IP Box: Preferential Tax on Intellectual Property and the European Meta
How IP box regimes work: modified nexus under BEPS Action 5, effective rate map (Ireland KDB, Cyprus, Netherlands, Luxembourg), and regulatory passporting in the EEA.
Companies & funds
Companies, funds, SPVs, holdings and investment vehicles in key jurisdictions.
Read from purpose to vehicle: business ownership, a joint investment, succession and asset protection call for different structures. Hubs explain the architecture; jurisdiction and vehicle pages show where substance, reporting, control and banking constraints arise.
A vehicle name alone does not decide the outcome: similar labels in two countries can carry different rights, control and disclosure. Separate formation from ongoing governance, tax treatment from company law, and asset protection from the ability to deal with the assets. For a meaningful comparison, identify the founder, beneficiaries and controllers, where decisions are made, which assets enter the structure, and the events that may require a distribution, sale or succession.
Use the topic as a reading route. Open an overview hub, then two or three closely relevant articles and compare them against one consistent set of criteria. On every page, check the modification date, scope and links to primary sources because rules, pricing and administrative practice change. If the research supports a decision about a specific person, company or asset, turn the shortlisted options into questions and confirm the current conditions before acting.
The catalogue is generated from the current Published corpus. A page appears here only when its public snapshot matches the active index revision; archived and quarantined material is excluded. This is a research map, not individual legal, tax or investment advice.
Articles
Inheritance in the UAE: Sharia defaults, DIFC Wills and ADJD
What happens to UAE assets on the owner’s death: frozen accounts, Sharia and Decree-Law 41/2022 defaults, DIFC Wills (AED 10,000) vs ADJD (AED 950), probate, guardianship of minors and how the UAE fits a multi-jurisdiction estate plan.
Singapore company: incorporation, tax, EP and banking substance
What a Singapore company really is in public law: an ACRA-registered legal person with resident director, secretary, tax perimeter and banking substance.
SCSp: The Luxembourg Partnership for Funds
How the Luxembourg SCSp works: tax transparency, GP/LP mechanics and the LPA, use with RAIF and AIFM, comparison with the SCS and the Delaware LP, launch timeline.
Cross-Border Prenups: Notarial Contracts, Radmacher and Choice of Law
How a marriage contract works for an international couple: notarial contracts in Germany, France and Switzerland, English prenups after Radmacher, US UPAA rules, Russian Art. 44 caveat, choice of law under EU Regulation 2016/1103 and recognition abroad.
Company audit in China
Annual statutory audit for companies in mainland China, incl. WFOE and Free Trade Zone entities: scope, deadlines and filing for family offices.
Money Service Operator (MSO) License in Hong Kong
Money Service Operator (MSO) license in Hong Kong from C&ED for money remittance and currency exchange. Requirements, substance, and suitability for payment businesses.
Property Division in a Cross-Border Divorce: Regimes, Assets, Protection
How property is divided in a cross-border divorce: five matrimonial regimes, real estate by situs, business valuation and buy-outs, account disclosure, crypto forensics, attacks on trusts and pension splitting.
Cook Islands trust + Nevis LLC: a procedural fortress without secrecy
How a Cook Islands trust over a Nevis LLC works: charging order, beyond-reasonable-doubt, a three-year sunset and phantom income as procedural barriers. Why it is asset protection, not a tax scheme, and where the contempt line runs.
SVF License in Hong Kong: Stored Value, Wallets, and the Banking Boundary
HKMA SVF license under Cap. 584: what stored value facilities can do, where the banking boundary lies and when this regime matters.
Ireland: Section 110 + ICAV — the US-friendly tax-neutral conduit
How an Irish Section 110 SPV zeroes its tax base through profit-participating notes, why the ICAV can check-the-box and kill PFIC, and where ATAD and anti-hybrid bite.
Investor Onboarding in a Fund: From Qualification and KYC to LPA and Capital Call
Complete guide to entering a fund: accredited investor and qualified purchaser qualification, KYC and source of wealth, tax forms W-8BEN/W-9, subscription agreement, LPA, and capital call mechanics.
Solicitor — English Lawyer for Private Capital
Solicitor in the English tradition: reserved activities, legal professional privilege, client account, undertakings, trust practice, and recognition of status outside England.
Feeder fund: access to a fund through an intermediate structure
Master-feeder and feeder platforms: how the intermediate structure works, two tiers of fees, tax transparency, and risks.
Gibraltar — LP&GP fund
Gibraltar LP/GP private fund setup: structure, regulation and how UHNW families manage assets for beneficiaries in a low-cost EU-adjacent jurisdiction.
Monaco company
Setting up a company in Monaco, a sovereign microstate for international business structuring and wealth protection. Tax framework and fit for UHNWIs.
Special Administrative Regions (SAR): Redomiciliation of Holdings to Russia
How special administrative regions on Russky and Oktyabrsky islands work, international holding company (IHC) status, and redomiciliation of holdings from abroad.
Beneficial Ownership and Nominee Structures
Beneficial owner and nominee structures: the 25% threshold, FATF Recommendation 24 update (2024), obligation to disclose nominators, registry reform, and BVI changes from 2025.
Seychelles IBC: Territorial Tax, Substance and Banking
Seychelles International Business Company under IBC Act 2016: territorial tax after 2019 reform, economic substance requirements, banking limitations and EU list status.
BVI Company: BC Act, Economic Substance and Beneficial Ownership Register 2025
BVI Business Company under BC Act 2004: zero tax, Economic Substance Act 2018, beneficial ownership register reform from January 2025 and legitimate interest access from April 2026.
Panama Private Foundation (Law 25): Structure, Taxes, Succession
Panama Fundación de Interés Privado under Law 25 of 1995: founder, council, protector, beneficiaries in private regulations, $10,000 contribution, territorial tax, FATF and EU status.
Holding Company in Switzerland: Rates, Participation Relief, Pillar Two
Swiss holding company: cantonal rates 12–15%, participation relief, TRAF 2020 reform, global minimum tax Pillar Two (QDMTT/IIR), and substance requirements.
Liechtenstein Foundation (Stiftung): Family Foundation and 12.5% Tax
Liechtenstein Stiftung under PGR (Art. 552): family foundation without members, privacy through deposit, beneficiary types, 12.5% tax and PVS status, Pillar Two impact.
Purpose Trust: Cayman STAR and the Enforcer Role
Cayman STAR trust (1997 law): purpose trust without human beneficiaries, enforcer role, perpetual duration, orphan ownership of PTC, and BVI VISTA analogue.
Jersey and Guernsey Trusts: Reserved Powers and Firewall
Channel Islands trusts: Trusts (Jersey) Law 1984 and Guernsey 2007, settlor's reserved powers, firewall protection from forced heirship and creditors, tax neutrality.
Delaware LP for Funds: GP/LP, Carry, and Blocker Structures
Fund structured as Delaware limited partnership: GP and LP roles, pass-through taxation and Schedule K-1, carried interest and §1061 rule, blocker corporations for foreign and tax-exempt investors.
Luxembourg Funds: UCITS, SIF and RAIF
Funds in Luxembourg: retail UCITS and alternative SIF/RAIF — structures, subscription tax (taxe d'abonnement), AIFM and the EU passport, CSSF supervision.
Holding Ladder and Dividend Flows
How dividends climb the holding ladder: withholding tax, Parent-Subsidiary and Interest & Royalties Directives, beneficial ownership, PPT, and CJEU Danish cases.
Cayman Fund: Exempted Company, ELP and SPC under CIMA Supervision
Cayman investment funds: Mutual Funds Act and Private Funds Act, exempted company, ELP and SPC structures, tax neutrality, economic substance and EU/FATF status.
UK LLP for International Partnerships
Limited Liability Partnership in the UK: limited liability, tax transparency, salaried member rules, and application for international partnerships and funds.
Malta Holding: 6/7 Refund System and Effective 5% Rate
How Malta's full imputation system and 6/7 tax refund work, participation exemption for holdings, substance requirements, and the impact of Pillar Two.
Why a South Dakota dynasty trust does not save the American living abroad
A South Dakota dynasty trust for an American who becomes UK-resident: how the Settlements Code, ToAA and s.86/s.87 TCGA collapse deferral, and how residence-based IHT from 6 April 2025 pulls trust assets into relevant property — and what the trust still delivers.
Wyoming DAO LLC and DUNA: Legal Wrappers for Decentralized Organizations
Wyoming pioneered DAO legal status: DAO LLC since 2021 and Decentralized Unincorporated Nonprofit Association (DUNA) since July 2024—structure, taxes, and limitations.
Malta: Cell Companies and the MFSA Licensing Hub
Cell company is a Maltese corporate structure where multiple segregated cells operate under one license and capital. PCC and ICC models for insurance, funds, and payments.
Holding in Ireland: 12.5%, participation exemption and Pillar Two
Ireland as a holding jurisdiction: 12.5% on trading profits, participation exemption for foreign dividends from 2025 and for capital gains, 75 tax treaties in force and Pillar Two rules.
New Zealand Foreign Trust: Zero Tax on Foreign Income and IRD Registration
How a New Zealand foreign trust works: resident trustee, foreign exemption trust, IRD registration, annual return, financial statements, CRS/FATCA and tax red flags.
Estonian Company (OÜ): 0% on Retained Earnings and 22/78 on Distribution
Estonian OÜ and deferred taxation: 0% on retained earnings, 22/78 on dividend distribution, abolition of 14% rate and security tax, 24% VAT, and e-Residency integration.
Private Trust Company (PTC): Family Trust Company and Control
What is a PTC, why families create their own trust company, how shares are held by purpose trust, and exemption conditions in Singapore, Cayman Islands, and BVI.
Minor Heirs and Guardianship
What happens to inheritance of minor children: guardianship, property management until adulthood, appointing a guardian in a will, and the role of trusts for children.
Incapacity Planning: Power of Attorney and Living Will
What happens to assets and decisions if the owner is alive but incapacitated: power of attorney, living will, and medical directives. A plan must cover this scenario.
Foreign Real Estate Succession
Why foreign real estate is inherited under the law of the country where it is located (lex rei sitae), how this creates forced heirship and double taxation issues.
Succession to Foreign Accounts and Brokerage Portfolios
How foreign bank accounts and brokerage portfolios are inherited: account freezing, bank requirements for heirs, US-situs for American stocks, and the role of designated beneficiaries.
Family Charter
What is a family charter: a set of rules for ownership, management, and succession of family capital. Why it's needed, what it includes, and how it relates to legal documents.
Business Succession: Transferring a Company to Heirs
How to transfer a family business to the next generation without collapse: separating ownership and management, shareholder agreements, foundation or holding at the top.
Trusts and CFC Rules: When a Foreign Trust Is a Controlled Foreign Company
When a foreign trust or foundation becomes a CFC for a Russian tax resident: controlling person, notifications, undistributed profits, PIT and distributions.
Gift Tax and Lifetime Gifting
Lifetime transfer of assets as an estate planning tool: gift tax, the UK 7-year rule, clawback into forced heirship calculations, and where gifting beats inheritance.
Inheritance Tax: Country-by-Country Map
Inheritance tax map for 2026: US and UK estate tax at 40%, French, German, Spanish and Italian rates, zero-tax regimes and situs traps for non-residents.
Trustee and Protector
A role map for trustee and protector: fiduciary duties, protector powers, reserved powers, conflicts of control, and when a trust risks being treated as a sham.