The idea of a family holding is as old as the dynasties themselves. European and American families have held their capital through a single top company for decades, so that it outlives the founder and does not fragment on division. Sweden's Wallenbergs run half of the country's industry through the listed holding Investor AB; Italy's Agnellis hold Ferrari and Stellantis through Exor; the Porsche and Piëch families control Volkswagen through Porsche SE. The construction is the same everywhere: as long as a holding sits at the top, assets and control stay unified from one generation to the next.
Concept
Passing down a dozen scattered assets—real estate, shareholdings, accounts—is painful: each obeys its own rules in its own country. A holding company gathers them into one structure, and what then passes on death is shares in the holding rather than a menagerie of separate assets.
Why This Matters for Inheritance
A holding gives a single point of control and management, simplifies division (shares are split, not individual objects), and lets the rules be set in the charter and a shareholders' agreement, while the assets themselves—the business, the real estate—keep working while the heirs formalise their stakes.
Link with a Foundation or Trust
The top of the structure is often a private foundation, a trust, or a Russian personal and inheritance foundation that owns the holding. The shares then stay indivisible, and income reaches the heirs by rules the founder set once. This is the classic foundation → holding → assets architecture: at the top of the Wallenberg structure sit charitable foundations, and it is they that control Investor AB. The general logic of such constructions is covered in holding structures.
Shareholders' Agreement
The key document is the agreement among the heir-co-owners: who manages, how shares may be sold, and what happens on the death, divorce or insolvency of one of them. A special case is the stake of minors, protected by the rules on guardianship of heirs. Without these arrangements a holding merely postpones the family conflict, deferring it to the moment when the co-owners become too many.
Holding StructuresPrivate FoundationsFamily OfficePersonal and Inheritance FoundationFamily CharterBusiness SuccessionCFC
How It Is Built in Practice
The typical construction is multi-level. At the top sits the founder's foundation or personal holding. Beneath it, sub-holdings by asset class: the operating business separately, real estate separately, the securities portfolio separately. And only beneath the sub-holdings—the specific companies and objects. An heir receives a share in the top holding and a board seat, while the keys to each warehouse and account stay with management. In the Agnelli family, the family company Giovanni Agnelli B.V. owns Exor, and Exor in turn owns Ferrari and Stellantis; a generational change in the family does not disturb the operating business for a single day.
Holding Jurisdiction
Where to register the top company is a question of tax, treaty network and reputation. The classic choice is a participation-exemption jurisdiction: a regime that exempts the holding from tax on dividends and gains from subsidiaries. In the Netherlands a BV holding applies the deelnemingsvrijstelling from a stake of 5%; comparable regimes are offered by Luxembourg through the SOPARFI and by Switzerland through participation relief. From 1 January 2026 Cyprus raised its corporate tax from 12.5% to 15% to comply with Pillar Two, but the Cyprus holding remains one of the cheapest in the EU.
The Holding and Russian Tax
For an owner who is a Russian tax resident, a foreign holding is almost always a CFC: its profit is subject to personal income tax even if no dividends were paid. Since 2025 the "fixed profit" regime is no longer flat—the tax depends on the number of CFCs and, on a progressive scale, reaches RUB 25 million a year instead of the former RUB 5 million. Against this background, a single holding over a dozen subsidiaries is cheaper to declare than a dozen scattered CFCs.
The second theme is ownership transparency. Beneficial-ownership registers and the automatic exchange of information (CRS) show the tax authorities who stands behind the holding. A nominee at the top therefore adds risk today; real protection comes from the right jurisdiction and heirs' rights formalised in advance.
When a Holding Is Justified
A holding is justified when there are several assets, they sit in different countries, and more than one heir will receive them. For a single flat or a single heir it merely adds the cost of maintenance, audit and reporting without a payoff. The top company is therefore designed as part of the wider system—together with a family office, a family charter and a business succession plan.
🧭 Check your case: Inheritance Navigator — which law governs, where forced heirship applies, and the taxes.
This material is for informational purposes and does not constitute individual legal advice.
Sources
Contact information
If you have questions or need a consultation, our experts will be glad to help.