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Entity Diagram · Cross-border

International tax holding structure — Entity Diagram

Cross-border tax holding structure with Irish IP company, Dutch distribution, and APAC entity — per OECD BEPS transfer-pricing documentation requirements.

Type Entity structureStandard Tier-based ownership hierarchyEngine schematex-entityUpdated 5/27/2026
International tax holding structure
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The scenario

Corporate counsel or a Big Four tax team draws this structure during cross-border M&A due diligence or transfer-pricing documentation. The OECD BEPS framework requires taxpayers to document the substance and economic rationale of every intercompany flow — this diagram is the first attachment to the TP master file and the tax opinion memo.

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