Core Structuring

Cross-Border Holdings

We advise on the structuring of assets and investments held across multiple jurisdictions — designing international holding pathways that are tax-efficient, legally robust and succession-ready across borders.

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Cross-Border Scope

  • International holding pathway design
  • Jurisdiction-by-jurisdiction asset analysis
  • Succession & forced heirship planning
  • Cross-border tax treaty positioning
  • Banking & regulatory compliance across borders
  • Currency & political risk structuring
What We Deliver

Our Advisory Services

International Holding Pathways

We map the optimal route from personal ownership to each cross-border asset — identifying the holding entity, jurisdiction, treaty position and documentation required for each pathway.

Forced Heirship Mitigation

Many jurisdictions impose forced heirship rules that override a personal will — particularly relevant for UAE nationals and EU residents. We design structures that comply with local law while preserving your intended succession.

Situs Planning

The situs (legal location) of an asset determines which jurisdiction's succession and tax rules apply. We advise on asset situs planning — repositioning assets into holding structures that change the situs and reduce succession risk.

Treaty Network Positioning

Tax treaty networks vary significantly by jurisdiction pair. We map your holding structure against applicable treaties to minimise withholding taxes on dividends, interest and capital gains across all jurisdictions in your structure.

Banking Across Borders

Advisory on banking structure for cross-border asset holders — which banks, which jurisdictions, which account structures — ensuring you can access, move and manage your capital across every jurisdiction you operate in.

Political & Currency Risk Structuring

Diversification of asset custody, holding entity jurisdiction and banking relationships across multiple stable jurisdictions — reducing concentration of political and currency risk without sacrificing return.

Our Approach

Built for Real Outcomes

Holding assets across multiple countries exposes you to multiple sets of rules — succession, tax, regulatory and banking — that interact with each other in ways that are rarely intuitive.

Our cross-border advisory begins with a complete asset and jurisdiction map. Only then do we design — ensuring every holding pathway is aligned with your objectives, compliant in every jurisdiction and resilient to regulatory change.

Common Cross-Border Scenarios

  • UAE resident with UK, European and US assets
  • GCC family with multiple international investment portfolios
  • Founder with business interests across multiple jurisdictions
  • UHNWI relocating between jurisdictions with significant asset base
  • Family with next-generation members in different countries

Jurisdictions We Navigate

  • UAE — zero income tax, ADGM/DIFC holding capability
  • UK — CGT, IHT, SDLT considerations for non-residents
  • EU — forced heirship, wealth tax, CFC rules
  • US — FBAR, FATCA, estate tax for US-connected persons
  • GCC — VAT, withholding and cross-border treaty considerations

What We Deliver

  • Cross-border asset & jurisdiction map
  • Holding pathway design for each asset class
  • Forced heirship exposure analysis
  • Treaty positioning memo
  • Banking structure recommendation
4+
Continents covered in active cross-border advisory
UAE
Central hub for most cross-border holding structures
Treaty
Bilateral treaty analysis for every jurisdiction pair
100%
Succession-ready — every pathway designed for transfer
Process

How We Work

01

Asset & Jurisdiction Mapping

We map every asset, its current ownership, its jurisdiction and the risks associated with that position.

02

Pathway Design

We design the holding pathway for each asset — entity, jurisdiction, treaty position, documentation.

03

Succession Overlay

We overlay the succession implications of each pathway and identify forced heirship exposures.

04

Banking & Compliance

We advise on banking structure and cross-border compliance requirements for the full asset map.

Common Questions

Frequently Asked

Every jurisdiction has its own tax rules, succession laws, forced heirship provisions and regulatory requirements. When you hold assets in multiple countries, you are subject to multiple overlapping legal systems — and the interaction between them is rarely simple. Our role is to map this complexity and design structures that navigate it cleanly.
Forced heirship rules require that a fixed portion of your estate pass to certain family members (typically children), regardless of your will. These rules apply in France, Spain, UAE (for UAE nationals), and many other jurisdictions. If you own assets in a forced heirship jurisdiction, those assets may be distributed differently from your wishes unless properly structured.
The UK's non-resident Capital Gains Tax, ATED (Annual Tax on Enveloped Dwellings) and SDLT rules make offshore ownership of UK residential property increasingly unattractive. We advise on UK property holding structures in light of current legislation — and on restructuring existing arrangements where they are no longer efficient.

Ready to Structure Your Cross-Border Holdings?

Our team maps your international asset base and designs holding pathways that are tax-efficient, succession-ready and compliant in every jurisdiction.

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