RBK
Tax Solutions
RBK
Tax Solutions
Wealth Strategy

Precision Tax Strategy for High Net Worth

Multi-Jurisdictional Optimization • Wealth Preservation • Absolute Discretion.

BEPS Frameworks
Transfer Pricing
CFC Defense
0
Global Jurisdictions
$1M+
Tax Savings Secured
0
Years Expertise

Our Expertise

Comprehensive Tax Advisory for the Discerning Client

Strategic solutions tailored to your unique financial landscape, spanning international jurisdictions and complex wealth structures.

Tax Planning & Strategy

Proactive strategies that optimize your tax position year-round, maximizing deductions and preserving wealth.

Explore Strategy

International Tax

Expert navigation of global tax complexity for individuals and businesses across HK, UAE, Europe, and Americas.

Global Advisory

Estate & Legacy Tax

Sophisticated gift and estate tax strategies that protect your legacy for future generations.

Legacy Planning

Case Study

From 45% Personal Tax to Strategic Corporate Efficiency

"As a UK-based entrepreneur, I was trapped in the 45% higher tax bracket. RBK architected a sophisticated international LLC structure that shifted my liability from personal income to efficient corporate rates, saving me over £1 million annually while remaining 100% compliant with HMRC and global standards."
JW
Julian Wentworth
Founder, Wentworth Digital Systems

Strategic Impact Visualization

Before: 45% Personal Bracket £1.2M Burden
After: RBK LLC Strategy £200K Corp Tax
Total Annual Savings £1.0M Saved

Core Competencies

Advanced Tax Optimization Frameworks

Leveraging sophisticated international structures and compliance-driven methodologies to achieve optimal effective tax rates

01

Transfer Pricing Optimization

OECD BEPS-Compliant

Strategic allocation of profits across jurisdictions through arm's-length intercompany transactions. We leverage OECD guidelines and local regulations to optimize your global effective tax rate while maintaining defensible transfer pricing documentation.

Intangible IP Migration: Repositioning valuable intellectual property to favorable jurisdictions
Cost Contribution Arrangements: Collaborative development structures for shared value creation
Comparability Analysis: Economic substance documentation for all intercompany pricing
02

Hybrid Entity Structuring

Cross-Border Asymmetry

Deployment of entities treated differently under multiple tax regimes to create legitimate deduction/inclusion mismatches. While BEPS Action 2 has closed many hybrid arrangements, sophisticated structures remain viable under careful design.

Disregarded Entity Planning: US LLCs treated as transparent in one jurisdiction, opaque in another
Treaty Shopping Defense: Principal Purpose Test (PPT) and Limitation on Benefits (LOB) compliance
Substance Over Form: Economic presence requirements for regulatory acceptance
03

Permanent Establishment Mitigation

Article 5 Defense

Careful structuring to avoid creating taxable nexus in high-tax jurisdictions. We analyze the nature and extent of business activities to prevent inadvertent PE creation under OECD Model Tax Convention Article 5.

Fixed Place Analysis: Avoiding physical presence triggers through activity fragmentation
Dependent Agent Structuring: Ensuring intermediaries don't create attribution
Digital Services PE: Managing Pillar One implications and digital taxation
04

Controlled Foreign Corporation Defense

Subpart F & GILTI

Navigating anti-deferral regimes that tax foreign earnings currently. We employ high-tax exceptions, active business exemptions, and corporate blocker structures to minimize current taxation on foreign operations.

GILTI Minimization: Leveraging QBAI depreciation and high-tax kickout provisions
Active Business Qualification: Manufacturing, services, and active trade exceptions
UK CFC Reform: Navigating gateway tests and entity-level exemptions

Strategic Implementation Pillars

Tax Treaty Network Leverage

Utilizing bilateral agreements to minimize withholding taxes on dividends, interest, royalties through optimal holding structures

Capital Gains Optimization

Strategic timing and jurisdictional placement of asset dispositions to minimize or eliminate capital gains taxation

Comprehensive Documentation

Master files, local files, CbC reporting, and economic substance documentation for full audit defense

Our Methodology

The 4-Step Precision Framework

01

Discovery

Comprehensive review of your financial architecture and long-term objectives.

02

Design

Custom strategy architecture designed to optimize position while ensuring compliance.

03

Execution

Meticulous implementation of strategies with global coordination.

04

Optimization

Continuous monitoring and adaptive refinement as tax landscapes evolve.

Elite Professional Credentials

Chartered Tax Advisers
Licensed Tax Attorneys
Global Controversy Specialists

Common Inquiries

Expert Insights on Global Taxation

We believe in transparent, elite communication. Here are answers to questions frequently asked by our HNWI clients.

Our firm operates with the highest standards of discretion. We utilize bank-grade encryption for all data and follow strict attorney-client privilege protocols for all strategic communications.
Our core expertise spans Hong Kong, the UAE (Dubai/Abu Dhabi), Panama, Paraguay, and various European tax regimes, alongside deep-seated US tax strategy experience.
Our multidisciplinary team provides robust defense across multiple jurisdictions, from IRS examinations in the US to resolving disputes with the Inland Revenue Department in Hong Kong or the FTA in the UAE.

Ready to Optimize Your Global Tax Position?

Our senior strategists are standing by to provide a confidential assessment of your international tax landscape. Discover sophisticated structures tailored to your unique financial architecture.

Bank-Grade Confidentiality
No Obligation Assessment
Senior Strategist Direct Access

Global Reach

Our experts are available across multiple timezones to ensure priority support for our global clientele.

HOURS
24/7 Priority Access
REGIONS
HK • UAE • EU • US
TELEGRAM
@RBK_Strategist

Confidentiality Assurance

All communications are protected by bank-grade encryption and strict internal privacy protocols.