Understanding Multi-Jurisdictional Holding Structures for Multi-Market Investors

Executive Summary for Multi-Market Investors

Multi-jurisdictional holding structures represent one of the most important planning tools available to private equity firms, family offices, and corporates investing across multiple markets. At their core, these arrangements involve establishing one or more holding companies in strategically selected jurisdictions—typically Luxembourg, the Netherlands, Singapore, or Delaware—to own operating subsidiaries and portfolio assets scattered across different countries. Rather than investing directly from a home entity into every target market, sophisticated investors interpose holding vehicles that centralize ownership, streamline governance, and optimize tax outcomes.

The key benefits of these structures are substantial. Treaty access allows investors to secure reduced withholding taxes on dividends flowing from countries like Germany or Italy. Risk ring-fencing isolates liabilities within separate legal entities, protecting the broader group from localized problems. Share deals become far easier to execute at exit when a single holding company owns the target, rather than requiring multiple local share transfers. And governance simplifies dramatically when board meetings, reporting, and decision-making flow through a unified platform.

The core trade-off, however, deserves honest acknowledgment. Structural efficiency comes at the cost of complexity. Maintaining entities across multiple jurisdictions means ongoing reporting requirements, substance obligations, director appointments, and administrative burdens that accumulate over time. This article focuses on post-2020 practice, incorporating the realities of BEPS implementation, EU Anti-Tax Avoidance Directives (ATAD), economic substance rules, and recent reforms in popular holding locations. For investors seeking clarity on how these structures work in today’s regulatory environment, the following sections provide a comprehensive roadmap.

Introduction: Why Multi-Jurisdictional Holding Structures Matter in 2024–2025

Consider a pan-European buy-out fund closing its latest acquisition in early 2024. The target portfolio includes a manufacturing company in France, a logistics operator in Poland, and a technology business in Spain. Rather than having the fund invest directly into each country, the sponsor establishes a Luxembourg holding platform—a Sàrl at the center—that acquires each target through local intermediate holding companies. This single structural decision unlocks treaty benefits, simplifies eventual exits, and creates a coherent governance framework across three distinct legal systems.

This example illustrates why global investors rarely invest directly from their home entity into every target country. The friction of dealing with multiple tax authorities, varying local laws, and inconsistent regulatory frameworks makes direct investment impractical at scale. Instead, interposing holding companies creates a centralized layer for ownership and financing, allowing investors to manage cross-border complexity from a single platform.

The primary users of these structures include:

• Private equity and infrastructure funds deploying capital across multiple markets

• Sovereign wealth funds with diversified global portfolios

• Multinational corporates expanding into new regions

• Large family offices with multi-market investment strategies

Current drivers are reshaping how these structures are designed. Cross-border deal flow has accelerated post-pandemic. The EU and OECD have implemented significant tax reforms targeting aggressive planning. Treaty-friendly hubs like Luxembourg, the Netherlands, Singapore, and the UAE continue to evolve their offerings. And substance requirements in traditional offshore centres have tightened considerably since 2019.

The rest of this article moves from foundational concepts through concrete structuring options, regulatory and tax considerations, and practical implementation steps for investors navigating this landscape through 2025 and beyond.

Core Concepts: What Is a Multi-Jurisdictional Holding Structure?

Before diving into design considerations, it helps to establish clear definitions of the building blocks.

What is a holding company?

A holding company is a legal entity whose primary purpose is to own shares or interests in other entities—subsidiaries, SPVs, and funds—rather than conducting day-to-day trading operations. The holding company itself typically has limited actual operations; its value lies in what it owns and how ownership is structured.

What makes a structure “multi-jurisdictional”?

A multi-jurisdictional structure involves at minimum three distinct layers:

• Investor jurisdiction: Where the ultimate investor resides (e.g., United States, United Kingdom, Germany)

• Holding jurisdiction: Where the holding company is established (e.g., Luxembourg, Netherlands, Singapore)

• Asset/operating jurisdictions: Where the underlying businesses or assets are located (e.g., France, India, Brazil)

The typical ownership stack

Most structures follow a recognizable pattern:

1. Investor vehicle (fund or corporate) at the top

2. Global or regional holding company in a treaty-friendly jurisdiction

3. Local intermediate holding companies where needed

4. Operating companies and asset SPVs at the bottom

Types of multi-jurisdictional platforms

Structure Type	Description	Common Use Case
Single regional hub	One EU holding company owns multiple EU targets	Pan-European private equity
Multi-hub model	Separate holding companies for each region (e.g., Luxembourg for Europe, Singapore for Asia, Delaware for US)	Global corporates and funds
Asset-class-specific holdings	Dedicated entities for real estate, intellectual property, or financing	Tax optimization for specific assets

Relationship to fund structures

Multi-jurisdictional holding platforms can be combined with master-feeder or parallel fund arrangements, but they serve different purposes. The holding layer sits below the fund level, focusing on portfolio ownership rather than investor pooling. This article concentrates on the holding structure rather than fund-level design.

Key Design Considerations for Multi-Jurisdictional Holding Platforms

Structuring a holding platform requires balancing tax, legal, regulatory, financing, and operational factors. No single consideration dominates; the optimal structure emerges from weighing trade-offs across all dimensions.

Tax Treaty Network and Participation Regimes

Double tax treaties reduce withholding taxes on cross-border payments. A Luxembourg holding company, for example, can access treaties with Germany, Italy, and dozens of other countries to secure reduced rates on dividends flowing upstream. Similarly, Singapore’s treaty network covers India, China, and Indonesia—critical for Asian portfolios.

Participation exemption rules provide further benefits. Luxembourg exempts dividends and capital gains from taxation if the holding company owns at least 10% (or €6 million) of the subsidiary and meets a 12-month holding period for share disposals. The Netherlands offers comparable exemptions. These regimes mean that profits can flow through the holding layer with minimal tax leakage.

Substance and Anti-Abuse Rules

Post-BEPS, economic substance requirements have become non-negotiable. Tax authorities expect holding companies to demonstrate:

• Local directors with genuine decision-making authority

• Office space and employees in the jurisdiction

• Board meetings held locally with documented agendas and minutes

• Real management and control functions performed on-site

EU ATAD rules and general anti-avoidance provisions (GAAR) in countries like France, Spain, and Italy target purely tax-driven structures. A holding company that exists only on paper, with no commercial rationale beyond tax savings, faces disallowance of treaty benefits and potential penalties.

Regulatory and Investment Restrictions

Foreign direct investment (FDI) screening regimes have expanded significantly. The EU framework introduced in 2019, Germany’s cross-sectoral screening, and India’s Press Note 3 for neighbouring countries all impose notification and approval requirements for foreign investors. Sectoral constraints—ownership caps in telecoms, defence, and media—influence where and how holding entities can be interposed.

Investors must map regulatory requirements early in the structuring process. A perfectly optimized tax structure becomes worthless if regulatory approvals are denied or delayed.

Financing and Treasury

Holding companies often serve as group financing centres. Debt push-down strategies—where acquisition debt sits at the holding level rather than the operating company—can generate interest deductions. However, thin capitalisation rules and interest limitation provisions (typically capping net interest deductions at 30% of EBITDA in many EU states) constrain aggressive leverage.

Cash pooling arrangements, dividend upstream planning, and intercompany loan structures all flow through the holding layer. Coordinating these across different jurisdictions with different tax laws requires careful documentation and arm’s-length pricing.

Legal System and Exit Routes

The choice between civil law and common law environments affects shareholder protections, dispute resolution, and exit flexibility:

Jurisdiction Type	Examples	Characteristics
Civil law	Luxembourg, Netherlands	Codified rules, predictable outcomes, strong creditor protections
Common law	Jersey, Delaware, UK	Flexible corporate law, established case law, familiar to Anglo-American investors

For exits, selling the holding vehicle itself (a share deal) is typically simpler than executing multiple local share transfers. A Luxembourg holding company can be sold to a buyer in a single transaction, regardless of how many operating companies sit beneath it.

Operational Footprint and Governance

Board composition matters for substance. Local directors should have real responsibilities, not merely sign documents prepared elsewhere. Governance calendars—regular board meetings, annual filings, statutory accounts—must be maintained in each jurisdiction. Information flows from operating companies to the holding level need clear protocols.

Common Holding Jurisdictions and Typical Use Cases

No single jurisdiction fits all investors. Selection depends on investor base, target markets, asset class, and operational preferences.

Luxembourg

Luxembourg has emerged as the leading EU hub for private equity, real estate, and infrastructure since the early 2000s. Popular vehicles include:

• Sàrl (private limited company): Flexible, widely used for holding purposes

• SOPARFI (Société de Participations Financières): Unregulated holding company regime

• SCS/SCSp (limited partnerships): Common for fund structures

• RAIF (Reserved Alternative Investment Fund): Regulated fund vehicle

Advantages include an extensive treaty network, robust participation exemption, developed AIFM ecosystem, and institutional familiarity. European investors and fund managers consistently cite Luxembourg as their preferred holding location.

The Netherlands

The Netherlands has historically served as a holding and conduit jurisdiction, with NV/BV companies, extensive treaties, and flexible corporate law. However, recent reforms—including anti-hybrid rules and increased scrutiny of letter-box companies—have raised substance requirements.

A Dutch BV today must demonstrate genuine Dutch management and decision-making. The days of purely nominal Dutch presence are over. For investors willing to meet these requirements, the Netherlands remains attractive, particularly for groups with operational reasons to be present.

United Kingdom

The UK’s post-2011 holding company regime offers:

• Exemption for substantial shareholdings (broadly, 10%+ held for 12+ months)

• No withholding tax on dividends

• Robust legal system with predictable outcomes

Brexit removed access to certain EU directives, but the UK remains popular for UK-centric groups and global structures where common law familiarity matters.

Singapore

Singapore serves as the primary Asian gateway, with strong treaties covering India, China, and Indonesia. Competitive tax rates, developed financial infrastructure, and a transparent legal system make it attractive for regional private equity funds and multinationals building South-East Asia portfolios.

The key differentiator is treaty access. Singapore’s treaty with India, for example, provides significantly better outcomes than direct investment from many Western jurisdictions.

Offshore and Tax-Neutral Centres

The Cayman Islands, British Virgin Islands, and Jersey/Guernsey remain common for fund and SPV purposes. However, post-2019 substance laws and OECD pressure have changed the landscape. Pure offshore structures without genuine substance face:

• Denial of treaty benefits in target countries

• CFC attribution in investor jurisdictions

• Increased audit risk and reputational concerns

These jurisdictions still have roles—particularly for parallel fund structures serving foreign investors from different tax regimes—but the era of substance-free offshore holding platforms has ended.

Emerging Alternatives

The UAE, particularly ADGM and DIFC, has expanded its role as a holding and fund hub since approximately 2018. New company and fund regimes, an expanding treaty network, and zero corporate tax have attracted attention. For investors targeting the Middle East and Africa, UAE platforms offer compelling alternatives to traditional European hubs.

Structuring Multi-Market Holdings: Practical Models

This section provides concrete examples of how structures are layered for different investor profiles and geographies.

Single EU Holding for Pan-European Assets

Example structure (2025):

A Luxembourg Sàrl sits at the top of the holding chain, owning stakes in:

• A French operating company (manufacturing)

• An Italian operating company (distribution)

• A Polish operating company (logistics)

Dividends and capital gains flow through Luxembourg, benefiting from EU participation exemptions and the Parent-Subsidiary Directive. The Sàrl provides:

• Centralized governance and reporting

• Single point of control for exits

• Treaty access for any non-EU co-investors

Multi-Hub Global Model

Example structure for a global sponsor:

Delaware/Cayman Fund
├── Luxembourg HoldCo (Europe)
│   ├── German OpCo
│   ├── French OpCo
│   └── Spanish OpCo
├── Singapore HoldCo (Asia-Pacific)
│   ├── Indian OpCo
│   ├── Indonesian OpCo
│   └── Vietnamese OpCo
└── UK HoldCo (Legacy UK assets)
    └── UK OpCo

Each hub aligns with local investors, regulatory frameworks, and deal pipelines. The Luxembourg entity serves European investors; Singapore serves Asian relationships; the UK handles legacy positions.

Vertical Chains vs. Flatter Structures

Approach	Structure	Best For
Vertical chain	Investor → Global HoldCo → Regional HoldCo → Local OpCo	Complex financing arrangements, multiple leverage levels
Flatter structure	Investor → Regional HoldCos → OpCos	Governance simplicity, faster decision-making

Vertical chains add flexibility for financing but increase administrative burdens. Flatter structures sacrifice some optimization for operational efficiencies.

Sector-Specific Holding Entities

Different asset classes may warrant dedicated holding vehicles:

• Intellectual property holding companies: Netherlands or UK, leveraging IP box regimes (Ireland’s 6.25% rate on qualifying income is particularly attractive)

• Real estate holding platforms: Luxembourg for European property portfolios, or REIT jurisdictions for tax-transparent structures

• Regulated financial holdings: EU banking groups require specific holding company structures under CRD IV/V

Integration with Fund Structures

Holding platforms typically sit below master-feeder or parallel fund arrangements. For example:

• Parallel EU fund (for European investors) and parallel non-EU fund (for US investors and others) both feed into a common Luxembourg holding chain

• The holding layer owns the same portfolio through the same structure, while the fund layer addresses investor-specific regulatory restrictions and tax considerations

This separation allows fund managers to serve a diverse investor base while maintaining unified portfolio management.

Tax and Regulatory Themes in Multi-Jurisdictional Holdings

OECD BEPS Actions, EU ATAD I/II, and transparency initiatives (CRS, FATCA, DAC6) have fundamentally reshaped holding structure design. Understanding these themes is essential for any multi-market investor.

Withholding Taxes and Treaty Access

Holding companies secure reduced withholding on cross-border dividends, interest, and royalties under specific treaties. The differences can be substantial:

Payment Type	Default Rate (No Treaty)	Treaty Rate (Typical)
Dividends	15-30%	0-5%
Interest	10-30%	0-10%
Royalties	10-30%	0-10%

For a portfolio generating significant distributions, the annual savings from treaty access can reach millions of dollars.

Anti-Treaty-Shopping and Principal Purpose Tests

The Multilateral Instrument (MLI) introduced the principal purpose test (PPT), now incorporated into most tax treaties. Tax authorities in Germany, India, and elsewhere assess whether a holding company has genuine commercial rationale beyond tax savings.

A holding company that exists solely to access treaty benefits, with no real substance or business purpose, will likely fail the PPT and lose treaty protection entirely.

Interest Limitation and Hybrid Rules

Typical EBITDA-based caps limit net interest deductions to 30% of EBITDA in many EU states. Anti-hybrid rules target mismatches where payments are deductible in one jurisdiction but not taxable in another. These provisions affect traditional high-leverage private equity structures and require careful modelling during deal structuring.

Substance and CFC Rules

Controlled foreign company (CFC) rules in major investor countries can attribute low-taxed passive income back to investors:

• US: GILTI regime taxes certain foreign income of US shareholders

• UK: CFC rules target low-taxed passive income in controlled entities

• Germany: CFC provisions apply to passive income below certain thresholds

Meeting substance requirements in the holding jurisdiction is often the primary defence against CFC attribution.

Regulatory Overlays

EU AIFMD affects how fund-owned holding companies are managed and reported. Cross-border insolvency creates challenges where assets, creditors, and corporate domiciles are dispersed—UNCITRAL Model Law and COMI (centre of main interests) concepts become relevant when restructuring is needed.

Reporting and Transparency

Ongoing reporting obligations include:

• Country-by-country reporting for large groups (revenue thresholds vary)

• Ultimate beneficial owner (UBO) registers in most EU states

• Automatic exchange of information under CRS

• DAC6 reporting for cross-border arrangements with certain hallmarks

Compliance failures carry significant penalties and reputational risks.

Operational, Governance and Risk Management Considerations

Running a multi-jurisdictional holding platform is an ongoing operational project, not a one-off transaction step.

Board Composition and Decision-Making

Best practice requires:

• Local directors with real responsibilities and expertise

• Regular in-jurisdiction board meetings (not just paper resolutions)

• Documented decision trails showing genuine deliberation

• Minutes reflecting substantive discussion of business matters

Directors should not merely rubber-stamp decisions made elsewhere. Tax authorities increasingly examine whether local management exercises real control.

Compliance and Reporting Calendars

A compliance map should cover each jurisdiction’s requirements:

Filing Type	Typical Deadline	Jurisdictions
Annual accounts	3-6 months after year-end	All
Corporate tax returns	6-12 months after year-end	All taxable entities
Transfer pricing documentation	With tax return	Major markets
Economic substance filings	Annually	Cayman Islands, BVI, others
UBO register updates	Within 1 month of changes	EU jurisdictions

Transfer Pricing and Intercompany Policies

All intercompany transactions must be priced at arm’s length:

• Intra-group loans (interest rates benchmarked to market)

• Management fees for services provided

• IP royalties for licensed intellectual property

• Shared services allocations

OECD transfer pricing guidelines provide the framework. Documentation requirements vary by country but are increasingly stringent.

Risk Allocation and Asset Protection

Ring-fencing liabilities through separate legal entities protects the broader group from localized problems. Key techniques include:

• Non-recourse financing at SPV level

• Limited cross-guarantees between portfolio companies

• Separate entities for different asset classes or geographies

Insolvency and Restructuring Issues

Challenges multiply when the place of incorporation, asset location, and creditor base differ. A Cayman holding company with assets in Mainland China and lenders in New York creates jurisdictional complexity.

Practical solutions include:

• Parallel local proceedings coordinated across jurisdictions

• Joint liquidator appointments with cross-border recognition

• Cooperation protocols between courts

The Saad Investments case demonstrated how Australian courts limited Cayman liquidators’ control over local assets to prioritize domestic tax claims—a reminder that cross-border insolvency rarely follows neat theoretical models.

Technology and Data

Centralised entity-management platforms help track:

• Corporate filings and deadlines

• Cap tables and shareholding changes

• Loan terms and covenant compliance

• Governance documents and meeting records

Investing in proper systems pays dividends as complexity grows.

Implementation Roadmap for Building a Multi-Jurisdictional Holding Structure

This section provides a step-by-step playbook for sponsors or corporates planning multi-country expansion between 2024 and 2027.

Step 1: Define Strategy and Investor Base

Before selecting jurisdictions, clarify:

• Target markets and anticipated deal pipeline

• Leverage policy and financing preferences

• Investor jurisdictions and their regulatory restrictions

• Anticipated holding period and exit strategies

These factors drive every subsequent decision.

Step 2: Select Holding Jurisdictions

Conduct comparative analysis of 3-4 candidate jurisdictions:

Factor	Luxembourg	Netherlands	Singapore	UAE
Treaty network	Extensive (80+)	Extensive (90+)	Strong Asia focus	Expanding
Participation exemption	Yes (10%/€6m)	Yes	Partial	Yes (ADGM)
Substance requirements	Moderate	Higher	Moderate	Lower
Setup costs	€€€	€€€	€€	€€
Familiarity to investors	Very high	High	High (Asia)	Growing

Step 3: Design the Legal Structure

Deliverables at this stage:

• Group charts showing all entities and ownership flows

• Entity type selection (Sàrl, BV, Ltd, LLC, SCSp, etc.)

• Shareholding and voting arrangements

• Financing flows and debt push-down plans

• Governance rules and reserved matters

Step 4: Secure Advice and Rulings

Engage local advisers in each relevant jurisdiction covering tax, legal, and regulatory matters. Where appropriate, seek advance tax rulings or clearances—though availability has narrowed in recent years.

Step 5: Entity Formation and Substance Build-Out

Practical steps include:

• Incorporating holding entities

• Opening bank accounts (allow 4-8 weeks in many jurisdictions)

• Appointing directors (local and investor-nominated)

• Hiring local staff or engaging managed service providers

• Arranging office space where substance requirements demand it

Step 6: Documentation and Financing Setup

Key documents to prepare:

• Shareholder agreements

• Intra-group loan agreements

• Service contracts for management and administrative services

• Transfer pricing policies

• Security packages for external lenders

Step 7: Ongoing Monitoring and Restructuring

Structures should be reviewed every 12-24 months to adapt to:

• Tax law changes and treaty updates

• Business strategy shifts

• Acquisitions or exits

• Potential simplification or onshoring of entities

The right structure today may not be optimal in three years.

Case Examples of Multi-Jurisdictional Holding Structures

These anonymised scenarios illustrate the principles described earlier with concrete geographies, timelines, and approximate figures.

Case 1: Pan-European Private Equity Platform

Background: A fund established in 2022 with commitments of €3.5 billion targeting mid-market European opportunities.

Structure:

• Luxembourg SCSp as the fund vehicle

• Luxembourg Sàrl as the main holding company

• Local intermediate holding companies in Germany, Spain, and Sweden

• Portfolio companies in manufacturing, healthcare, and business services

Outcomes:

• Luxembourg participation exemption applied to exits, eliminating holding-level capital gains tax

• EU Parent-Subsidiary Directive reduced withholding on dividends to 0%

• Centralised governance through the Sàrl simplified investor reporting

Lessons: Early investment in Luxembourg substance (local directors, regular board meetings, dedicated staff) protected treaty benefits and satisfied LP due diligence requirements.

Case 2: Asia-Focused Family Office

Background: A Singapore-based family office in 2023 with approximately $800 million in investable assets seeking exposure to high-growth Asian markets.

Structure:

• Singapore holding company at the centre

• Direct stakes in Indian operating companies (consumer goods, fintech)

• Indonesian operating company (logistics)

• Vietnamese operating company (manufacturing)

Outcomes:

• Singapore-India treaty reduced withholding on dividends from 15% to 5%

• Local investment team in Singapore satisfied substance requirements

• Coordination with India’s GAAR and indirect transfer rules avoided tax disputes

Challenges: India’s indirect transfer rules (taxing gains on shares deriving substantial value from Indian assets) required careful structuring. The family office ensured the Singapore entity had genuine substance and commercial rationale beyond tax.

Case 3: Global Corporate Reorganising Legacy Holdings

Background: A US multinational in 2021-2024 with operations across 30+ countries, accumulated through decades of acquisitions. Legacy structure included redundant entities, trapped cash, and inconsistent governance.

Transformation:

Before	After
45+ holding entities globally	2 regional hubs (Netherlands for Europe, Singapore for Asia)
Cash trapped in multiple jurisdictions	Centralised treasury function
Inconsistent intercompany loans	Standardised financing arrangements
Multiple local share registers	Unified cap table management

Outcomes:

• Reduced annual compliance costs by approximately 35%

• Improved cash repatriation flexibility

• Created cleaner structure for potential carve-outs or IPOs

Lessons: Restructuring legacy holdings requires patience. The project took three years, involved extensive regulatory filings, and required careful management of tax authority relationships. The long-term benefits justified the investment.

Future Trends in Multi-Jurisdictional Holding Structures

Regulatory, tax, and geopolitical developments through the late 2020s will continue reshaping preferred holding locations and designs.

Increasing Scrutiny of Low-Substance Entities

Purely formal holding companies—those without employees, office space, or genuine decision-making—face growing challenges:

• Treaty benefits increasingly denied

• Higher audit risk from tax authorities

• Reputational concerns from institutional investors

Substance is no longer optional.

Convergence Toward Onshore and Treaty-Based Hubs

The shift from classic offshore models (Cayman/BVI conduits) toward substance-rich hubs is accelerating. Luxembourg, the Netherlands, Singapore, and UAE free zones are gaining share from traditional tax havens. This trend will continue as regulatory frameworks and tax laws evolve.

Digitalisation and Data-Driven Compliance

Growth areas include:

• RegTech platforms automating entity management

• Real-time tax analytics across multiple jurisdictions

• Automated reporting for CRS, DAC6, and local requirements

Technology investment reduces errors and frees advisers to focus on strategic questions.

ESG and Responsible Tax

Institutional investors and sovereign wealth funds increasingly expect “responsible tax” policies from portfolio companies and managers. This influences:

• Jurisdiction selection (avoiding blacklisted or controversial locations)

• Structure transparency (willingness to disclose holding chains)

• Tax contribution narratives in annual reports

Potential Reforms

Ongoing developments to monitor:

• OECD Pillar Two (global minimum tax): Implementation affecting holding regimes in low-tax jurisdictions

• EU reforms: Continued pressure on substance requirements and conduit arrangements

• National measures: UK, Germany, France, and Asian markets refining their approaches

Investors should design adaptable structures that can be adjusted without wholesale reorganisation as rules evolve.

Conclusion: Building Resilient Multi-Jurisdictional Holding Structures

Multi-jurisdictional holding structures remain among the most powerful tools available to investors seeking to build and manage cross-border portfolios. When designed thoughtfully, they deliver tax efficiency, asset protection, governance clarity, and operational flexibility that direct investment simply cannot match.

Success depends on aligning investment objectives with genuine substance and commercial rationale. Structures that exist only on paper, with no real employees, directors, or decision-making, will increasingly fail under tax authority scrutiny and investor due diligence. The regulatory compliance and administrative burdens of maintaining entities across multiple jurisdictions are real costs that must be weighed against benefits.

Structure design should be treated as a strategic exercise, revisited periodically—at minimum every two to three years—or upon major legal changes, acquisitions, or exits. What works today may not be optimal as tax laws evolve, treaties are renegotiated, and business strategies shift.

For high net worth individuals, family offices, private equity sponsors, and multinational corporates considering cross-border portfolios from 2024 onwards, the path forward is clear: map your current and target footprints, identify the jurisdictional differences that matter most for your investment goals, and engage experienced cross-border advisers to craft a tailored, future-proof holding platform. The complexity is real, but so are the rewards for clients navigating this landscape with tailored solutions built on solid foundations.

This article is provided for general information only and does not constitute financial, investment, legal, tax, or regulatory advice. Views expressed are necessarily high-level and may not reflect your specific circumstances; you should obtain independent professional advice before acting on any matter discussed.

If you would like support translating these themes into practical decisions - whether on capital structuring, financing strategy, risk governance, or stakeholder engagement - Bridge Connect can help.

Please contact us to discuss your objectives and we will propose an appropriate scope of work.