Business Structure Design

In global expansion, the holding structure of a company directly impacts its tax burden, capital efficiency, and governance flexibility.IVYE GROUP provides tailored structure design services for corporate groups and pre-IPO entities. By integrating multi-jurisdictional regulations, we help clients establish compliant and practical international holding and investment structures—enhancing overall tax efficiency, capital flow, and strategic flexibility.

✅ Scope of Structure Design Services

  • Offshore structure planning (e.g., BVI + Singapore + PRC)
  • Holding structure and “Red-Chip” pathway advisory
  • Cross-border fund flow and profit repatriation planning
  • Shareholder rights allocation and agreement drafting
  • CRS, FATCA, and other disclosure compliance advisory
  • Pre-IPO equity restructuring strategies

📍 Structure Design Workflow

1
Needs Analysis & Objective Identification
  • Define expansion goals (IPO preparation, tax optimization, risk isolation, global footprint)
  • Analyze business regions, applicable tax treaties, and future capital pathways
  • Map relationships between holding entities, fund flows, and ultimate beneficial owners
2
Structure Design & Scenario Simulation
  • Develop layered holding structures with nodes in Singapore, BVI, Cayman, Hong Kong, etc.
  • Simulate tax, capital mobility, and reporting obligations under different structures
  • Plan Red-Chip or VIE frameworks with draft governance agreements
3
Cross-Border Capital Flow & Tax Efficiency
  • Design capital injection pathways and profit repatriation methods (dividends, interest, royalties, etc.)
  • Identify withholding tax risks and evaluate treaty applications
  • Build compliance mechanisms for CRS/FATCA reporting requirements
4
Shareholder Rights & Governance Agreements
  • Define shareholding arrangements for founders, investors, and onshore/offshore entities
  • Draft key terms for VIE agreements, joint venture agreements, or shareholder pacts
  • Reserve flexibility for future fundraising, exit planning, and control transitions
5
Pre-IPO Restructuring & Optimization (if applicable)
  • Provide pre-IPO shareholder and equity structure reviews
  • Align offshore holding frameworks, tax residency planning, and due diligence requirements
  • Evaluate listing rules and transparency standards across different exchanges
6
Jurisdictional Coordination & Execution
  • Deliver structure diagrams and transaction flowcharts to support implementation
  • Liaise with legal advisors, corporate secretaries, and tax teams across jurisdictions
  • Assist with registrations, amendments, and compliance filings as required

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