// Already Structured Offshore?
You built a profitable business offshore. Congratulations — now try getting the money out. Withholding taxes eat 5-30% at the border. FX controls require government approval. Dividends trigger double taxation. The profit is real. The access isn't. We design compliant extraction channels — royalties, management fees, intercompany structures — so your money actually reaches you.
Book Your Consultation// The Problem
Dividends from your operating company to you personally: 5-30% withholding tax at source, depending on jurisdiction and treaty network. A $1M dividend from a Vietnamese company to a non-resident? Up to $100K gone before it leaves the country. And that's before your personal income tax at destination.
Many jurisdictions require central bank approval for outbound transfers above certain thresholds. Vietnam's State Bank of Vietnam controls foreign exchange. Indonesia requires tax clearance certificates. India needs RBI compliance. Your bank account shows profit — but the transfer gets blocked, delayed, or questioned.
Corporate tax on profits (17-25%). Withholding tax on extraction (5-30%). Personal income tax on receipt (0-45%). Without treaty planning and proper structuring, your effective rate stacks to 40-60%. A profitable business becomes a tax trap — money grows inside the company but costs a fortune to access.
// The Solution
Every channel below is legal, documented, and audit-ready. The difference between tax avoidance and tax evasion is paperwork. We handle the paperwork.
Extract 5-15% of revenue as royalties. Your operating company licenses IP (brand, software, know-how) from a holding company in a treaty jurisdiction. Royalty payments are deductible expenses for the operating company, reducing corporate tax. Withholding tax on royalties: 5-10% via treaty (vs. 20-30% without). The holding company receives royalties at favorable rates.
Deductible at source, taxed at destination. A regional holding provides genuine management services — strategic direction, compliance oversight, financial reporting, HR support. Fees must be at arm's length (market rate) and documented. Transfer pricing reports are essential. Done properly, management fees are the most flexible extraction channel.
Treaty-reduced withholding, participation exemption at holding level. Operating company → holding company dividend: reduced withholding via double tax treaty (often 5% vs. 10-30% direct). Holding company receives dividend under participation exemption (0% in Singapore, Hong Kong, Cyprus). From holding to you: one more layer, but total extraction cost drops to 5-8%.
Interest deductible, principal tax-free. Holding company lends to operating company. Interest payments are deductible for the borrower, reducing corporate tax. Principal repayments are not income — they're debt service. Withholding on interest: 5-15% via treaty. Thin capitalization rules apply — debt-to-equity ratios matter. We model the optimal structure.
Shared services at cost + margin. Centralize functions (accounting, IT, marketing) in a regional hub. Bill operating companies at cost plus 5-10% margin. Every payment is a deductible expense at source and modest income at the hub. Spreads profit across the structure and creates genuine economic substance.
Centralize cash, deploy capital efficiently. A treasury company in Singapore or Hong Kong manages group liquidity. Operating companies deposit excess cash; treasury deploys across the group. Interest income at treasury level, deductible at source. Requires genuine treasury function and proper documentation.
Every month your money stays trapped is a month of opportunity cost. 30-minute consultation to map your extraction options — we'll model the numbers for your specific situation.
// Case Study
A European founder running a $4M-revenue manufacturing operation in Ho Chi Minh City. Vietnamese corporate tax: 20%. Dividend withholding to non-resident: 10%. Effective extraction cost without structuring: 28%. After restructuring: Singapore holding company licenses the brand and production know-how to the Vietnamese subsidiary. Management fees for regional oversight. Royalty withholding: 5% (Vietnam-Singapore DTA). Management fee withholding: 0% (service PE exemption with proper structuring). Dividend to Singapore holding: 5% (treaty rate). Singapore participation exemption: 0% on dividends received. Total extraction cost: under 8%. Annual savings: $80K+ on $1M extracted.
"Built a factory in Vietnam, $4M revenue, couldn't get the money out efficiently. Direct dividends were costing me 28% by the time they reached my personal account. Singapore holding with IP licensing and management fees — total extraction cost dropped to 7.5%. The structure paid for itself in the first quarter."
// Transfer Pricing
Every intercompany payment must be priced as if between unrelated parties. Royalties benchmarked against comparable license agreements. Management fees based on time allocation and market rates. Interest on loans at published interbank rates plus appropriate spread. Without benchmarking, tax authorities reclassify payments as disguised profit distribution.
Transfer pricing documentation is not optional — it's mandatory in most jurisdictions with penalties for non-compliance. Master file (group-wide overview), local file (entity-specific transactions), country-by-country reporting (for larger groups). Vietnam requires TP documentation for all related-party transactions above VND 50 billion. We build documentation into the structure from day one.
The holding company must do something real. Employees, office space, board meetings, actual decision-making. Shell companies with no substance get their treaty benefits denied. Tax authorities share information automatically via CRS — they know when a "Singapore company" has no Singapore presence. We ensure genuine economic substance at every node.
// FAQ
You can — but dividends often trigger withholding tax at source (5-30% depending on jurisdiction and treaty), plus income tax in your personal tax residency. A $500K dividend can lose $150K+ to double taxation. Proper structuring — holding companies in treaty jurisdictions, royalty flows, management fee arrangements — can reduce total extraction cost to under 5%. Book a consultation to model your specific numbers.
Corporate tax hits profits inside the company (17% in Singapore, 20% in Vietnam, 9% in UAE). Withholding tax hits money leaving the country — dividends, royalties, interest, management fees paid abroad. They stack. A company in Vietnam pays 20% corporate tax, then 5-10% withholding on the remainder when sending it out. Your effective rate climbs fast. We design structures that minimize both layers.
Absolutely — if done properly. Royalties for IP use, management fees for services rendered, interest on intercompany loans — these are standard business transactions used by every multinational. The key is arm's length pricing (market rates), proper documentation (transfer pricing reports), and genuine substance (real services, real IP). Without these, tax authorities reclassify payments as disguised dividends. We ensure your structure withstands audit.
Transfer pricing is the biggest compliance risk in cross-border structures. Tax authorities in Vietnam, Indonesia, India, and increasingly across Southeast Asia actively audit intercompany transactions. Payments above market rate get denied. Documentation gaps invite penalties. We build transfer pricing documentation into every structure — benchmarking studies, functional analyses, and master files that satisfy local requirements.
Typically 2-4 months for a holding company with IP licensing and management fee arrangements. This includes entity formation, bank account opening, IP assignment, transfer pricing documentation, and the first compliant payment flow. Rush timelines are possible but increase compliance risk. We recommend starting before year-end to capture a full fiscal year of benefit. Book a consultation to map your timeline.
Yes, but Vietnam has specific challenges: foreign contractor tax (FCT) on payments abroad, strict FX controls requiring State Bank approval for large transfers, and withholding tax rates that vary by payment type (5% royalties via treaty, 10% management fees, 5% dividends via treaty with Singapore). A Singapore holding with IP licensing is the most common compliant structure. We work with Vietnam-based counsel to ensure every payment clears FOREX approval.
// Related Solutions
Every dollar trapped in a poorly structured entity is a dollar you can't reinvest, can't spend, can't deploy. The extraction structure typically pays for itself within the first transfer. Book a consultation — 30 minutes, no obligation.