Below are the highlights of the webinar:
GCC clients can underestimate tax exposure when setting up structures, overlooking key triggers such as UK tax residency, claims from jurisdictions like France based on habitual residence, and the presence of US citizens within the family, which can complicate distributions and generate unexpected liabilities.
Asset location can play a major role in tax implications, as placing UK, US, or French assets into structures can create significant liabilities, especially since civil law jurisdictions like France do not recognize trusts, and UK property transfers can trigger various taxes.
UK residential property structures have evolved, with older company-held setups now penalized under current laws; today, co-ownership among family members or Wills can be a more tax-efficient approach.
Succession planning for property depends on how ownership is structured, with joint tenancy enabling automatic transfer to surviving owners and bypassing probate. While tenancy in common requires a will and a formal probate process, each option has different implications in common law versus civil law jurisdictions.
US citizenship among beneficiaries adds complexity but does not prevent structuring, as long as the US-connected individual is not the settlor. Solutions like grantor trusts or adjusted foundations can be tailored to comply with US tax rules.
Clients seeking control over structures must tread carefully to avoid tax residency issues, particularly in the UAE and KSA, where sitting on boards of offshore companies managed locally can unintentionally trigger local corporate tax exposure.
Private trust companies and foundations can help balance control with compliance, by allowing families to influence governance without directly holding board positions that might create tax obligations under substance rules.
The overarching message is clear: take tax advice early and review regularly, as even well-established structures may contain hidden risks, and evolving global and regional tax frameworks demand continuous reassessment.
Watch the full webinar for deeper insights into the tax considerations and structuring strategies that can help protect and transfer your wealth across generations.
