherwise), and the treatment of specific income categories under each treaty article.
Design and implementation of cross-border holding structures for individuals, families, and corporate groups. Selection of holding jurisdictions, layering of vehicles, integration of UAE freezone and mainland entities, substance and management considerations, and the management of withholding-tax exposure on cross-border distributions.
Analysis of permanent-establishment exposure for businesses operating across borders — including the management of staff, premises, and decision-making that may give rise to PE status in a jurisdiction where the entity is not otherwise tax-resident. Structuring to manage that exposure within the substance of the commercial operation.
Following the introduction of the UAE federal corporate-tax regime, advisory on the proper positioning of UAE entities — including the application of qualifying freezone status, the small-business relief, and the treatment of cross-border income within the UAE corporate-tax framework. Coordination with the Danish-side treatment of the same flows.
Building of the substance and documentation that supports a cross-border position — including economic substance requirements, transfer-pricing documentation, intra-group services and royalties, and the maintenance of board and operational records that withstand subsequent examination.
Representation in cross-border tax disputes — including mutual-agreement procedures (MAP) under double-taxation treaties, transfer-pricing audits, and parallel proceedings in multiple jurisdictions. Coordination of strategy across the involved tax administrations.