Milestone is a boutique international tax practice established in Mayfair, London.

Open

Preserving and passing wealth to future generations

The Client

High net worth individual

The Problem

A South American national, with significant worldwide commercial interests, wanted to create a European holding structure that would preserve and pass on wealth to descendants.

The Solution

  • We inserted an EU holding company that would be held by a trust established under the laws of a non-black jurisdiction. The EU holding company would, in turn, hold the operating assets in Latin America. The client, his children and members of his extended family would be beneficiaries of the trust.
  • By utilizing a bi-lateral investment treaty agreed between the holding and operating jurisdictions, the family would also be given a certain degree of protection for foreign direct investments.
  • We ensured that profits could be repatriated within (and out of) the structure with minimum tax leakage to enhance internal rates of return.
  • Capital gains were deferred to reduce tax leakage.
  • Finally we ‘future-proofed’ the structure as far as practicable; and made certain our proposals would be commercially and practically workable for our client on a day to day basis.