00 — International structuring

International Structuring

Your LTD is running, but your situation is getting more complex? Assets to protect, shareholdings to centralise, markets to prepare: when the LTD alone is no longer enough, we design the architecture that complements it. Holding, Mauritius company, US LLC, Hong Kong Limited, trust: each building block has a precise role, and access is opened to our clients as a priority.

Mauritius · US LLC · HK
OECD compliant
Economic substance
01 — Our solutions

Our international structuring solutions

When the LTD is no longer enough, we design bespoke legal and tax architectures: holding, Mauritius, US LLC, Hong Kong, trust. Priority access reserved for our clients.

01

International holding

We create and manage holding companies to centralise your assets: subsidiaries, property, intellectual property. Depending on your situation, the holding will be British, Mauritian or elsewhere. The choice is always driven by your operational reality.

  • Centralised dividend flows
  • Asset protection and centralised governance
  • Preparation for a sale or succession
  • Jurisdiction choice driven by your real situation
02

Mauritius company

Our historic jurisdiction. Attractive taxation, OECD-compliant framework, extensive tax treaty network. Relevant for international activities, and essential if Mauritian tax residence is part of your plan.

  • Some of the most competitive taxation in the world
  • Framework compliant with international standards
  • Can be combined with Mauritian tax residence
  • Experienced team on the ground through our network
03

US LLC

An LLC owned by a non-resident, with no US activity or presence, can be tax transparent: profits are taxed in your country of residence, not in the US. Powerful, but compliance-heavy, never a default setup.

  • Tax transparency for eligible non-residents
  • Access to the US ecosystem (Stripe US, banks)
  • Specific filing obligations handled
  • Systematic relevance check before formation
04

Hong Kong Limited

The gateway to Asia. The territoriality principle allows, under conditions, exemption of foreign-source profits. A serious structure, with real accounting and audit obligations. We tell you if it's justified.

  • Territorial taxation: offshore profits exemptable under conditions
  • Strong credibility in Asia
  • Mandatory annual audit handled
  • Relevance assessed case by case
02 — Jurisdictions

The jurisdictions that complement the LTD

Each jurisdiction has a precise role. We don't sell trendy destinations: we pick the building block your situation calls for, or none at all.

45+

United Kingdom

The LTD as the foundation: global credibility, simplicity, 0% withholding tax on dividends

0 %

Mauritius

A Mauritian company for international business: attractive taxation in an OECD-compliant framework

OCDE

United States & Hong Kong

US LLC and Hong Kong Limited for precise use cases, assessed case by case

Mauritius company

Some of the most attractive taxation in the world within a compliant, recognised framework. Relevant for international activities and Mauritian tax residence. It's our historic jurisdiction: we know it from the inside.

Holding & trust

Isolating assets, preparing a transfer, structuring a group: UK or international holding companies, wealth trusts. Powerful tools, to be handled rigorously and only when the situation justifies it.

US LLC

The LLC (notably Wyoming or Delaware) can be tax transparent for a non-resident with no US activity. A precise tool for precise profiles, never a default solution.

Hong Kong Limited

The gateway to Asia, with a territorial tax principle: foreign-source profits can be exempt under conditions. Relevant for international trading and Asia-focused activities.

03 — Economic substance

Substance and compliance: our approach

The credibility and durability of any international structure rest on demonstrable economic reality and full compliance. We refuse artificial setups: that's what protects our clients over time.

01

Management and governance

  • Real, documented governance
  • Decisions made where you actually are
  • Minutes and registers up to date
  • Consistency between structure and operational reality
02

Operational reality

  • Real, demonstrable activity in each entity
  • Financial flows backed by contracts
  • Documented transfer pricing between related entities
  • No empty shells, ever
03

Documentation and compliance

  • Filings in every jurisdiction involved
  • CRS compliance and information exchange
  • Beneficial ownership registers up to date
  • A complete, traceable file in case of audit
04 — Our method

Our structuring method

A rigorous four-phase approach to designing and implementing your bespoke international architecture.

01

Diagnosis and analysis

We analyse your situation in depth: existing entities, flows, tax residence, wealth goals. We identify whether a complementary structure is justified, and we tell you if it isn't.

02

Structure design

We design the target architecture: choice of entities and jurisdictions, flows between structures, tax implications in your country of residence. You receive a clear diagram with a comparative analysis of the options.

03

Implementation

Formation of the necessary entities, account openings, contracts between structures, compliance in each jurisdiction. We coordinate everything with our licensed local partners.

04

Monitoring and adaptation

Ongoing management of the structure: accounting, filings, compliance in each jurisdiction. We adapt the architecture as your situation or regulation evolves.

Need a bespoke structure?

We analyse your situation and design the architecture best suited to your objectives. No commitment.

05 — Clarification

Are advanced structures offshore?

No. The word "offshore" brings to mind opaque jurisdictions and shell companies. What we set up is the opposite: declared, documented, compliant structures in jurisdictions aligned with OECD standards.

Mauritius reformed its framework in 2018-2019 and meets international transparency standards. US LLCs carry precise filing obligations. Hong Kong requires annual accounting and audit. None of these building blocks is a loophole: they are regulated tools.

The appeal comes from legal mechanisms: territorial taxation, LLC tax transparency, double taxation treaties, no withholding tax. Used correctly, with substance, they are perfectly defensible. It's optimisation by the rules, not opacity.

06 — Who is it for?

Who is international structuring for?

When it makes sense

You're scaling up

Your LTD runs well and your situation is getting more complex: shareholdings, assets, multi-country income. Time to structure properly.

Multi-country group

You operate in several jurisdictions and need a central holding to rationalise financial flows and governance.

Wealth protection

You want to isolate assets from operational risk, prepare a succession or organise your wealth: holding companies and trusts are the right tools.

Specific markets

US ecosystem (LLC), Asia (Hong Kong), international (Mauritius): some activities justify a dedicated building block alongside the LTD.

When it's NOT the right fit

100% local activity

If your activity fits entirely within your LTD and one market, international structuring makes no sense. The LTD is enough.

Setup without substance

If the goal is to create an empty structure to artificially park profits, it's both illegal and contrary to our approach.

Very limited budget

Each additional entity carries recurring costs. If the expected gain doesn't largely cover them, we'll advise against the structure. Honestly.

07 — Mistakes to avoid

Common mistakes in international structuring

The pitfalls we see most often among founders who structure without proper support.

01

Neglecting economic substance

The number one cause of requalification. Without documented economic reality, the structure is considered fictitious by tax authorities.

02

Picking a jurisdiction by default

Mauritius, Delaware or Hong Kong are neither good nor bad in the absolute: it all depends on your flows, your residence and your goals. A structure chosen by imitation costs money without returning any.

03

Ignoring transfer pricing

Flows between entities of the same group must be documented and priced at arm's length. Missing documentation is a major tax risk.

04

Underestimating compliance costs

Accounting, audits, filings in each jurisdiction: recurring costs are real. They must be factored in from the design stage.

Frequently asked questions about international structuring

The answers to the questions we're asked most often about advanced structures complementing the LTD.

Economic substance is the proof that a company really exists where it's registered: real activity, documented decisions, flows backed by contracts. Since the OECD's BEPS reforms, it has become the key criterion for tax authorities to recognise a structure's legitimacy. Whatever the jurisdiction (UK, Mauritius, US, HK), we only set up structures with demonstrable reality.

Each pair of countries has its double taxation treaty: it allocates taxing rights and provides mechanisms to avoid double taxation on dividends, interest and royalties. A good structure uses them as written, with the required substance, never by forcing them. Our team analyses the ones applicable to your situation.

Yes, systematically. Every jurisdiction we propose (UK, Mauritius, US, Hong Kong) complies with OECD standards and participates in automatic information exchange (CRS or equivalent). We refuse opaque setups: full compliance, up-to-date beneficial ownership registers, complete documentation. That's what protects our clients over time.

Absolutely, it's one of the most relevant uses. A holding centralises your shareholdings, channels dividends and prepares a sale or succession. Depending on your situation, it will be British, Mauritian or elsewhere: the choice is driven by your real flows, your tax residence and your goals, never by fashion.

International structuring means legally organising a group's flows across several countries, using existing tax treaties and legal frameworks. It's perfectly lawful and governed by international law. Tax evasion is something else entirely: hiding income or using fictitious structures. At The Horizon Founder, we only propose transparent, compliant, documented structures.

What if your tax bill dropped to 0%?

Depending on your country of residence and your profile, a well-structured UK LTD can bring your taxes down to the legal minimum, sometimes 0%. Book a strategy call, no commitment: we'll tell you with real numbers.