There is a question I am sometimes asked at the end of a first meeting: how did you come to do this work? The honest answer is that I did not come to it. I was pushed into it by a client who had a problem I did not know how to solve — and the experience of solving it, slowly and imperfectly, changed everything that came after.
I had been working in the Russian market. Local clients, local structures, local problems. The work was straightforward in the way that all work feels straightforward when you have not yet encountered what it can become. Then a client arrived with a situation that was none of those things. The problem was international, the structure was genuinely complex, and the tools I had been using were inadequate. I had two choices: tell the client I could not help, or learn what I did not know.
I chose the second. Not from particular virtue — I was simply more afraid of admitting ignorance than of acquiring knowledge. What followed was a long and uncomfortable education in the mechanics of international corporate structures, offshore jurisdictions, banking relationships, and the gap between how structures look on paper and how they function when they meet the real world. The client was patient. The learning curve was steep. The outcome was, eventually, satisfactory.
That experience set the direction for everything that followed.
For a period, the work centred on what everyone in that era called offshore structures. The logic was simple: clients needed privacy, asset protection, and tax efficiency; offshore jurisdictions offered all three; the job was to connect the requirement to the solution.
I became competent at this. More than competent. And then, gradually, I began to notice something that took time to articulate clearly: the structures that worked best were not the most opaque ones. They were the ones that could withstand scrutiny — structures that had a coherent logic, a defensible purpose, and documentation that matched what was actually happening inside them.
This observation seems obvious now. It was not obvious then. The prevailing assumption in the offshore world was that privacy meant concealment, and that concealment was the product. What I came to understand — through cases that went wrong, through banking relationships that collapsed, through clients who found that their carefully constructed structures fell apart precisely when they needed them most — was that the most durable structures were the ones that had nothing to hide.
Not because concealment was always wrong. But because a structure built around concealment is fragile in a specific way: it depends on the concealment holding. The moment the concealment fails — when a bank asks a question the structure cannot answer, when a regulator examines what the documentation actually says, when a counterparty requires transparency as a condition of doing business — the entire construction is at risk.
A structure built around coherence and legibility is fragile too, in different ways. But when it is examined, it survives the examination. That is a significant difference.
Over time, as the regulatory environment around offshore structures tightened, the work shifted. Clients who had previously been content with British Virgin Islands companies and Cayman structures began asking for something different: structures that would not attract immediate suspicion, that could be explained to a bank or an investor without producing a visible flinch.
The move toward what I call "respectable" jurisdictions — Cyprus, the Netherlands, Luxembourg, the United Kingdom, Ireland — produced a discovery that I had not anticipated. These jurisdictions, properly used, could offer structures that were not merely more acceptable to banks and investors, but genuinely more private and more secure than the offshore alternatives they were replacing.
This sounds counterintuitive. The assumption is that secrecy requires secrecy jurisdictions — that the less reputable the address, the better the protection. What I learned, working through the mechanics of how these structures actually function, is that this assumption is backwards. A structure built in a jurisdiction with a functioning legal system, proper corporate governance requirements, and genuine treaty networks offers a quality of protection that a letterbox company in a low-tax jurisdiction cannot match. The protection comes not from opacity but from the integrity of the framework.
A British Virgin Islands company exists in a regulatory environment that is increasingly scrutinised and increasingly unable to offer the benefits it once did. A properly constructed holding structure in the Netherlands, with genuine economic substance and coherent governance, sits within a framework that has been tested, respected, and defended in courts for generations. When something goes wrong — and in international business, something always eventually goes wrong — the question is not which structure offered the most secrecy. It is which structure held.
I have worked with clients across a wide range of industries, jurisdictions, and levels of complexity. The problems change. The regulatory environment changes. The jurisdictions that are fashionable change. The tools available change.
What does not change is the quality of the thinking that produces good outcomes.
Early in my career, I treated client briefs as specifications. The client described what they wanted; my job was to find a structure that delivered it. This produced technically correct solutions that were sometimes genuinely wrong — wrong not in a legal sense, but in the deeper sense that they did not serve the client's actual situation as well as a different approach would have.
What changed, over time, was a willingness to challenge the specification before attempting to fulfil it. To ask not just "how do we achieve what the client is asking for?" but "is what the client is asking for actually what they need?" These are different questions. And the difference matters enormously, because clients — including sophisticated, experienced ones — frequently arrive with a solution already formed in their minds, when what they actually need is a diagnosis.
The most valuable thing I can offer a client is not a structure. It is an honest assessment of the situation they are actually in. That assessment is sometimes uncomfortable. The client who arrives convinced that a particular structure will solve their problem does not always welcome the observation that the structure they have in mind will create three new problems while solving one. But the discomfort of an honest assessment, delivered at the outset, is significantly smaller than the cost of discovering, after the structure has been built and the banking relationship has been opened and the investment has been made, that something fundamental was wrong.
I have learned to say uncomfortable things early. Not from pleasure in saying them — they are genuinely uncomfortable — but from experience of the alternative.
There is a habit of mind in this work that I value above most others: taking apparently absurd ideas seriously.
Clients and colleagues regularly propose things that seem, on first encounter, either technically impossible or commercially unrealistic. The instinct, particularly early in a career, is to dismiss them quickly — to identify the obvious objection and move on. I have learned to resist that instinct.
The reason is not that absurd ideas are usually right. They are usually not. The reason is that the process of working through why an idea is wrong almost always produces something useful. The objection that dismantles the original idea often points toward a different approach that would not have been found any other way. The constraint that makes the proposed structure impossible frequently reveals, when examined carefully, a flexibility that the constraint was obscuring.
The right answer, in my experience, rarely arrives fully formed. It arrives through a process of genuine engagement with the question — including the questions that initially appear to have obvious answers. The most elegant structures I have built, the ones that genuinely solved the problem they were designed to solve and continued to work when examined by banks and investors and regulators, emerged from conversations that began with ideas that seemed unpromising.
This is not a method. It is an attitude. The attitude is: everything is worth understanding before it is dismissed.
I am sometimes described as a tax adviser, sometimes as a corporate structuring specialist, sometimes as a banking consultant. All of these descriptions are accurate. None of them is complete.
What I actually do is sit at the intersection of law, structure, and the practical reality of international business — and try to build things that work in that space. Not on paper. Not in theory. In the actual world where banks conduct compliance reviews, where investors conduct due diligence, where regulators examine substance, and where clients need their structures to function under conditions that were not always anticipated when the structures were designed.
The problems are not getting simpler. The regulatory environment is not getting more lenient. The questions that banks and investors ask are not getting less searching. In that environment, the only thing I can offer with confidence is this: thirty years of getting things wrong before getting them right, and a considered view, earned through that experience, of what actually matters and what does not.
What matters is the structure being built for the world as it is — not as it was when the last set of rules applied, and not as the client wishes it were. What matters is the analysis being honest enough to say that before it is built, rather than after.
Everything else follows from that.
Vladimir Shuvalov is a legal and tax adviser with thirty years of experience in international corporate structuring, banking acceptability, and cryptocurrency architecture.
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