Cross-border tax counsel
International tax and corporate structuring for groups that move.
PI26 Advisory is a boutique counsel firm focused on cross-border M&A, holding-company design, transfer pricing, and the day-to-day compliance work that keeps mid-cap groups out of the headlines.
Partner-led
Every engagement
Independent
No audit affiliation
EU / UK / OECD
Working perimeter
Est. MMXVI
Geneva & London
Practice areas
What we work on
International tax
Cross-border tax planning and structuring for mid-cap groups operating in the EU, the UK and the wider OECD perimeter.
Cross-border M&A
Tax-led counsel on cross-border acquisitions, divestments, joint ventures and post-deal integration for mid-cap targets.
Holding-company structuring
Design and reorganisation of multi-tier holding structures across the EU, the UK, Switzerland and Asia-Pacific.
Transfer pricing
Benchmarking, documentation and controversy support for intra-group transactions across the OECD perimeter.
Wealth & succession
Tax-driven structuring of family-owned business holdings, succession planning, and the move of operating control between generations.
Tax compliance & controversy
Ongoing compliance discipline and defence in tax-authority enquiries for cross-border mid-cap groups.
Insights
From the desk
Pillar Two
Pillar Two implementation across EU member states — where the variance bites
Two years into the EU minimum-tax directive, the local variances in QDMTT design are the real story. A field note for in-scope groups.
Alistair Thorpe · 22 Apr 2026
Transfer pricing
BEPS Action 13 country-by-country reporting — the 2026 refresh
New tax-authority guidance on CbCR data eligibility is narrowing the safe-harbour numerator. Documentation discipline matters again.
Helena Ribeiro · 11 Apr 2026
Holding companies
Dutch substance requirements after the 2024 review — what survived
The Dutch substance discussion has moved past the 2024 consultation paper. Three durable changes for holding-company structures.
Marco Conti · 28 Mar 2026
People
A small bench, by design
Alistair Thorpe
Managing Partner
Helena Ribeiro
Partner — Transfer pricing
Marco Conti
Senior Counsel — Holding structures
Yuki Tanaka
Partner — Cross-border M&A
Considering a cross-border move?
We take a small number of engagements that match the bench. Tell us what you are weighing and we will say plainly whether we are the right firm.