Residence, ownership and succession are often considered separately, although their tax questions are usually connected. We advise international families and their offices on all three, wherever the family lives and its assets are held, in Europe, the Americas, Asia, Africa, Australia or the Gulf. When a family is spread across several countries, we read each country's rules together.
A move from one country to another changes which country can tax income, gains and, in some places, an estate. We advise before the move on when residence starts and ends in each country concerned, and how a treaty settles a claim by two countries to the same person. We advise on moves in any direction between Europe, the Americas, Asia, Africa, Australia and the Gulf.
More on this areaHow assets are held decides where tax falls and when. We compare holding them directly or through a family investment company, trust or foundation, and set out the tax cost of each option in the countries involved. We tailor these structures so that no one involved is at a material tax disadvantage in the country where they are tax resident, whether they are a shareholder, founder, settlor, beneficiary, guardian or protector.
More on this areaA foundation set up in one country also has to work under the tax rules where its founder and beneficiaries live. We advise on how assets go into the foundation and how its founding documents are written, so it does not create a tax problem at home.
More on this areaPassing wealth on can bring income tax, capital gains tax, transfer duties or inheritance tax, and when heirs live in different countries each may face a different bill. We work with the family's lawyers on wills, shareholders' agreements and insurance so the tax result matches what the family intends. If a structure set up by a relative or business partner is disputed, we explain its tax treatment to the court, mediator or tribunal.
More on this areaWe know how family offices run, invest and hold property, and we advise them with that in mind. For a family office we advise on its structure, its investments and the distributions it makes to family members, whose own tax positions can differ widely from one country to the next.
More on this areaWhen a marriage ends across borders, dividing shares, property or a business can be a taxable disposal in one country and tax free in another. We advise on the position in each country involved and help a spouse's counsel explain a family structure to the court.
More on this areaUnder CRS and FATCA, information about accounts and structures is reported to tax authorities and exchanged between countries. We explain what will be reported about the family and its structures, and complete the forms that UAE portals and the US Internal Revenue Service require. When you open a company or a bank account, we check that the tax residence you declare is right, so the right information is shared.
More on this areaWe work alongside your lawyer, bank and trustees, and advise only on tax.
Founder
International tax adviser for more than forty years, in Sydney, London, New York and Dubai. Has advised on the tax laws of more than 75 countries. PhD in commercial law, Queen Mary University of London, on BRICS and international tax law, published by Kluwer. Chartered accountant (ICAEW, CA ANZ) and Chartered Tax Adviser.
Senior International Tax Adviser
Chartered accountant and US CPA with more than twenty years in tax. Former head of tax in industry and senior adviser at a Big Four firm. Has advised on tax across more than 30 countries. Focus on cross-border structuring, disputes and negotiations with tax authorities.
Tax Consultant
Fifteen years in tax and compliance across the UAE and South Africa. Former tax compliance officer with knowledge of the SARS and UAE FTA regimes. Builds the firm's African tax capability.
Write to us about a planned move, or a change in how the family holds its assets.
