01
P.O.E.M.
Place of Effective Management
Is your residency safe from corporate inversion or dual-residency claims?
Bulletproof Substance & Evidentiary Defense
Audit Defense & Protection
In the era of modern international tax enforcement, a strategic tax opinion is only as strong as the documentary evidence backing it up. We specialize exclusively in building, structuring, and notarizing audit-ready defense files that satisfy the highest standards of international anti-abuse rules.
+15
Years of practice
+400
Files integrated
98%
Favorable rulings
24h
Response to requests
Services
Defense built
on notarized
evidence.
A practice focused on evidentiary substance: documenting, certifying and protecting every operation before the tax authority.
File integration
Methodical construction of the defense file: contracts, receipts, logs and material evidence.
Document notarization
Notarial certification of documents, facts and certain dates that shield evidence under review.
Audit defense
Comprehensive support during reviews, on-site visits and desk audits.
Authority-Driven Risk Scoring
A comprehensive assessment of corporate structures, featuring a Defensive Risk Score tied to tax jurisdiction aggressiveness.
Methodology
A rigorous process. Four phases.
01
Pre-Diagnosis
We assign a baseline Defensive Risk Score calculated against the specific behavioral patterns of the target tax administration
02
Daily Optimization
Orderly collection of evidence, supporting records and substance. Notarization & Timestamping when needed
03
Audit-Ready Status
We notify you when you reach the status of low risk score profile against the exposure to PPT, POEM, MLI, and CFC Rules.
04
Defense
We assist you in case of international tax audit is triggered by a specific jurisdiction
We Continuously Verify
The Six Pillars of Modern International Tax Friction.
We audit your setup against the exact six pillars of modern international tax friction. Your score increases with every framework you need to be safe from.
02
PPT
Principal Purpose Test
Can you objectively prove that tax optimization was not the primary driver of the transaction?
03
Substance Over Form
Substance Over Form Test
Does your physical, economic reality perfectly match your legal contracts and corporate design?
04
MLI Clauses
Multilateral Instrument
Are your treaty benefits vulnerable to the latest OECD anti-abuse updates ratified between your operating jurisdictions?
05
National Anti-Abuse Laws
Domestic GAAR
Do you comply with specific, domestic General Anti-Abuse Rules unique to that country?
06
CFC Rules
Controlled Foreign Company
Are your foreign subsidiaries at risk of income attribution under Controlled Foreign Company rules?
YouTube channel
Tax knowledge,
in the open.
Analysis, criteria and case studies on documentary defense and tax audits. Each week, content for taxpayers, accountants and attorneys.
Visit the channel Contact
An audit is won before it begins.
Schedule a confidential consultation. We will assess your documentary situation and design a tailored protection plan.