High Net Worth Services

Why personal structuring has become harder

The combination of the OECD common reporting standard (CRS) implementation in China, the 2019 IIT reform, the renewed exchange-control scrutiny on outbound flows, and the 2024 Pillar Two implementation has changed the calculus for Chinese families and entrepreneurs considering offshore structures. Many legacy arrangements — passive BVI holdcos, single-jurisdiction trusts, undifferentiated family investment vehicles — no longer deliver the tax efficiency or the operational simplicity they once did. We work with clients and their private bankers, family offices and trust counsel to redesign the structure with current rules in mind.

Our services

International holding and succession structures

We design the offshore holding and succession stack — the choice of jurisdiction (Hong Kong, Singapore, the Netherlands, the United Kingdom and others), the form (trust, foundation, holding company, family investment vehicle), and the operating governance — to support the family's commercial interests and inter-generational objectives while remaining defensible under the beneficial-owner regime, the STA's CFC rules and the destination jurisdiction's substance requirements.

ODI compliance and outbound reporting

For structures involving Chinese-resident settlors or beneficiaries, we manage the SAFE and NDRC registration of the outbound investment, the annual reporting, and the tax-clearance process when capital is repatriated. We also advise on the structuring that avoids triggering exchange-control complications at the moment of investment or return.

Cross-border tax planning and exit

We advise on IIT planning for senior executives and founders, including the structuring of deferred compensation, equity vesting and dividend flows. For entrepreneurs considering partial or full monetisation — through trade sale, IPO or secondary — we model the personal tax outcome and coordinate with the transaction counsel on the step-plan.

Tax opinion and family governance

Where the family requires a written opinion on the tax consequences of a particular structure or transfer, we prepare it in the form the in-charge bureau and the relevant overseas authorities expect. Where the family wishes to formalise its governance we work alongside the family-office counsel on constitution documents, family charters and the related reporting frameworks.