A hospitality operator with cross-border presence across UK and Indonesia. Restructured the holding architecture and tax position. Saved a six-figure compliance cost over two years.
The situation
A hospitality founder operating across the UK and Indonesia reached us with a holding structure that had grown organically as the business expanded. The operating entities in each jurisdiction were sound. The structure between them was not. The founder was paying tax twice on the same profit in two regimes, was carrying compliance cost for entities that no longer served a purpose, and had a transfer-pricing position that would not survive the next audit.
The cost of doing nothing was visible. The cost of doing something was the founder’s reluctance to disrupt a working business to fix a structural problem.
The work
A scoped tax-structure review across the UK and Indonesia entities. The work used the ADIT-shaped framework that anchors the cross-border capability of the practice. UK side: permanent establishment risk, residency tests for the founder, hybrid mismatch exposure. Indonesia side: PSAK alignment, OSS-RBA structuring, transfer pricing under PMK-35.
The recommendation was a simplified holding structure that retained operating control in both jurisdictions, eliminated the double-taxation exposure, and reduced the number of entities by a third.
The outcome
The restructure was implemented over a six-month period in conjunction with the founder’s existing lawyers and accountants. The annualised compliance cost reduction is six figures. The tax position is now stable against forward-looking audits in both jurisdictions.
What we worked
Founder Diagnostic, then quarterly tax-structure advisory inside the Fractional CFO Retainer.
The pattern this engagement surfaced
Cross-border tax problems almost always feel like an accountant question. They are usually a structural question. The accountant can file the right return inside the existing structure. The structure is what is producing the wrong return.
If your business runs across two or more tax regimes and the structure has grown rather than been designed, the conversation starts with a Discovery Exchange.