Legal advice, tax structuring and transaction support services on offshore structures and offshore companies

Offshore companies are the hidden champions of cost-efficient structuring, powerful asset protection, and smart succession planning. However, since the offshore jurisdictions provide a much lower level of regulations and protection, the offshore investor faces a high risk of a total loss of his offshore assets.

An offshore structure allows a tax-efficient structuring of wealth and profit streams, which couldn’t be achieved onshore without tax evasion and by hiding money from the government. However, offshore participants are typically neither aware of nor responsible for the tax requirements in the investor’s own jurisdiction, nor do they worry about his tax compliance at home.

Typically, offshore structures operate in a business environment that includes not only the ultimate beneficial owner but also the offshore service provider, certain nominees, shadow directors, and other participants. The appeal to improper and sometimes even criminal behavior is high, while the investor has to take care of his protection mechanism on his own.

Seven professional services for all the flag theory elements

PUGNATORIUS Ltd. is the Bangkok-based specialist provider of transactional legal and tax advice on foreign investments in Thailand’s manufacturing and service industries as well as property developments and acquisitions. The law firm has a long tradition and particular know-how to assist and advice offshore investors and cross-border transactions involving offshore jurisdictions on pragmatic offshore solutions.

The PUGNATORIUS group does neither provide legal advice on offshore jurisdictions nor the formation of offshore companies on its own. Instead, it supports offshore investments and investors mostly with respect to these seven professional services:

#1. Offshore legal and tax advice: Location-independent advice on the advantages and disadvantages of holistic offshore structures and the flag theory of nomad capitalists and permanent travelers. Advice on reporting and tax requirements in the home country and the efficient implementation of the offshore jurisdiction in the value-added chain, the asset protection scheme and the succession process.

#2. Offshore company: Communication with the offshore service provider – if required on a no-name basis – and support and logistic support in the formation of the offshore company. Independent recommendation for a specific offshore jurisdiction, on the selection of the offshore service provider and the individual parameters of the offshore company. Negotiations with regarding contractual obligations, reporting, compliance, and other matters. Design and negotiation of a “declaration of trust” and nominee agreement.

#3. Offshore bank account: Support and assistance in the selection and set-up of an offshore bank account or an onshore bank account for an offshore company. Providing of compliance-related documentation and confirmations as required by banks and offshore providers. Assistance in the customer due diligence and KYC/AML procedures as required under the offshore’s legislation and regulatory framework.

#4. Offshore investment and disinvestment: Transaction support and legal assistance to transfer assets and wealth from onshore to offshore and vice versa. Securely, confidential, and in compliance with the onshore and offshore legislation.

#5. Offshore nominee services: Acting in selected cases as a nominee, shadow director, trustee or middleman in offshore structures and offshore companies.

#6. Offshore FinTech: Assistance and support on the combination and integration of cryptocurrency wealth, digital asset businesses and other FinTech areas into the offshore world. Advice on the structuring and accomplishment of an offshore ICO

#7. Offshore search and rescue services: Assistance in the search for runaway nominees, lost offshore assets and enforcement of rights and claims vis-a-vis offshore participants. Sourcing and providing of offshore intel and company files from offshore companies worldwide. Rapid reaction task force on offshore leaks.

PUGNATORIUS can efficiently and precisely set out a strategy to manage your offshore exposure by taking into account the bigger picture. The firm maintains long-term, handpicked relationships with global affiliates that share our policy and standards. Offshore advice and support for high net worth clients and corporations.


Andorra, Liechtenstein, Guernsey, Monaco, Mauritius, Labuan, Liberia, Seychelles, Brunei, Hong Kong, Maldives, Cook Islands, Nauru, Niue, Marshall Islands, Vanuatu, Anguilla, Antigua and Barbuda, Bahamas, Barbados, Belize, Bermuda, British Virgin Islands, Cayman Islands, Grenada, Montserrat, Panama, St Vincent and the Grenadines, St Kitts and Nevis, Turks and Caicos, US Virgin Islands | #PanamaPapers, #Offshoreleaks, Panama Papers.