The Architecture of Tax Planning.

Strategic tax advisory and legal counsel rooted in international case law and the rigor of OECD Transfer Pricing standards.

Core Disciplines

Guiding Principle

Substance over form.

Economic substance prevails over legal form.

Dainis Vodolagins

Practice lead

Dainis Vodolagins

Founder & Director

  • International tax lawyer in Riga; lectures international tax law at university level.
  • Formerly in Big Four international tax practice; now independent.
  • Matters across Latvia, Estonia, Cyprus and Malta, in Latvian, English, Russian and German.

Every matter is read by the same person from the first call to the last filing.

Signature Jurisprudence

Foundational Case Law & Global Rulings

  1. 2004US

    GlaxoSmithKline Holdings v. Commissioner

    The largest transfer-pricing settlement in US history — USD 3.4 bn on intangibles valuation.

  2. 2006CJEU

    Cadbury Schweppes v Commissioners of Inland Revenue

    Defining the threshold for 'wholly artificial arrangements' and freedom of establishment in EU tax law.

  3. 2012IN

    Vodafone International Holdings BV v. Union of India

    The landmark Supreme Court ruling on indirect transfers and the limits of extraterritorial capital gains.

  4. 2016EU

    Apple State Aid (T-778/16, C-465/20 P)

    The contest over selective tax advantages and the evolution of the Arm's Length Principle as an EU standard.

  5. 2017AU

    Chevron Australia Holdings Pty Ltd v Commissioner

    Benchmarking intra-group loan interest against the arm's length standard.

Digital materials

Working files, not templates.

The regional layer — rates, decision trees and the audit practice of VID, EMTA, VMI and the Cyprus Tax Department across Latvia, Estonia, Lithuania, Cyprus, Malta and the UAE — in files your team can edit and drop into a board pack.

01 /

Cross-Border Tax Decision Trees 2026

PowerPoint · 19 slides · PDF included

Seven decision trees for the structuring questions that produce most cross-border work. Four questions under one gateway; exits are priced — an oxblood box is a stop with the cost stated, the black box is the supportable outcome.

  • Holding company location; IP ownership and DEMPE
  • Residence and permanent establishment
  • Intercompany financing
  • Distributor model: full-risk, LRD, agent
  • Centralised hub vs. local entities
  • Treaty and Directive access
€39 Buy

Refunds: 14 days, no questions asked. Refunded in full; access to the files and the licence end with it.

Buy the Decision Trees first and the €39 is credited against the Playbook with code TREES39.

Sold by All-Around Legal digital — SIA "DDA Projects", reg. No. 40203546787, Elizabetes iela 19-7, Riga, LV-1010. It is a digital-products company, not a law firm or a licensed tax adviser. The advisory practice SIA "DV Tax Consulting", to which this website belongs, is a separate legal entity, is not a distributor of these materials and is not a party to the sale. General information for professionals, current to 1 September 2026; it is not tax, legal, accounting or investment advice, and no adviser-client relationship arises from purchase.

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