A crypto entrepreneur with substantial self-built capital needed a corporate structure, banking, source-of-funds documentation, and a tax position that worked. We designed the structure and coordinated legal, tax, audit, and banking partners to deliver it.
Trading activity sat in a personal exchange account. No company, no corporate bank account, no source-of-funds package a European bank could review. Part of the capital came from ICO token compensation with no written employment contract.
Run trading through a corporate vehicle with workable tax. Support dividend distributions with low personal tax leakage. Address Portuguese CFC exposure. Open European corporate banking. Document source of funds for compliance teams.
A Cyprus company with operating substance, corporate banking at a European institution, a documented $2.5M capital base, a dividend workflow in place, and ~2.5% effective corporate tax under the Cyprus IP Box.
The client had already built substantial crypto capital — but the legal, tax, and banking framework was not in place. Trading activity sat in a personal exchange account. There was no corporate vehicle, no corporate bank account, and no source-of-funds package that a European financial institution could review.
Part of the capital came from token compensation as CTO of an ICO startup — with no written employment contract. The rest came from high-frequency algorithmic trading across 208 million transactions. The beneficial owner held a nationality that draws closer review in banking onboarding.
Five problems had to be solved together. They were interdependent. A solution for one that broke another would not work.
We led the structure design and coordinated delivery across four linked workstreams. Local legal, tax, and audit partners in Cyprus supported jurisdiction-specific execution.
The company needed substance, control, and a defensible place of management. Cyprus was chosen for its EU base, 12.5% corporate tax rate, treaty network with Portugal, and providers experienced with crypto clients.
Cyprus-resident director appointed. Board meetings and written resolutions handled in Cyprus. Management actions recorded there. The structure had to pass both tax authority and banking review for place of effective management.
The structure was built around the Cyprus tax framework and the client's Portuguese NHR position. The trading algorithm was assessed for Cyprus IP Box treatment, bringing the effective corporate tax rate to approximately 2.5%.
We built a repeatable dividend process: board approvals, management accounts, shareholder instructions, and Cyprus filings. The dividend flow was structured to work cleanly against Portuguese NHR treatment of foreign-source income.
This was the heavy part of the matter. The capital came from two sources, each requiring different documentation approaches.
Standard audit tools could not handle the scale of the trading dataset. We developed a custom Python-based review method to load exchange data, draw statistically valid samples, and match against records. The methodology was used under formal engagement by a licensed Cypriot audit firm.
CTO compensation track: We reconstructed the path of each token tranche from receipt to disposal — blockchain evidence, exchange records, public technical evidence, project materials, invoices, and a plain-language note tying the narrative together.
Trading history track: The custom review method processed the full 208M transaction dataset. Samples were drawn and matched against exchange records. The result was an audit-confirmed trading profit of $2,026,876 for the reviewed period, with no discrepancies in tested samples.
A structure that exists on paper but cannot bank is not usable. We supported corporate banking by shaping the application package around the bank's review logic: UBO documents, substance evidence, source-of-funds support, business model description, and audit history — presented as one coherent file.
We then built the first dividend cycle end to end, establishing the process for ongoing use.
This was not an investigation. It was multi-disciplinary implementation work. The outcome depended on coordinating legal, tax, audit, and banking workstreams so that each component supported the others.
A source-of-funds file that audit could not sign off on would not support banking. A corporate structure without substance would not support the tax position. A dividend process without proper documentation would not be repeatable. Each piece had to fit.
The result is a structure the client can use going forward — not a one-time fix, but an operating framework for ongoing trading, distributions, and compliance.
The structure was built on the Cyprus IP Box regime, Cyprus dividend rules, Portuguese NHR treatment of foreign-source income, and cross-border anti-avoidance rules tied to substance and control. Local legal, tax, and audit partners in Cyprus executed jurisdiction-specific components under our coordination.
Initial conversations are confidential and without obligation.
clearjudgment@proton.me