Publications
Notes for principals and their advisers.
Written for readers who already hold structures, not for readers deciding whether to. Twenty-eight notes on structuring, banking, residency, tax, governance and succession across the jurisdictions the firm works in.
What a bank is actually reading in a corporate file
Account opening is not a document-collection exercise. The institution is testing whether the structure, the stated activity and the source of funds describe the same business, and most refusals follow from an inconsistency rather than an omission.
Holding company jurisdiction: the questions that settle it
Six questions decide where a holding company belongs, and none of them is the headline tax rate. Where the assets sit, where decisions are taken, which treaties are needed, what the banks will accept, what must be disclosed, and who inherits.
Moving a principal without moving the structure
A change of residence does not relocate the companies, the accounts or the assets, and the interval in which the two are misaligned is where most of the cost arises. What has to be sequenced, and in what order.
Preparing a structure before an exit, not after it
The window in which a founder can still restructure closes when terms are agreed, not when the transaction completes. What can be put in place beforehand, and what becomes materially harder once a buyer is identified.
Foundations and trusts compared, for families holding across borders
Both hold assets outside the personal estate; they differ in ownership, control, recognition and how a bank treats them. A practical comparison for families with beneficiaries in more than one jurisdiction.
Mainland, free zone and offshore: what the choice determines
The three Emirates pathways differ in permitted activity, presence requirements, disclosure and the view banks take of them. The differences that matter are rarely the ones set out in a comparison table.
Corporate tax in the UAE: what changed for holding companies
The introduction of corporate tax altered the calculation for holding structures more than for operating ones. Which holdings are affected, which exemptions require substance, and what has to be registered.
Source of wealth and source of funds: why banks treat them differently
One explains how the money was made over a lifetime; the other explains where this particular payment came from. Confusing them is the most common reason a file is returned for further information.
Substance, and the file that has to exist before it is asked for
Substance requirements are tested retrospectively. A structure documented as decisions are taken is defensible; one documented in response to a query is not, whatever the underlying position.
Setting up a single-family office: the operating decisions before the legal ones
Most family office structures are designed before anyone has settled who decides what, who reports to whom and what the family actually wants administered. The operating questions that should precede the incorporation.
When an SPV is the right vehicle, and when it adds only cost
A special purpose vehicle isolates a risk, a co-investor or an asset. Where none of those is present, it adds a set of filings and a bank relationship in exchange for nothing.
Relocating from Western Europe to the Gulf: the order of decisions
Residency, exit position, corporate structure and banking each depend on the others, and the sequence in which they are taken determines the cost. A practical order of operations for principals leaving a European tax residence.
Double tax treaties, and the substance a treaty claim now requires
A treaty is not self-executing. What a jurisdiction expects to see before it accepts that a company is resident where it says it is, and why a registered address is no longer part of that answer.
Why corporate accounts are closed after opening
An account lost six months after opening usually reflects a mismatch between what the file described and what the account then did. What triggers a review, and what keeps a relationship intact.
Beneficial ownership registers: what is public and what is not
Disclosure regimes differ sharply between the jurisdictions private clients use most. What is filed, who may see it, and what the practical consequences are for a family that values discretion.
Establishing in Morocco as a base for African operations
For groups operating across the continent, the question is rarely which single African jurisdiction, but where the holding and coordination sit. What Morocco offers, and what it does not.
Exit taxation on relocation: what to settle before departure
Several European jurisdictions tax unrealised gains on the departure of a resident. What is triggered, what is deferrable, and why the structure should be settled before the residence changes rather than after.
Succession documentation for a cross-border family
A will valid in one jurisdiction may be ineffective in another, and a structure can succeed at holding assets while failing at passing them on. What has to exist alongside the corporate documents.
Migrating a company between jurisdictions
Continuation, redomiciliation and transfer of seat are not the same thing, and only some jurisdictions permit any of them. What survives a migration, and what is treated as a disposal.
United Kingdom holding companies: disclosure as the trade-off
A British entity is understood by counterparties everywhere, which is exactly why it is placed in public view. What is on the register, and when the recognition is worth the transparency.
Tax residency certificates, and when they actually help
A certificate evidences residence for treaty purposes; it does not create it, and it will not resolve a competing claim on its own. What it is used for, and what is required to obtain one.
Digital asset holdings in a family structure: custody and reporting
Holding digital assets through an entity raises questions of custody, valuation, audit and exchange onboarding that most corporate structures were not designed to answer.
Iberia for Latin American families
Spain and Portugal are used as the European anchor for families whose operating interests remain in Latin America. What that structure typically looks like, and where it commonly fails.
Transfer pricing for family groups with intercompany flows
Management charges, loans and licence fees between related entities are now examined in jurisdictions that previously ignored them. What documentation a private group is expected to hold.
Governance appointments: directors, trustees and where liability sits
A nominee is not a shield, and an appointment taken lightly transfers real exposure. What each role carries, and the circumstances in which the firm will and will not accept one.
Multi-currency banking for cross-border groups
Groups collecting in one currency, paying in another and reporting in a third accumulate cost and reconciliation risk quietly. How account structures are usually arranged, and what banks will support.
Consolidated reporting for a family holding several structures
Once a family holds through more than three entities, the question stops being what each one owns and becomes what the family owns in total. What consolidated reporting requires.
Joint ventures between families: the documents that prevent the dispute
Two families co-investing through a shared vehicle need the exit agreed while relations are good. The provisions that matter, and the ones most often left out.
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Notes are general in application and do not constitute legal, tax or regulatory advice. They describe practice observed across institutions and jurisdictions and should not be relied upon in relation to any particular set of circumstances.