How to Set Up Offshore Tax Structures for Real Estate

Offshore structuring for real estate isn’t about hiding money. It’s about building a clear, compliant path for cross‑border investing that keeps more of your returns, protects assets, and makes financing and exits simpler. Done right, it’s boring—in the best possible way. Done poorly, it’s expensive, stressful, and can unravel at the worst time (usually a refinancing or an exit). This guide walks you through how I approach these projects with clients: practical steps, key decisions, and the pitfalls that matter. Quick note: this is general information to help you frame decisions and questions; work with qualified tax and legal advisors for your specific situation.

What Offshore Structuring Can (and Can’t) Do

Offshore structures are tools. They can be smart, legal, and efficient—if you use them for the right purposes.

What it can do:

Reduce friction from withholding taxes through treaty access.

Ring‑fence liabilities with special‑purpose vehicles (SPVs) per property or project.

Centralize ownership for joint ventures or multiple investors.

Improve financing capacity and interest deductibility within rules.

Provide succession planning and asset protection when paired with trusts/foundations.

Make exits cleaner (selling a shares in a holdco vs. the property, where feasible).

What it can’t do:

Eliminate tax in the country where the property is located. Real estate is taxed at source almost everywhere.

Provide secrecy. The Common Reporting Standard (CRS) and FATCA mean banks and administrators report beneficial owners and financial information across borders.

Bypass anti‑avoidance rules like CFC regimes, GAAR, hybrid mismatch rules, or economic substance requirements.

What has changed:

Economic substance now matters. Most jurisdictions require demonstrable people, premises, and decision‑making where the company claims to be resident.

Treaties aren’t automatic. “Treaty shopping” structures without real substance risk denial of benefits under Principal Purpose Tests (PPT) and similar rules.

The era of “letterbox” companies is effectively over.

The Building Blocks of a Typical Structure

Think of your structure as a stack with each layer performing a job, and each job documented.

Investor level:

Individuals, family offices, pension funds, sovereigns, or funds. Investor type dictates reporting, exemptions, and CFC exposure.

Top holding company (HoldCo):

Sits in a treaty‑friendly jurisdiction with established governance, e.g., Luxembourg, Ireland, the Netherlands (with caveats), Singapore, UAE, Jersey/Guernsey. The HoldCo owns lower‑tier SPVs.

Property SPVs (PropCos):

Local companies or partnerships that actually hold the real estate and deal with local taxes, permits, and operations.

Financing entities:

Sometimes a separate finance vehicle provides debt to PropCos to optimize interest deductibility within limits, and to segment credit risk.

Fund or joint‑venture layer:

If you’re aggregating external investors, a fund vehicle (e.g., Cayman/Delaware LP, Luxembourg RAIF/SIF) may sit above the HoldCo.

Trusts or foundations:

Used sparingly for succession and asset protection, typically above the investment stack. They add complexity and reporting.

The cash flow map:

Equity and shareholder loans flow down to SPVs for acquisitions.

Rents pay expenses, then service debt, then distribute profits up.

On exit, proceeds return as dividends, interest, or capital gains at HoldCo level.

The tax layers you must model:

Corporate income tax at PropCo level.

Withholding tax (WHT) on interest, dividends, and sometimes service fees paid cross‑border.

Property‑specific taxes (e.g., real estate transfer tax/stamp duty on acquisitions and sometimes share deals).

VAT/GST on development, management, and leasing activities.

Capital gains tax on the sale of property or property‑rich entities.

Frameworks That Shape Your Options

Before sketching diagrams, you need to know the rules of the game.

OECD BEPS and ATAD (EU):

Limit interest deductions (often 30% of EBITDA, plus carryforwards).

Attack hybrids (payments treated differently across jurisdictions).

Introduce GAAR/PPT to deny benefits where tax advantage is the main purpose.

Economic Substance:

Zero‑ or low‑tax jurisdictions now require core income‑generating activities, local directors, adequate expenditure, and office presence. Paper boards no longer pass scrutiny.

CRS and FATCA:

Banking secrecy is gone. Financial institutions report account holders and controlling persons. Expect KYC/AML questions and annual reporting.

CFC rules:

Your home country may tax low‑taxed offshore profits as they arise. Real estate income can be caught unless it’s demonstrably active and taxed at reasonable rates.

Pillar Two (15% global minimum):

Applies to groups with consolidated revenue above €750 million. It can alter the calculus for large real estate groups and institutional investors by imposing top‑up tax if an entity pays below 15%.

Source‑country specifics:

US: FIRPTA taxes non‑US persons on US real estate gains; 15% withholding on gross sale proceeds generally applies unless an exception. REIT distributions can attract 30% WHT without treaty relief.

UK: Non‑residents are taxed on gains from direct and indirect disposals of UK property; SDLT applies on asset acquisitions; interest deductibility is tightly policed.

Germany: Real estate transfer tax can be triggered on share transfers in property‑rich entities when ownership thresholds are crossed.

Each market has its quirks—model them early.

Step‑by‑Step: Designing a Compliant Offshore Real Estate Structure

I follow a repeatable sequence. It avoids rework and helps you catch issues before they become expensive.

1) Define the investment strategy and investor profile

Hold vs. develop? Leverage level? Income vs. capital gains?

Investors: US taxpayers? EU funds? Middle Eastern family office? CFC and reporting rules vary.

Time horizon and exit strategy. Many tax benefits reverse if you exit the wrong way.

2) Choose target property jurisdictions

Where are you buying? Each destination sets the base tax cost and reporting obligations.

Are you building a portfolio across countries? Consider a hub jurisdiction with treaty coverage to multiple target markets.

3) Map cash flows and exit scenarios

Draw how money moves for three states: steady‑state operations, refinancing, and exit (asset sale vs. share sale).

Identify what’s taxed where. Model WHT on interest/dividends and local corporate tax.

4) Run a treaty and domestic law analysis

For each payment, check domestic WHT rates, treaty reductions, and limitation on benefits/PPT.

Check capital gains treatment on share disposals of property‑rich entities.

5) Pick the entity stack

Decide on HoldCo jurisdiction based on treaties, governance, and your investor base.

Use a separate SPV per asset or per country to ring‑fence liabilities and simplify exits.

Consider whether a financing SPV or intercompany loan makes sense—only if it passes substance and transfer pricing tests.

6) Build a substance plan

Appoint resident directors with real decision‑making authority.

Secure an office or a corporate services arrangement that provides dedicated space and staff support.

Hold board meetings and keep minutes in the jurisdiction of incorporation. Document mind and management.

7) Design financing and transfer pricing

Set leverage targets within interest limitation rules. Bank debt is generally easier to defend than shareholder debt.

Price shareholder loans at arm’s length, with clear loan agreements, interest rate benchmarking, and covenant terms.

Avoid hybrids that are neutralized by anti‑hybrid rules.

8) Check regulatory and fund rules (if raising money)

EU marketing triggers AIFMD compliance. Understand if your vehicle is an AIF and who the AIFM is.

Some jurisdictions require licensing for loan origination or property management.

9) Set up banking and service providers

Choose banks that understand cross‑border real estate. Expect 6–12 weeks for KYC.

Appoint auditors, administrators, and tax agents early; they keep your compliance calendar on track.

10) Register for taxes and elections

VAT/GST registrations for development or property management.

Withholding tax registration for interest and dividend payments.

Local corporate income tax filings and elections (e.g., group relief, REIT elections where applicable).

11) Assemble documentation

Intercompany agreements (loans, management, IP licenses if any).

Board resolutions, powers of attorney, registers of beneficial owners.

Transfer pricing documentation with functional analysis and comparables.

12) Implementation timetable

Entity formation: 1–4 weeks for most SPVs; 4–8 weeks for holding entities with bank accounts.

Acquisition closing: coordinate legal, tax, and financing tracks. Always leave buffer for bank KYC.

13) Ongoing compliance

Annual audits where required, substance returns, CRS/FATCA reporting, WHT filings.

Update TP documentation after refinancings or material changes.

Governance cadence: quarterly board meetings supported by real reporting packs.

Choosing Jurisdictions: Pros, Cons, and Use Cases

There’s no universal “best” jurisdiction. The right answer depends on where you invest, who your investors are, and the kind of substance you can credibly maintain.

Luxembourg

Why it’s popular:

Broad treaty network across Europe and beyond.

Flexible vehicles (Sàrl, SA, Soparfi, SCSp, RAIF/SIF for funds) and investor‑friendly legal frameworks.

Established ecosystem of administrators, banks, and directors.

Considerations:

Corporate tax exists; the HoldCo may pay little if it mainly holds shares and qualifies for participation exemptions, but operating entities face normal rates.

Withholding tax on dividends generally applies, with exemptions for qualifying parent/participation holdings or treaties. Interest is usually not subject to WHT if structured properly.

Substance and transfer pricing enforcement are real; expect scrutiny, especially on shareholder loans.

Good fit:

Pan‑EU portfolios, institutional investors, and situations needing debt pushdown with robust TP support.

Netherlands

Pros:

Strong legal system, experienced service providers, historically extensive treaties.

Well‑known for cooperative tax rulings (now more limited) and clear TP frameworks.

Watch‑outs:

Anti‑abuse rules tightened considerably; WHT on certain payments to low‑tax jurisdictions; PPT challenges.

Requires meaningful substance; “conduit” structures are risky.

Good fit:

Corporate groups with existing Dutch presence and genuine operational substance.

Ireland

Pros:

Common law system, good treaties, respected fund ecosystem.

Section 110 vehicles exist but are carefully policed for property‑related income.

Watch‑outs:

Irish tax authorities target perceived abuses; ensure your asset class and cash flows align with accepted structures.

Expect robust TP and substance requirements.

Good fit:

Fund platforms and investor bases familiar with Irish governance and custody.

Jersey/Guernsey

Pros:

Tax‑neutral, high‑quality governance, respected regulators, and strong professional services.

Often used as fund or holding layers for UK assets; listed debt options help with UK interest WHT planning.

Watch‑outs:

Economic Substance Rules apply; you need real decision‑making on island.

Treaty network is limited; UK property taxes bite at the UK level regardless.

Good fit:

UK‑focused portfolios, listed or institutional capital, and governance‑heavy structures.

Singapore

Pros:

Excellent treaties across Asia, straightforward tax administration, and business‑friendly regulation.

Real operational hub potential with high‑quality talent.

Watch‑outs:

Withholding can still apply on outbound interest; treaty access requires substance and purpose.

Less helpful for EU portfolios; shines for Asia‑Pacific investments.

Good fit:

Asian property strategies, regional headquarters with genuine operations, family offices investing in APAC.

UAE (ADGM/DIFC and mainland)

Pros:

Extensive treaty network, 0% tax regimes available for qualifying free‑zone activities (subject to evolving rules), and strong finance ecosystem.

Attractive for investors resident in the Middle East and North Africa.

Watch‑outs:

Corporate tax at 9% now exists broadly; qualifying free‑zone relief depends on activity and compliance.

Substance and real presence are essential; regulations have been evolving rapidly.

Good fit:

Middle East capital pools, structures with real management in the region, Asia/Africa gateways.

Cayman Islands and BVI

Pros:

Tax neutral, world‑class fund ecosystems (Cayman especially), quick formations.

Popular for pooling capital and fund GP/LP structures.

Watch‑outs:

Very limited treaty benefits; not suitable for reducing WHT from operating countries.

Substance rules and UBO disclosure apply; still fully within CRS/FATCA.

Good fit:

Fund layers and co‑investment platforms, not treaty‑driven holding companies.

Financing the Structure: Debt vs. Equity

Financing can create as much value as the asset itself—if you respect the guardrails.

Debt pushdown basics:

Interest may be deductible at the PropCo level, reducing taxable income. But most countries limit net interest deductions to a percentage of EBITDA (commonly 30%).

Bank debt is easier to defend than shareholder debt. If you use shareholder loans, benchmark the rate and maintain formal agreements.

Withholding on interest:

Many countries levy 0–20% WHT on outbound interest. Treaties or domestic exemptions (e.g., quoted debt, private placement exemptions) may reduce this to 0–10%.

Paying interest to low‑tax jurisdictions triggers extra scrutiny and anti‑avoidance rules.

Preferred equity and hybrids:

Preferred equity can achieve similar economics to debt without tripping interest limitations.

Hybrid mismatch rules can deny deductions if the instrument is treated inconsistently across jurisdictions; get opinions before issuing clever instruments.

Transfer pricing:

Prepare a functional analysis: who controls risk, who provides management, who has the people?

Keep contemporaneous documentation: benchmarking studies, loan terms, board approvals, and annual updates.

Thin capitalization and anti‑avoidance:

Some countries have specific ratios or targeted rules for related‑party loans. Assume you need to prove business purpose beyond tax outcomes.

Special Paths: REITs, Funds, and Family Offices

REITs

What they offer:

Corporate‑level tax exemption in exchange for distributing most taxable income and meeting asset and ownership tests.

For non‑resident investors, distributions may be subject to WHT, and gains on sale of REIT shares may still be taxed.

Where they fit:

If you can achieve scale, a REIT can be an efficient wrapper for stabilized income assets. Domestic REIT status (US/UK/Singapore) matters more than offshore holding layers.

Private funds

Common approach:

Use a tax‑transparent partnership (e.g., Cayman/Delaware LP, Luxembourg SCSp) to pool capital.

Portfolio investments flow through HoldCos and SPVs suited to each market.

Regulatory overlay:

AIFMD in the EU, SEC rules in the US, and local marketing regimes dictate how you raise and manage capital. Build compliance into the plan early.

Family offices and succession

Trusts/foundations:

Useful for succession, asset protection, and governance. They don’t erase taxes but can bring order to multi‑generational ownership.

Watch forced heirship and “look‑through” rules in the family’s home country.

Practical tip:

Keep operating SPVs separate from family vehicles. The family structure owns the HoldCo, not the properties directly.

Worked Examples

Example 1: Pan‑EU logistics portfolio

Facts:

Investors: EU pension fund (80%), Middle Eastern family office (20%).

Assets: Warehouses in Germany and Poland; target leverage 55%.

Structure:

Luxembourg HoldCo (Sàrl) with two PropCos: a German GmbH and a Polish SP. Each asset sits in its own PropCo.

Senior bank debt at PropCo level; shareholder loan from HoldCo to Polish PropCo to balance leverage.

Why this works:

Luxembourg provides treaty access to reduce dividend and interest WHT into HoldCo, subject to PPT and substance.

Substance: two independent Luxembourg resident directors, quarterly board meetings in Luxembourg, local administrator, and a small office lease. The bank and shareholder loans are benchmarked with TP studies.

Numbers (illustrative):

Net rent EUR 12m across portfolio; interest EUR 5m; EBITDA interest cap allows full deduction.

Withholding: German WHT on interest can often be reduced or eliminated with proper documentation; Polish WHT reduced under treaty if PPT met.

Annual compliance per entity: EUR 8k–30k depending on audits. Formation and transaction costs ~1–2% of deal size at the outset.

Pitfalls avoided:

No hybrid instruments across borders. Clear purpose for the shareholder loan. Lux HoldCo has real decision‑makers and governance.

Example 2: US multifamily inbound investment

Facts:

Investors: Non‑US individuals via a Cayman fund.

Asset: Stabilized multifamily property in Texas, hold 7–10 years.

Structure:

Cayman LP fund with a Cayman GP. A US blocker C‑Corp (or a domestically controlled REIT for certain strategies) sits between the fund and the US PropCo LLC.

The blocker protects non‑US investors from US trade/business filing obligations and manages FIRPTA exposure.

Why this works:

FIRPTA taxes non‑US investors on US real estate gains. A US blocker pays US corporate tax but can simplify investor reporting and manage WHT on distributions.

If structured as a domestically controlled REIT, non‑US investors may avoid FIRPTA on the sale of REIT shares, subject to stringent requirements.

Numbers (illustrative):

Corporate blocker pays US federal corporate tax; dividends to Cayman fund can be planned around distributions and financing.

Exit strategy considers FIRPTA withholding (typically 15% of gross proceeds if selling property) vs. share sale of a domestically controlled REIT.

Pitfalls avoided:

No direct foreign ownership of US property by individuals, which would trigger complex filings and FIRPTA issues.

Keep blocker capitalized and run as a real corporate entity with proper governance.

Example 3: UK build‑to‑rent development

Facts:

Investor: Single family office, non‑UK resident.

Asset: Development to rental, exit via share sale if market supports it.

Structure:

Jersey HoldCo with UK PropCo. Senior bank loan at PropCo; shareholder loan from HoldCo.

Consider using listed notes or private placement exemptions to manage UK interest WHT on cross‑border interest.

Why this works:

Jersey offers tax neutrality and strong governance. UK taxes apply to UK property income and gains regardless; the offshore layer helps with investor pooling and financing.

Interest limitation rules modeled early; VAT registered for development inputs.

Pitfalls avoided:

Proper UK management for development activities; ensure Jersey board decisions occur offshore to preserve residence.

Plan for UK non‑resident gains rules on indirect disposals; monitor share‑deal transfer tax exposure under UK anti‑avoidance.

Compliance and Governance That Actually Protects You

Paper compliance fails under stress. Build routines that mirror real management.

Board and decision‑making

Appoint independent, resident directors who understand real estate transactions.

Hold meetings in the company’s jurisdiction. Circulate packs with financials, covenant checks, and forecasts. Keep detailed minutes.

Economic substance

Maintain a real footprint: office services, local phone/address, and dedicated administrative support.

Budget for local director fees, travel, and office costs; regulators can and do ask for evidence.

Documentation culture

File intercompany agreements and TP studies before funds move.

Renew benchmarks on refinancing or rate changes.

Maintain UBO registers and keep KYC current with banks and administrators.

Reporting calendar

Corporate tax returns, VAT/GST, WHT filings, CRS/FATCA, audited financial statements, and economic substance returns.

Use a centralized compliance tracker across all entities to avoid late filing penalties.

AML/KYC hygiene

Source of funds/source of wealth checks are stricter for real estate. Prepare investor documentation early.

Avoid nominee arrangements that obscure ownership; they slow banking and raise red flags.

Costs, Timelines, and Practicalities

Budgeting upfront avoids surprises and helps you choose where complexity is worth it.

Formation and initial setup (indicative ranges)

Basic SPV in a mainstream jurisdiction: USD 3k–10k.

Premium HoldCo with substance: USD 15k–40k (formation, legal docs, initial director fees).

Fund vehicles (Cayman/Delaware LP, Lux RAIF): USD 50k–200k+ depending on complexity and regulatory scope.

Annual maintenance

SPV compliance (company secretarial, accounting, tax returns): USD 5k–15k per entity.

Audit (where required): USD 10k–50k per entity depending on size.

Directors and office services: USD 10k–60k per entity based on substance profile.

Banking and transaction costs

Bank onboarding: 6–12 weeks; fees vary; be ready for intensive KYC.

Transaction legal and tax due diligence: 0.5–1.5% of deal value for significant acquisitions.

Timelines

Structure design and advisor alignment: 2–4 weeks.

Entity formation: 1–4 weeks.

Bank accounts: variable; plan parallel tracks to avoid closing delays.

Total to closing: 8–16 weeks is common if you start documentation early.

Common Mistakes and How to Avoid Them

Chasing zero tax at the HoldCo while ignoring source taxes

Fix: Start modeling at the property level. The source country sets the baseline.

No substance plan

Fix: Budget for real governance and local decision‑making. Appoint credible directors and keep minutes.

Over‑engineering debt

Fix: Simpler beats clever. Use bank debt where possible; keep shareholder loans within clear TP ranges.

Ignoring exit taxes and transfer rules

Fix: Model asset vs. share sale outcomes, including real estate transfer taxes on “property‑rich” share deals.

Mixing development and investment in one SPV

Fix: Separate entities for development (higher risk, VAT/GST heavy) and stabilized investment (lenders prefer clean SPVs).

Poor documentation

Fix: Execute intercompany agreements before cash moves. Update TP annually. Keep compliance files organized.

Assuming treaty benefits without qualification

Fix: Test PPT/LOB conditions. Demonstrate business purpose beyond tax outcomes. Don’t rely on residency certificates alone.

Waiting on banking

Fix: Start KYC as soon as you pick jurisdictions. Provide clean UBO charts and source‑of‑funds evidence.

Forgetting VAT/GST

Fix: Register and reclaim where eligible. Development and property management are VAT‑active in many countries.

Exit Planning From Day One

Your structure should make money during operations and lose as little as possible at the finish line.

Asset sale vs. share sale

Asset sale: often triggers property transfer taxes and resets depreciation; the buyer likes it for clean title.

Share sale: can reduce transfer taxes in some markets but may trigger “share deal RETT” rules or catch capital gains on property‑rich entities. Buyers may discount for latent tax risks.

Step‑up and holding periods

Some jurisdictions reward longer holding periods or allow asset step‑ups at corporate reorganizations. Understand these before the first acquisition.

REIT exits

Consider rolling stabilized assets into a REIT for an IPO or trade sale. The preparation takes time—start governance, reporting, and portfolio standardization early.

Lockbox and earn‑out mechanics

For development or value‑add, design earn‑outs and price adjustments that don’t inadvertently create extra tax layers or VAT surprises.

Treaty and PPT at exit

Share disposals via HoldCo only work if treaty access is defensible. Keep your substance and documentation strong up to the day of signing.

Quick Checklists

Pre‑acquisition checklist

Investment memo with tax model for operations and exit.

Jurisdiction shortlist with treaty map and PPT analysis.

Entity chart with roles, substance plan, and board composition.

Financing plan: bank vs. shareholder debt, interest cap modeling, WHT analysis.

VAT/GST and property transfer tax plan.

Compliance calendar draft (returns, audits, CRS/FATCA, ESR).

First 90 days after acquisition

Finalize intercompany agreements and TP documentation.

Complete tax registrations (corporate, VAT, WHT).

Set up accounting, reporting packs, and governance cadence.

Confirm banking signatories, treasury procedures, and covenant monitoring.

File UBO/beneficial ownership registers where required.

Annual cycle

Board meetings at least quarterly with real packs and decisions.

Audit and file on time; update ESR/CRS/FATCA reports.

Renew TP benchmarks; test interest limitations with actuals.

Review WHT reclaims and treaty paperwork; track deadlines.

Re‑forecast for refinancing and update exit models.

Frequently Asked Questions

Do I need a tax ruling?

Sometimes. Rulings can provide certainty on participation exemptions, financing, or specific fact patterns. Many jurisdictions now grant fewer rulings and require robust substance and disclosure. If a ruling is pursued, factor in 8–16 weeks and legal fees.

Can I use a zero‑tax company to avoid tax?

No. Real estate is taxed where it sits. Zero‑tax holding companies can still be useful for pooling investors or managing governance, but they don’t erase source taxes and can struggle to access treaties.

How much substance is “enough”?

Enough to reflect the scale and complexity of your activities. At minimum: resident directors who actually decide, regular board meetings in‑jurisdiction, proper records, and some level of local expenditure. For financing entities, expect higher scrutiny.

What if my investors are US taxpayers?

You’ll need to navigate PFIC/CFC concerns and sometimes prefer transparent entities. US‑connected investors often want blocker structures or REITs for US assets. Coordinate early with US tax counsel.

Should I consolidate development and stabilized assets?

Usually not. Separate risk profiles help with financing, VAT/GST compliance, and clean exits.

How do regulators view intercompany loans now?

They expect commercial terms, clear business purpose, and control of risk by the lender entity. “Back‑to‑back” loans without substance are easy targets.

A Practical Blueprint You Can Start With

When I’m asked to “just make it work,” this is the lean, defensible baseline I propose for a cross‑border buy‑and‑hold strategy:

One HoldCo in a treaty‑rich, substance‑friendly jurisdiction with two independent resident directors, a small office service, and quarterly governance.

One PropCo per asset jurisdiction (or per asset for larger deals), each with local management, tax registrations, and bank accounts.

Bank debt at PropCo; shareholder loan only if it passes TP and doesn’t break interest limits. Document everything before funding.

Simple cash waterfall: rent to expenses to debt service to distributions. Avoid exotic hybrids unless there’s a compelling non‑tax rationale.

Exit modeled both ways with a clear preference and pre‑agreed documentation pathway.

Compliance calendar implemented on day one; auditors and tax agents appointed at formation.

It’s not flashy, but it clears banks’ credit committees, keeps tax authorities comfortable, and protects your IRR.

Data Points Worth Remembering

Withholding taxes commonly range:

Dividends: 5–30% standard, often reduced by treaties to 0–15%.

Interest: 0–20% standard, with possible exemptions for listed/qualified debt.

Always verify specific rates and conditions; a one‑point change can swing millions over a hold period.

Interest limitation rules:

Many jurisdictions cap net interest deductions at 30% of EBITDA, with carryforwards and group escape hatches. Don’t assume full deductibility.

Reporting regimes:

CRS/FATCA reporting by banks and administrators is routine; build it into your data collection. Expect beneficial ownership transparency.

Pillar Two:

If you’re above €750m consolidated revenue, run a Pillar Two analysis early. Real estate may qualify for carve‑outs but requires careful modeling.

Bringing It All Together

A good offshore real estate structure does three things: it respects source‑country taxes, it makes treaty access and financing clean, and it stands up to daylight. Focus on purpose and documentation first, tax second. Start simple, only add layers you can justify, and maintain real governance. If you can explain your diagram to a skeptical banker in five minutes and to a tax auditor in fifty—supported by minutes, models, and agreements—you’re on the right track.