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§00Structure · Glossary

Multi-Tier Holding Structure

A corporate stack with multiple jurisdictions interposed between ultimate owners and operating entities.

In full

Multi-tier holding structures interpose two or more jurisdictions between the ultimate beneficial owners and the operating company — typically for treaty optimization, IP location, or limited liability layering. Examples include UAE → Netherlands → U.S., or BVI → Singapore → U.S.

This definition is general information about how the term is used in U.S. cross-border tax. It is not advice, and how it applies depends on your own facts and on the treaty, if any, in force with your country.