Overview
The challenge
The family office had accumulated a portfolio of direct investments, fund interests and real estate holdings across more than a dozen jurisdictions over three decades, structured under a patchwork of historic holding vehicles that no longer reflected the family's current residency, tax position or succession plans. A recent change in the principal family members' country of residence had created both an opportunity and a pressing need to simplify the structure before the next generation began to take on greater responsibility for the family's affairs.
The restructuring needed to address exposure to changing tax regimes in several jurisdictions simultaneously, without triggering unnecessary tax charges on the transfer of existing holdings, and while preserving flexibility for further changes in family circumstances.
Our approach
Our Private Wealth team conducted a full review of the family's existing holding structures, working alongside the family office's investment team to understand the practical constraints on restructuring each category of asset. We designed a simplified holding structure centred on a small number of jurisdictions selected for their tax treaty networks and regulatory stability, and sequenced the restructuring carefully to manage tax exposure on the transfer of legacy holdings.
Throughout the process, we worked closely with the family's local tax advisers in each relevant jurisdiction, and with our own Tax team, to ensure the new structure was coherent across all the jurisdictions in which the family held assets.
The outcome
The restructuring reduced the number of holding entities in the family's structure by more than half, while preserving the family's existing investment strategy and improving the clarity of reporting for the family office's investment team. The simplified structure has since formed the platform for the family's succession plan, with governance arrangements now in place to support the transition of responsibility to the next generation.
