For many years, the trust was the default answer to international wealth planning in a number of jurisdictions. For example, in the past, wealthy clients moving to the UK could use a well-structured offshore trust to protect their assets, undertake succession planning and benefit from significant tax advantages.

Since the UK tax rules changed fundamentally in April 2025, trusts no longer hold the same benefits. For UK resident settlors, trusts are now largely “looked through”, meaning the income and gains can be taxed as though they are personally theirs. Assets within the trust may also be exposed to inheritance tax for UK long term residents (resident for ten out of twenty years). As a result, advisers have been re-evaluating structures that may have been in place for decades, giving many wealthy families different options they might not have considered before.

How the focus for wealth structures is shifting

Historically, wealth planning focused on delaying tax liabilities. Increasingly, wealthy families and their family offices are now prioritising governance, control, succession planning and flexibility. For some, the tax changes have been a catalyst for a broader reassessment of how family wealth should be held.

We are also seeing traditionally UK-based families explore international structures. Rising UK tax rates, the growing international mobility of younger generations, and concerns about preserving wealth across multiple jurisdictions mean that many families now see value in establishing structures that can accommodate future migration, overseas investment and global family ownership.

Trusts do not fit well into the tax and succession laws in civil law jurisdictions, which cover most of continental Europe and much of the wider world. So a wholesale review of wealth holding structures is underway for many ultra wealthy families.

The increasing use of companies and why families are using them

In many jurisdictions, companies are often used for holding family wealth as an alternative to trusts, where trusts are not recognised or together with a trust as part of a wider structure. In the UK, the family investment company has been growing in popularity over the past decade as tax rates on trusts and individuals have increased while corporate tax rates have remained relatively low.

A company provides a familiar governance framework and can allow investment profits to accumulate at corporation tax rates rather than family members being taxed immediately at high personal tax rates. Family members can hold different classes of shares, allowing future growth to pass to younger generations while senior family members retain control. Many entrepreneurial families find the corporate model more intuitive than a trust structure and appreciate the clarity that company law provides.

Where wealth is not required for immediate use, this route can be an efficient vehicle for long-term capital accumulation, with improved compounding due to lower tax rates, and family succession planning.

Why family offices are turning to investment funds and private fund structures

Interest in regulated funds is also growing. Funds provide professional investment management, diversification and robust governance. They are particularly attractive for families who would prefer to focus on strategic oversight rather than day-to-day investment decisions.

Private fund arrangements, including Jersey Private Funds and other private labelled funds, have gained particular attention. These allow significant family wealth or connected investors and / or family members to pool capital in a professionally managed environment while retaining a degree of flexibility over how wealth is invested and passed between generations.

For many family offices, opting for these structures represents a move away from bespoke trust administration towards institutional-quality investment infrastructure and potentially allows them some control separate from the family.

How offshore bonds can provide tax deferral

Offshore bonds are also generating renewed interest as they offer tax deferral. Income and gains can generally roll up within the policy, with tax arising principally when benefits are taken or a chargeable event occurs.

There are limits on investment choice within the bond, but for internationally mobile families, timing a realisation can be particularly important. Where a future move overseas is anticipated, an offshore bond’s flexibility may create planning opportunities that would not otherwise be available, especially if a realisation can take place in a jurisdiction which will not tax the bond profits. At the same time, the relative simplicity of these structures makes them attractive to families seeking a lower administrative burden than a traditional trust arrangement.

Protected cell companies and other specialist vehicles

Larger families with more complex wealth arrangements are increasingly exploring structures such as protected cell companies (PCCs).

A PCC allows assets and liabilities to be segregated into separate cells within a single legal framework. This means different branches of a family can maintain their own investment portfolios while benefiting from shared administration and governance.

From a tax perspective, PCCs can offer attractive opportunities to defer capital gains tax. Whilst income is generally taxed on UK resident investors as it arises, gains realised within a properly structured offshore PCC may not be immediately attributed to shareholder level. This can allow capital proceeds to be reinvested within the cell, with UK tax deferred until funds are distributed or the cell is wound up. The foreign situs of the investment may also benefit internationally mobile families and those considering leaving the UK in the future.

While PCCs are not suitable for every family, they demonstrate the continuing innovation in wealth structures. As families lead more global lives and governance becomes more important, specialist structures like PCCs are likely to attract more attention alongside more traditional arrangements.

International mobility remains important

Families who anticipate that future generations will live, work or study overseas are increasingly considering structures that can continue to function efficiently across multiple jurisdictions. Foreign companies, offshore funds and international pension arrangements can all play a role depending on a family's objectives and future plans.

From a UK perspective, since the April 2025 tax changes, both internationally mobile families and traditionally UK-based families have been increasingly concerned with the same issues: preserving wealth across generations, managing governance and ensuring that structures remain adaptable in an uncertain and globalised world.

Choosing the right structure for family wealth

Perhaps the most important lesson from the evolving tax treatment of trusts and the recent UK non-dom reforms is that there is no single replacement for the trust.

Wealthy families and their family offices will need to consider a combination of these structures to achieve their goals. The challenge is selecting the right combination of vehicles to support governance, investment objectives, family succession and global mobility.

A review of wealth holding arrangements now can also drive the wider conversation on the family’s purpose of wealth and their values so as to design the right arrangement that is bespoke to the family’s particular wishes. This exercise fits well with the overall professionalisation and personalisation of wealth structures that we are seeing for these ultra wealthy families.

To explore which structures could work best for your family’s circumstances, please contact Caroline Le Jeune or your usual RSM contact.

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