Tax Disputes

Board Minutes and Tax Substance: Why Documentation Can Make or Break a Holding Company Structure

June 3, 2026by Dr Dawkins Brown

Executive Summary In modern international tax planning, documentation is no longer an administrative afterthought. It is a central part of tax defence. Holding companies, investment platforms, regional headquarters, and cross-border ownership structures may be legally valid, but they remain exposed if the evidence does not prove that they are commercially real. The recent Milan...

When Is a Holding Company a Conduit? Understanding Beneficial Ownership and Anti-Avoidance Risk

June 3, 2026by Dr Dawkins Brown

Key Insight: A holding company is not vulnerable merely because it is lean. It becomes vulnerable when it lacks real substance, decision-making autonomy, commercial purpose, and evidence that it controls the income or assets it legally holds. Executive Summary Holding companies remain valuable tools in international tax and corporate structuring. They can support investment management,...

Corporate Structuring Cross-Border Business Dawgen Global Tax Insights Tax Administration & Policy Tax Advisory Tax Audit Tax Controversy Tax Dispute Resolution Tax Disputes Tax Risk Management Tax Strategy Tax Technology Tax Technology & Data Tax Treaties

Substance Beats Formality: What the Milan Tax Court’s Luxembourg Holding Ruling Means for Cross-Border Tax Planning

June 3, 2026by Dr Dawkins Brown

Executive Summary International tax planning is entering a new era in which paper structures are no longer sufficient, but genuine commercial substance remains powerful. A recent ruling by the First Instance Tax Court of Milan provides an important reminder that foreign holding companies should not automatically be disregarded simply because they are lean, investment-focused...

Designing a Pan-Caribbean Tax Operating Model for a Multi-Jurisdictional Group

April 19, 2026by Dr Dawkins Brown

C | Context A diversified Caribbean group, built over three decades through a combination of organic expansion and strategic acquisition, had accumulated a multi-jurisdictional footprint whose tax management had not kept pace with its commercial development. The group’s fourteen legal entities, spread across six Caribbean jurisdictions, were each managed by local finance teams operating under...

Tax Disputes Tax Firm Tax Incentives Tax Litigation Tax Objections Tax Planning Tax Planning Services Tax Risk Tax Risk Management Tax Strategy Tax Technology Tax Technology & Data Tax Treaties Taxation Services

Tax Strategy and Governance: Building a World-Class Tax Function for Caribbean Businesses

April 6, 2026by Dr Dawkins Brown

From Compliance to Strategy Eleven articles ago, this series opened with a foundational proposition: that tax is not a fixed cost to be simply paid, but a managed variable — shaped by how well the organisation understands its obligations, how proactively it plans its structures and transactions, and how rigorously it maintains the compliance...

Board Minutes and Tax Substance: Why Documentation Can Make or Break a Holding Company Structure

When Is a Holding Company a Conduit? Understanding Beneficial Ownership and Anti-Avoidance Risk

Substance Beats Formality: What the Milan Tax Court’s Luxembourg Holding Ruling Means for Cross-Border Tax Planning

Tax Strategy and Governance: Building a World-Class Tax Function for Caribbean Businesses

June 3, 2026Board Minutes and Tax Substance: Why Documentation Can Make or Break a Holding Company Structure

June 3, 2026When Is a Holding Company a Conduit? Understanding Beneficial Ownership and Anti-Avoidance Risk

June 3, 2026Substance Beats Formality: What the Milan Tax Court’s Luxembourg Holding Ruling Means for Cross-Border Tax Planning

June 1, 2026The Hidden Systems Challenge of IFRS 20: Why Data, Controls and Audit Readiness Matter

June 1, 2026IFRS 20 and EBITDA: Why Lenders, Investors and Boards Must Pay Attention

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