How We Work
Some clients come to us before a single decision has been made about Ireland. Others arrive with a structure already in place that has never been formally reviewed. The engagement process is designed to serve both situations equally, and every client remains within an active oversight framework once the engagement concludes.
Considering Ireland for the first time
You are weighing the commercial case for an Irish structure and need specialist analysis of what it genuinely requires before committing to anything. The feasibility assessment is where the engagement begins.
Operating an existing Irish structure
Your Irish entity is already in place. The structure may not have been reviewed against current standards, or the business has evolved since it was established. The engagement begins with a structured review of where the position currently sits.
The following stages apply to both entry points. Where a client enters at the existing structure path, the earlier stages are replaced by a structured review that establishes the current position before the analysis proceeds.
The Enquiry
Contact begins with a short written enquiry describing the business, the existing structure where one is in place, and the circumstances that prompted the question about Ireland. The enquiry confirms whether the matter falls within the scope of this practice and whether the next stage is appropriate. Every enquiry is reviewed personally and a response is provided within two working days.
The Feasibility Assessment or Structural Review
For clients considering Ireland for the first time, this stage examines the business model, operational structure, customer geography and revenue profile alongside the interaction between the proposed Irish position and the existing UK structure. The output is a written recommendation identifying the conditions under which the structure operates appropriately and any adjustments required before implementation proceeds.
For clients with an existing Irish structure, this stage establishes a complete picture of where the position currently sits across both jurisdictions, identifying what is technically sound, what requires adjustment and what the priority areas are before the position can be considered defensible.
The Risk and Viability Review
The structure is examined across all relevant technical areas before any recommendation is made.
The CFC position, UTPR exposure, UTPP risk, transfer pricing methodology, substance framework, corporate residence analysis and permanent establishment considerations are assessed together as a single structural position rather than as separate issues.
This stage includes Reverse Viability. The implications of exiting the structure are modelled so that the full commercial and technical consequences of both entry and exit are understood before any commitment is made.
Design, Implementation or Remediation
For new structures, the design is completed in full and professional advisers across both jurisdictions are coordinated through a single integrated brief. Transfer pricing methodology is documented at the point it is established. Substance arrangements are evidenced from the beginning of the Irish operation. The compliance calendar is in place before the structure becomes operational.
For existing structures requiring adjustment, remediation is scoped and agreed in writing before work begins. Each element is addressed in a defined sequence so that the position moves from its current state to a technically sound and fully documented one in a controlled and orderly way.
Documentation produced during this stage forms the technical record on which the structure stands.
Ongoing Oversight
Cross-border structures require active oversight and every client remains within that framework after their engagement concludes. The commitment ensures the structure remains sound as legislation and commercial circumstances evolve.
Legislation changes in ways that directly affect existing structures. The introduction of the Unassessed Transfer Pricing Profits regime and the expansion of outbound payment defensive measures are recent examples. Businesses also develop as people move, operational functions change and group structures adapt.
Ongoing oversight covers the full structural position on a periodic basis. Where legislative or commercial developments affect the structure, clients are informed and the necessary adjustments are addressed as part of the oversight process. No client finishes an engagement with Cross-Border Strategists and is left to monitor a complex cross-border position alone.