Latest / Offshore Tax with HTJ.tax
Structuring Around CRS for Russians
Top Company (Custodial Institution)The company’s articles and memorandum allow its shares to transfer automatically to designated third parties (typically family members) upon the shareholder’s death.This mechanism does not create a trust, because there is no fiduciary relationship—only a custodial structure.Therefore, it does not fall under EU trust-related sanctions, which target fiduciary and trust-like arrangements.The company’s place of effective management (POEM) is in Svalbard, a CRS non-participating jurisdiction.As a result, the top company is treated as a Non-Reporting Financial…
The skinny
The skinny isn't ready yet — notes appear once the transcript is processed.