Memoranda

Tax Memorandums

Memorandums are the core output of Meridian — structured tax advisory documents that follow Big 4 professional standards. Each memorandum includes facts, analysis, conclusion, and recommendations, with mandatory citations to authoritative sources.

Memorandum Types

PE Analysis

Permanent establishment risk assessment — evaluates whether business activities in a jurisdiction create a taxable presence under the applicable treaty and domestic law.

Withholding Tax (WHT)

Analysis of withholding tax obligations on cross-border payments: dividends, interest, royalties, and management/technical service fees.

IP Structuring

Intellectual property structuring advice — covers transfer pricing, substance requirements, and beneficial ownership for IP holding arrangements.

Holding Company

Holding company analysis — participation exemptions, capital gains treatment, and structural considerations for international holding structures.

Pillar 2 / BEPS

GloBE (Global Anti-Base Erosion) analysis including top-up tax calculations, safe harbour assessments, and transitional provisions.

Creating a Memorandum

  1. Navigate to Memorandums → New Memorandum
  2. Enter a title describing the advisory matter
  3. Select the memorandum type (PE, WHT, IP, Holding, or Pillar 2)
  4. Add the relevant jurisdictions using country codes (e.g., NL, DE, US)
  5. Set the tax year and advisory date — these control which version of the law is applied
  6. Provide the client facts and background
  7. Click Create Draft — the AI will generate a structured memorandum based on your inputs

Editing and Review

Memorandums follow a three-stage workflow:

Draft

Initial creation and AI generation. Edit freely.

In Review

Submitted for review. Content is locked for quality check.

Final

Approved and ready for client delivery.

Each memorandum section — background, objective, analysis, technical guidance, etc. — can be edited individually. Use the Generate with AI button to regenerate specific sections based on your updated facts.

Citations and Sources

Every conclusion in a Meridian memorandum is traced to authoritative sources. Citations include treaty article references, case law holdings with dates, OECD commentary paragraphs, and domestic legislation sections.

Citations are generated automatically by the AI based on the legislation database and any documents you have uploaded. You can review and edit citations in the memorandum editor.

Best practice

Always verify AI-generated citations against the original source material before finalizing a memorandum for client delivery.