Insights
Notes from the practice
Commentary on cross-border structuring, banking, residence, tax and regulatory change. Articles more than 24 months old carry a note saying so.
Regulatory
23 articles
Regulatory
HMRC Connect: How Offshore Assets Are Tracked
How HMRC Connect and global data exchange let the UK tax authority track offshore assets, and what compliant taxpayers should understand about disclosure.
Regulatory
EMI, PSP, VASP or MSB: A Fintech Licensing Decision Framework
A decision framework for choosing between EMI, PSP, VASP and MSB licences: what each permits, capital and substance, jurisdictions, timelines and banking.
Regulatory
BEPS Pillar Two: The Global Minimum Tax Explained
A clear guide to BEPS Pillar Two and the 15% global minimum tax: who is in scope, how the GloBE rules work, and what it means for offshore structures.
Regulatory
OECD Pillar One: How Profit Reallocation Will Work
OECD Pillar One reallocates taxing rights over the largest multinationals to market jurisdictions. Here is what it means and who it affects.
Regulatory
Pillar Two First-Year Compliance: What to Do Now
Pillar Two compliance in its first year is a data and process challenge. Here is a practical guide to GloBE calculations, safe harbours, and filings.
Regulatory
FATCA for Individuals: Your Reporting Obligations
FATCA for individuals means US persons must report foreign financial assets on Form 8938. Here is who is affected and how it differs from the FBAR.
Regulatory
FBAR Reporting Requirements for US Persons Explained
FBAR reporting requirements catch many US persons with foreign accounts. Here is who must file FinCEN Form 114, what counts, and the penalties.
Regulatory
Transfer Pricing Essentials for Multinational Groups
Transfer pricing essentials for multinationals: the arm's length principle, documentation, methods, and how to manage audit risk across borders.
Regulatory
Transfer Pricing Basics Every Entrepreneur Should Know
Transfer pricing basics for entrepreneurs: when the rules apply to your group, the arm's length principle, simple documentation, and pitfalls to avoid.
Regulatory
Permanent Establishment Risk in the Remote-Work Era
Permanent establishment risk from remote work: how home-based employees and roaming founders can create a taxable presence abroad, and how to manage it.
Regulatory
Permanent Establishment Risk: A Complete Guide
A complete guide to permanent establishment risk: the types of PE, treaty rules, profit attribution, common triggers, and how to manage exposure.
Regulatory
Tax Treaty Shopping After BEPS: What Still Works
Tax treaty shopping is far harder after BEPS. We explain the principal purpose test, the limitation on benefits clause, and how to claim treaty relief.
Regulatory
BVI Beneficial Ownership Register: 2025 Update
How the BVI beneficial ownership register reforms reshape disclosure, access and compliance for companies and their owners. What changed and what to do.
Regulatory
Cayman Economic Substance: Enforcement Explained
How Cayman economic substance enforcement works in practice: which entities are caught, what the tests require, and the penalties for getting it wrong.
Regulatory
CRS Expansion 2025: New Jurisdictions and Crypto
The Common Reporting Standard keeps expanding into new jurisdictions and crypto assets. Here is what automatic exchange means and why transparency wins.
Regulatory
Beneficial Ownership Registers: What Changed in 2025
Beneficial ownership registers reshaped corporate transparency in 2025. We explain who must file, who can see it, and what owners should do now.
Regulatory
Beneficial Ownership Registers Worldwide: A Country Guide
A worldwide guide to beneficial ownership registers: how the rules differ by region, who can access the data, and what it means for international structures.
Regulatory
UK Autumn Budget: Offshore Planning Implications
What the UK Autumn Budget direction means for offshore structures: the non-dom changes, IHT shifts, and how internationally mobile families should respond.
Regulatory
FATF Grey List Updates 2025: What They Mean for You
FATF grey list updates in 2025 reshape banking and due diligence for offshore structures. Here is what changed, why it matters, and how to respond.
Regulatory
The EU AML Single Rulebook 2025: A Practical Guide
The EU AML single rulebook and new AMLA authority reshape anti-money-laundering compliance across the bloc. Here is what changes and how to prepare.
Regulatory
Global Minimum Tax: What It Means for Offshore Structures
How the global minimum tax reshapes offshore structures, who falls in scope, and the planning moves that still work for international groups in 2026.
Regulatory
DAC6: The EU Mandatory Disclosure Regime Explained
A clear guide to DAC6, the EU mandatory disclosure regime for reportable cross-border arrangements: hallmarks, who reports, intermediaries and penalties.
Also in Insights
Reference
Guides and comparisons
Longer guides on jurisdictions, structures and routes to residence.
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Example scenarios
Illustrative scenarios showing how a matter is approached.
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Glossary
Plain-English definitions of cross-border terms, from ATED to VASP.
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Questions clients ask
How the firm works, what it charges and where it operates.
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The adviser's note
A quarterly note on banking, structures, residence and regulatory change. No marketing emails.
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What it covers
Much of the firm's thinking sits in client memoranda rather than published articles. The note covers the parts that apply more widely: changes in jurisdictions, banking practice and regulatory deadlines.
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