How a Tech Scale-Up Rebuilt Its Global Tax Structure Safely

A rapidly growing software-as-a-service group from the technology sector had expanded into eight countries within four years. The founders focused on product and sales, while tax and legal structures developed in an improvised way. Local advisors in each jurisdiction gave isolated recommendations, and no one coordinated the overall picture. The group reached a point where investors started asking detailed questions about international tax exposure, especially regarding intellectual property and transfer pricing. At this stage, the management decided that structured support in international tax law was essential to secure the next funding round.

The board engaged Radner’s team to perform a comprehensive review of the group’s cross-border tax position. The initial mandate covered analysis of the holding structure, intellectual property ownership, intercompany financing and pricing of intra-group services. Radner’s team began with a series of workshops with the CFO, head of legal and regional managers to map how the business actually operated. This operational mapping was crucial, because the tax structure had to reflect real value creation, not a theoretical model. The workshops revealed that key development and strategic functions were concentrated in two countries, while revenue was booked in many more.

Radner’s team then conducted a detailed review of existing contracts, including license agreements, development contracts and service arrangements between group entities. Many of these documents were outdated, inconsistent or never fully executed. The team identified that intellectual property was formally owned by a small entity in a low-tax jurisdiction, but most development work and risk-taking occurred elsewhere. This created a significant risk of tax authorities challenging the allocation of profits. The review also showed that some local entities were under-remunerated for their functions, which could lead to transfer pricing adjustments.

Using the findings from the review, Radner’s team prepared a risk matrix covering all jurisdictions where the group operated. Each risk was assessed in terms of probability, potential financial impact and complexity of remediation. The matrix highlighted three critical areas: intellectual property alignment, transfer pricing documentation and withholding tax exposure on cross-border payments. The team presented this matrix to the board in a structured session, explaining how international tax law principles applied to the group’s specific fact pattern. This allowed the board to prioritize actions based on both risk and business strategy.

One of the first strategic decisions was to redesign the intellectual property holding model. Radner’s team proposed relocating ownership of core software and trademarks to a jurisdiction that combined a robust treaty network with substance requirements that the group could realistically meet. The proposal was not driven solely by tax rates, but by alignment with where key people and functions were located. The team explained how the DEMPE functions analysis under international tax standards would support the new structure. This gave the board confidence that the model would be defensible in tax audits.

To implement the new intellectual property structure, Radner’s team coordinated with local counsel in three jurisdictions. The process involved valuation of existing intangibles, design of new license and development agreements, and planning of any exit taxation in the countries where intellectual property was previously booked. The team prepared step plans describing each legal and tax action in chronological order, including required filings and expected timelines. These step plans were shared with management and investors to demonstrate that the restructuring was controlled and compliant.

Parallel to the intellectual property workstream, Radner’s team addressed transfer pricing. The group had historically used simple cost-plus markups for most intra-group services, without detailed benchmarking. Radner’s team performed a functional and risk analysis for each type of entity: development centers, sales hubs, support teams and the central platform company. Based on this analysis, the team designed a new transfer pricing policy that differentiated between routine and entrepreneurial functions. Benchmarking studies were obtained to support arm’s length margins, and a consistent methodology was defined for all countries.

Documentation was a critical element of the project. Radner’s team prepared a master file describing the group’s global business, value chain and transfer pricing policy. Local files were drafted for priority jurisdictions where tax audits were most likely. The team ensured that the documentation aligned with the new intellectual property structure and reflected the actual flow of services and risks. This comprehensive documentation package significantly reduced the risk of penalties and adjustments in future audits. It also provided a clear narrative that management could use when discussing tax matters with investors.

Another important area was withholding tax on cross-border payments, especially royalties and service fees. The group had previously relied on local finance teams to apply treaty rates, often without formal residency certificates or beneficial ownership analysis. Radner’s team reviewed payment flows and identified where treaty benefits might be challenged. The team then designed standardized procedures for obtaining and storing documentation needed to apply reduced withholding tax rates. This included templates for declarations, checklists for finance staff and guidance on when to seek advance rulings.

As part of the international tax law support, Radner’s team also evaluated the group’s exposure under anti-hybrid and anti-avoidance rules. Some financing arrangements between group entities used instruments that could be treated differently in various jurisdictions. The team analyzed whether any mismatches could trigger denial of deductions or other adverse consequences. Where necessary, financing structures were simplified to eliminate ambiguity. This not only reduced tax risk but also made the group’s financial reporting more transparent for investors.

Communication with stakeholders was carefully managed throughout the project. Radner’s team prepared concise briefing materials for the board, focusing on strategic implications rather than technical detail. For the finance and legal teams, more detailed technical memos were provided, explaining the rationale behind each structural change. Training sessions were organized for regional controllers to ensure they understood the new transfer pricing policy and documentation requirements. This multi-layered communication approach ensured that the new structure would be implemented consistently across the group.

During the implementation phase, Radner’s team monitored progress against the step plans and adjusted timelines where regulatory approvals took longer than expected. The team coordinated with notaries, valuation experts and local tax advisors to ensure that all formalities were completed correctly. When questions arose from local tax authorities about specific transactions, Radner’s team prepared responses that framed the changes within the broader business rationale. This proactive engagement helped avoid disputes and delays.

Within twelve months, the group had a fully implemented and documented global tax structure aligned with its business model. Intellectual property ownership was consolidated in a jurisdiction with strong substance and treaty protection. Transfer pricing policies were consistent, benchmarked and supported by robust documentation. Withholding tax procedures were standardized, reducing the risk of unexpected costs on cross-border payments. The board now had a clear overview of tax risks and mitigation measures, which was a significant change from the previous fragmented situation.

The benefits of the project became particularly visible during the next funding round. Investors conducted detailed due diligence on tax matters, including review of transfer pricing documentation and intellectual property arrangements. Radner’s team supported management in responding to due diligence questions, providing technical explanations where needed. The structured international tax law framework reassured investors that the group’s global expansion was sustainable from a tax perspective. This contributed to a higher valuation and smoother negotiation of investment terms.

In the longer term, the new structure also facilitated expansion into additional markets. Because the group now had clear policies and documentation templates, opening entities in new countries became more predictable. Radner’s team remained involved on a periodic basis, updating documentation and advising on new regulatory developments. The group could focus on product innovation and sales, knowing that cross-border tax matters were under control. This shift from reactive problem-solving to proactive planning was one of the most significant qualitative outcomes.

From a financial perspective, the project did not aim to minimize tax at all costs, but to achieve a sustainable and defensible position. Effective tax rates stabilized within a predictable range, and the risk of large retroactive assessments was significantly reduced. The group also avoided potential double taxation by aligning profit allocation with value creation. The combination of reduced uncertainty, improved investor confidence and operational clarity demonstrated the tangible value of structured support in international tax law for a fast-growing tech business.

Ultimately, the case of this technology scale-up shows how a fragmented international footprint can be transformed into a coherent, compliant and strategically aligned tax structure. By integrating legal, financial and operational perspectives, Radner’s team created a framework that supported both current operations and future growth. The project illustrated that international tax law, when applied thoughtfully, is not merely a defensive tool but a foundation for secure global expansion and long-term value creation.