Surviving and Thriving in a High-Tax Future

“The era of ‘bank secrecy’ is essentially over.”

The global tax landscape is becoming increasingly complex, and scrutiny of wealth is growing. As a result, families, entrepreneurs, and advisors are reconsidering their approaches to tax planning, compliance, and wealth preservation.

In this conversation, Multipolitan sits down with Michael Velten, founder of Velten Advisors. Michael is a qualified solicitor and CPA in Australia, as well as a certified tax advisor in both Hong Kong and Singapore. He spent 12 years as a Senior Partner at Deloitte Southeast Asia, where he led financial services tax, private client tax, and family office advisory, while also holding leadership roles in investment management and real estate.

Together with Michael, we will examine how ultra-high-net-worth (UHNW) families are adapting to transparency and reporting obligations, the latest regulatory trends across key jurisdictions, and the evolving challenges of cross-border tax planning. Michael also shares his insights on the rise of digital entrepreneurs, the impact of global minimum taxes, and the future of private tax advisory in an era characterised by mobility, innovation, and increased reputational risk.

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How are ultra-high-net-worth families rethinking their tax strategies in light of rising global transparency and reporting obligations?

UHNW families are adjusting their tax strategies in response to increasingly strict global transparency and reporting standards. The period of discreet wealth management is shifting towards one where automatic information sharing, heightened compliance demands, and harmonised international tax policies compel families to focus on transparency, proactive planning, and tax management rather than privacy.

The strategic response is complex. UHNW families are restructuring their wealth through trusts, foundations, and charitable giving for tax optimisation and social impact. Many are rethinking residency and domicile strategies to minimise taxes. Some are investing in compliance frameworks and using technology and tax tools to navigate cross-border regulations.

Families are now adopting proactive tax planning and compliance, recognising that attempting to minimise disclosures is no longer practical. With the upcoming Crypto Asset Reporting Framework (CARF), the Common Reporting Standard (CRS) 2.0, and the EU Tax Observatory’s proposal for a 2% minimum tax on ultra-high-net-worth (UHNW) wealth for the G20, UHNW families are focusing on strategies to remain compliant while protecting their multigenerational wealth. This shift alters how ultra-wealthy families approach tax planning in a progressively transparent environment.

Effective tax planning for UHNW families and individuals requires transparency, compliance, and agility in responding to evolving international tax initiatives. Those who adapt will protect their wealth; those who hesitate may face risks in this era of global tax transparency.

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What are the most significant tax reforms or regulatory trends you've observed recently across key jurisdictions like Singapore, the UAE, the UK, or the US?

Recent years have seen notable changes in tax policies and regulatory trends across major global jurisdictions, including Singapore, the United Arab Emirates (UAE), the United Kingdom (UK), and the United States (US). These reforms are primarily driven by international tax coordination (especially OECD initiatives), economic competitiveness, and the need for fiscal sustainability.

The most important trend is the widespread adoption of OECD BEPS 2.0 (Pillar Two) rules, with Singapore, the UAE, and the UK all introducing a 15% minimum effective tax rate for MNEs with revenues exceeding EUR 750 million. This marks a notable shift towards global tax coordination.

Key Regulatory Trends:

• Enhanced Transparency: Jurisdictions are mandating more detailed reporting and disclosures concerning beneficial ownership.
• Digital Economy Emphasis: Broadening tax bases to encompass digital services and contemporary business models.
• Enhanced Compliance and Transparency: Greater accountability through improved reporting, higher audit standards, and clearer beneficial ownership disclosures, especially in the UAE and UK.
• Enhanced Enforcement: Increased investment by tax authorities in technology, analytics, compliance personnel, and auditing resources.
• Political Uncertainty: Particularly in the US, where important tax provisions may be about to expire.

Key local developments:

1. Singapore

Implementation of OECD Pillar Two (BEPS 2.0): Singapore has enacted the Multinational Enterprise (Minimum Tax) Act 2024, along with associated regulations, effective from 1 January 2025. This legislation establishes a minimum effective tax rate of 15% through top-up taxes, specifically the Domestic Top-up Tax (DTT) and the Multinational Enterprise Top-up Tax (MTT), for in-scope multinational groups.

Corporate Income Tax (CIT) Rebate and Incentives: For the Year of Assessment 2025, eligible companies will receive a 50% CIT rebate (capped at SGD 40,000), along with a cash grant of SGD 2,000 to help with business costs. New and enhanced tax incentives are designed to strengthen Singapore's equities market, including tax breaks for new listings and fund managers, as well as increased deductions for equity-based remuneration schemes.

Extension and Refinement of Existing Incentives: The Mergers & Acquisitions and Double Tax Deduction for Internationalisation schemes have been extended until 2030. Enhanced regulations now provide upfront certainty that gains from the disposal of shares, including preference shares, are not taxed, and allow group ownership to count towards the relevant thresholds.

Enhanced Compliance and Transparency: Intended adoption of CRS 2.0 and the CARF.

2. UAE

Introduction of Federal Corporate Tax: In 2023, the UAE introduced a federal corporate tax system, imposing a 9% tax on profits over AED 375,000. However, qualifying Free Zone Persons (QFZPs) can benefit from a 0% rate if they meet certain criteria.

Domestic Minimum Top-Up Tax (DMTT): Starting in 2025, the UAE will implement a 15% DMTT targeting multinational enterprises with global revenues exceeding EUR 750 million. This measure ensures that MNEs pay a minimum effective tax rate while still benefiting from the advantages of Free Zone incentives.

Enhanced Compliance and Transparency: New regulations now mandate regular disclosures of the Ultimate Beneficial Owner (UBO), require audits for Free Zone entities, and strengthen controls for the Foreign Account Tax Compliance Act (FATCA) and CRS.

3.United Kingdom

OECD Pillar Two Implementation: The UK has introduced the Income Inclusion Rule (IIR) and a DMTT for large multinational companies, effective from accounting periods beginning on or after 31 December 2023. The Under-Taxed Profits Rule (UTPR) will take effect for accounting periods commencing on or after 31 December 2024.

Tax Simplification and Modernisation: The government aims to make the tax system easier to understand and more current, tackle non-compliance, and create a fairer system. Recent reforms include amendments to transfer pricing, permanent establishment regulations, and the diverted profits tax.

Other Important Changes: Increased Capital Gains Tax (CGT) rates, the abolition of the “non-dom” regime (now replaced by the new regime for foreign income and gains, or FIG), and higher employer National Insurance Contributions (NICs) rates from April 2025.

4. United States

The primary focus in the United States is the "One Big Beautiful Bill."

The "One Big Beautiful Bill” represents a tax and spending initiative that the House approved on 22 May 2025, now awaiting Senate review. Backed by the GOP, this legislation builds on the 2017 Tax Cuts and Jobs Act (TCJA) by introducing tax reductions and new provisions for individuals, families, businesses, and non-profits.

Notable features include doubling the standard deduction, increasing the child tax credit to $2,500 per child, removing taxes on tips and overtime, and raising the SALT deduction cap to $40,000 for eligible married couples. Additionally, the bill introduces new deductions for auto loan interest, expands benefits for small businesses, and establishes a tiered excise tax for private foundations and universities.

The bill affects federal spending, raises the debt limit, and gradually removes several clean energy tax credits, sparking debate. It can pass through the Senate using reconciliation rules with a simple majority, bypassing the filibuster; however, negotiations are anticipated. While passing in the House is a milestone, the final version and approval remain uncertain as senators modify provisions before it becomes law.

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In a world of increasing scrutiny on wealth and mobility, how do you help clients balance tax efficiency with reputational and compliance risks?

In an era of increased scrutiny on wealth, taxes, and global mobility, assisting clients in achieving tax efficiency while managing reputational and compliance risks requires a proactive approach.

The key is to develop a tax risk management framework. This framework helps advisers guide clients towards sustainable tax outcomes that protect reputations and ensure compliance. It recognises that aggressive tax minimisation may harm long-term value through reputational damage or regulatory sanctions.

Balancing tax efficiency with reputational and compliance risks requires a layered approach that prioritises sustainability over short-term savings. This begins by defining the level of risk and scrutiny that clients are willing to accept. High-profile individuals and UHNW families and individuals face unique reputational risks compared to private business owners. Next, develop a framework to assess strategies while considering regulatory complexity, public perception, and audit likelihood. This sets the parameters before exploring optimisation opportunities.

The approach focuses on creating a balanced tax risk policy that aligns efficiency goals with the overall risk appetite and business strategy.

The components of a tax risk management framework include:

• Comprehensive Tax Risk Policy: Define clear strategies for tax planning and compliance, supported by strong internal controls.
• Proactive Risk Assessment: Consistently identify and assess potential exposures resulting from regulatory and tax changes, as well as complex transactions and transactions involving high-risk areas.
• Compliance-First Mitigation: Prioritise adherence to tax laws over aggressive optimisation strategies that may attract scrutiny.
• Technology Integration: Utilise analytics for real-time visibility and improved tax compliance and reporting accuracy.
• Continuous Monitoring: Regular updates to strategies that reflect changes in regulations and public sentiment.
• Reputational Management: Incorporate transparency and ethical principles into a sustainable tax strategy.

The framework emphasises that an effective tax strategy involves risk awareness, transparency, and ethical considerations that go beyond mere technical optimisation. It recognises that reputational concerns are of great importance, with family businesses and UHNWIs adjusting their approaches due to public scrutiny, not just for tax efficiency.

Some broader observations include:

• Prioritise substance over form: Effective tax strategies should have real economic substance. Focus on those that align with actual business operations or investment goals.
• Implement Documentation Standards: Keep records that provide business reasons for each structure, including board resolutions and operational evidence. Robust documentation ensures compliance and protects reputation against scrutiny.
• Regular Compliance Health Checks: Conduct regular reviews of structures and positions as tax laws evolve to ensure ongoing compliance with these laws. Monitor ownership requirements, substance regulations, and tax treaty updates. Detecting compliance gaps early helps prevent larger issues.
• Prepare for transparency: With rising global demands for transparency, such as beneficial ownership registers and automatic information exchanges, craft strategies that can withstand public scrutiny. Consider how structures are portrayed in media coverage and whether they align with declared family and corporate values.

In short, the key is to build tax efficiency that enhances, rather than undermines, broader business and personal objectives.

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With the rise of digital entrepreneurs, influencers, and crypto-native clients, how has tax advisory work evolved over the past five years?

Tax advisory work has undergone a significant transformation to keep pace with the evolving business models and revenue streams of the emerging digital economy. The complexity surrounding the classification and reporting of digital income has increased significantly, with advisors now routinely managing influencer sponsorship deals, affiliate marketing commissions, NFT sales, DeFi, and subscription-based digital products. Each requires distinct treatment, and guidance from tax authorities can often lag these innovations, leaving advisors to navigate grey areas while safeguarding clients from future compliance issues.

Some specific observations follow:

• Cryptocurrency and Multi-Jurisdiction Complexity: Crypto transactions have become a specialised area, requiring advisors to track cost basis across various wallets, manage hard forks and airdrops, and handle DeFi transaction reporting. Meanwhile, digital entrepreneurs operating across state and international borders face more complex nexus issues and compliance requirements in multiple jurisdictions than traditional business structures.
• Technology Integration Requirements: Tax practices focused on this area may need to invest in technology to manage the volume and complexity of digital transactions. This includes crypto tax software, automated bank feed integrations, and platforms that can process transactions from various digital revenue streams. These capabilities were unnecessary in traditional practice.
• Shift to Ongoing Advisory Relationships: The traditional reactive approach has evolved into ongoing advisory relationships. Digital entrepreneurs need regular tax advice, optimisation of their entity structure, and proactive strategies for managing irregular income streams.

All of this leaves aside the implications of the Crypto-Asset Reporting Framework for digital entrepreneurs. The CARF is poised to reshape the digital economy landscape. This OECD initiative requires comprehensive reporting of all crypto activities, including cryptocurrencies, stablecoins, NFTs, DeFi transactions, and tokenised securities. The exchange of information will commence in 2027 (for 2026) or 2028 (for 2027). Over 60  jurisdictions committed to implementation and automatic data sharing between tax authorities.

The operational impact on digital entrepreneurs will be immediate and substantial. Crypto-Asset Service Providers (CASPs) must gather enhanced documentation, including tax residency details and taxpayer identification numbers, while reporting obligations encompass crypto-to-fiat exchanges and peer-to-peer transfers.

In jurisdictions adopting the CARF, exchanges, wallet services, NFT marketplaces, and DeFi platforms must allocate resources to compliance infrastructure. These obligations go beyond traditional Anti-Money Laundering and Know-Your-Customer standards.

As with the implementation of FATCA and CRS, tax professionals will have a vital role in advising CASPs and digital asset investors.

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Many family offices are diversifying across multiple jurisdictions. What are the biggest pitfalls or blind spots you see in cross-border tax planning?

Asian family offices diversifying across jurisdictions face significant pitfalls in cross-border tax planning. The complexities of tax regimes, evolving regulations, and increased transparency create challenges.

The most critical issues include:

• Misunderstanding Tax Residency and Permanent Establishment Risks: Many families mistakenly believe that incorporating in a low-tax jurisdiction alone allows them to avoid tax residency and permanent establishment issues. In reality, corporate tax residency depends on where management and control take place, not just where the company is legally registered. If key decision-makers or operations are in a high-tax country, that country may tax the entity’s worldwide income. Setting up an office, hiring staff, or conducting activities in another country can create a permanent establishment, subjecting the family office to local taxation on part of its income, even if it is registered offshore.
• Neglecting Withholding Taxes: Investing internationally, particularly in the US or major markets, can result in significant withholding taxes on interest, dividends, royalties, and rent. For instance, interest paid from the US to non-US investors faces a 30% withholding tax unless tax treaties or domestic exemptions, such as the portfolio interest exemption, are applicable. Poor investment structuring can lead to avoidable tax liabilities and increased compliance burdens.
• Residency Assumptions and Tie-breaker Rules: Many families underestimate the complexities involved in determining tax residency. Simply possessing a passport or residing in a location for fewer than 183 days does not guarantee non-resident status. Countries like Australia and the UK employ intricate tie-breaker tests that consider factors such as available housing, family connections, and economic ties. Families from Asia often overlook how these regulations interact across different jurisdictions, which can lead to unexpected dual residency situations. Additionally, CRS 2.0 will require the reporting of all domestic tax residencies, not just the tie-breaker residency as specified in the relevant tax treaty. For example, this could have significant implications for mainland Chinese individuals with a family office and/or tax residence in Singapore who still hold household registration in China, thereby continuing to be regarded as domestic tax residents in China while residing and being taxed in Singapore.
• CRS and Automatic Information Exchange Gaps: Although most families are familiar with the Common Reporting Standard, they often overlook important timing and scope issues. Planning for the timing of information exchange frequently lacks coordination with the moments when tax obligations arise. Furthermore, many believe that all Asian jurisdictions engage with the CRS uniformly; however, countries such as Taiwan, Thailand, and the Philippines have varying levels of implementation, presenting both opportunities and risks for planning.
• Controlled Foreign Corporation (CFC) Rule Complexity: Asian families often establish structures without a complete understanding of how CFC rules operate in their home countries (e.g., China, Indonesia, and Taiwan). When combined with CRS reporting, these structures may face increased scrutiny. At the same time, consideration should be given to potential CFC planning opportunities that might exist.
• Trust and Foundation Structure Misalignment: There can be a tendency to use standard or “cookie-cutter” offshore structures without considering how they are perceived in each relevant jurisdiction, such as the country where the beneficiaries reside. This oversight can lead to unexpected tax liabilities, particularly in jurisdictions with high tax rates and complex tax systems, such as Australia.
• Succession Planning Across Different Legal Systems: Asian families often concentrate on minimising current taxes, sometimes at the expense of considering how various inheritance and gift tax laws interact during succession. The complexity caused by the conflict between forced heirship rules in civil law jurisdictions and Anglo-Saxon trust principles may be overlooked.
• Evolution of Substance Requirements: The need for economic substance requirements is increasing, particularly in jurisdictions such as Hong Kong and Singapore. This trend impacts not only access to tax treaties and benefits but also foreign-sourced income and capital gains exemptions. Having just a local director or registered office may no longer be enough. Tax authorities are more closely examining actual business activities, the placement of key personnel, and decision-making processes.
• Transfer pricing documentation issues: When family entities engage in cross-border transactions, such as lending money, providing services, or transferring assets, inadequate documentation of arm's-length pricing may result in transfer pricing adjustments and penalties.
• Exit tax pitfalls: Family members might move to a different jurisdiction without properly addressing their tax obligations in their home country, leading to situations where they could be taxed as residents in multiple locations or face exit fees or taxes on unrealised gains.
• Treaty shopping: The use of tax treaties becomes more difficult as countries enforce anti-abuse measures. Family offices must focus on current substance requirements and principal purpose tests.

The most effective Asian family offices focus on continuous monitoring. They maintain detailed records and recognise that cross-border tax planning necessitates ongoing adjustments in response to shifting family circumstances, evolving regulatory environments, and evolving international tax laws.

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Global minimum taxes and the OECD’s Pillar Two rules are gaining traction; how do these developments impact private investors and multinational families?

OECD Pillar Two rules target large MNEs with annual consolidated group revenues of EUR 750 million or higher. The purpose of Pillar Two is to ensure that these major companies pay at least a minimum tax rate on income generated in each country where they do business.

Pillar Two is part of the broader OECD/G20 BEPS (Base Erosion and Profit Shifting) initiative, which addresses tax challenges caused by digitalisation. The framework aims to mitigate tax competition and prevent the "race to the bottom" in corporate tax rates, thereby enabling multinationals to avoid shifting profits to low-tax jurisdictions. Over 65 countries have either implemented or drafted legislation based on the OECD's Pillar Two framework.

Pillar Two could have implications for multinational family businesses and private investors. These include:

• Top-up taxes: Family businesses with revenues exceeding EUR 750 million in at least two of the past four years must pay additional taxes in countries where the effective tax rate is below 15%, which can undermine local tax incentives and free-zone concessions. The regulations provide safe harbours and de minimis exclusions to facilitate compliance. Even if they do not owe top-up tax, these businesses still face extensive global compliance and reporting requirements. In some jurisdictions, penalties for non-compliance and failure to file can be severe.
• The EUR 750 million Threshold Brings Unexpected Risks: The global minimum tax targets multinational groups with consolidated revenues exceeding EUR 750 million, but many family offices and private investors may unintentionally fall within its scope. The challenge stems from how "revenues" are interpreted for investment-focused entities and the application of "deemed consolidation" regulations, which can classify connected entities as being under common control. Families managing significant investment portfolios alongside trading operations, or those with complex international holding structures, might find that revenue aggregation obligations create compliance requirements, even if the family office was not the main target.
• Structural Challenges with Trusts and Foundations: Identifying the Ultimate Parent Entity (UPE) is crucial for determining which entities fall under the Pillar Two framework. Family asset-holding structures, such as trusts and foundations, may be regarded as UPEs. When personal assets or family office entities are combined with business assets within the same ownership structure, those personal assets will be included in the Pillar Two framework.
• Compliance Challenges: Entities within scope must submit GloBE Information Returns, which require more than 150 data points for each entity. These entities need to monitor effective tax rates across all operating jurisdictions, which necessitates the use of sophisticated accounting systems.
• Investment Strategy Considerations: Family offices often hold portfolio investments in offshore financial centres that offer favourable tax rates. Consequently, investment income and gains become significant sources of potential exposure under minimum tax laws. Structures falling under these regulations may incur top-up tax charges if they generate income or gains taxed at a rate below the 15% threshold. However, the outcome varies; investment returns might avoid top-up taxes due to accounting practices, specific exemptions in regulations, or if the low-taxed income is offset by higher-taxed profits within the group.
• Political Uncertainty Adds Complexity: In January 2025, President Trump announced that the OECD “Global Tax Deal” held "no force or effect" in the United States, effectively withdrawing from the international agreement. Despite this, many major jurisdictions are still progressing with the rules, resulting in a fragmented set of compliance obligations for families conducting business internationally. This situation introduces unpredictability for cross-border structures and could influence families' strategies for international tax planning.

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Succession and intergenerational wealth transfer planning remain key themes. How are tax strategies shifting in this space, especially for families with globally mobile heirs?

The most significant intergenerational wealth transfer in history is currently underway, with $124 trillion in assets expected to change hands by 2048. Affluent families, especially those with mobile heirs, are increasingly prioritising succession planning and wealth transfer. This occurs against the backdrop of significant changes to tax laws and evolving international frameworks that necessitate strategic consideration.

For example, American families are preparing for the expiry of provisions from the TCJA. By 2025, the lifetime estate and gift tax exemption is expected to decrease from $13.99 million to approximately $7 million in 2026, representing a nearly 50% reduction. This decline is seen as a "once-in-a-lifetime" opportunity to save on federal gift and estate taxes. As a result, there has been a significant increase in strategic gifting, with families adopting a "use it or lose it" approach to maximise current federal gift and estate tax exemptions. Importantly, the IRS has stated that lifetime gifts made. At the same time, the exemption is higher, which means that if the exemption amount is reduced, it will not result in retroactive taxation, thereby alleviating concerns about clawback and encouraging prompt action. This change has prompted families to accelerate wealth transfer plans to secure today’s favourable thresholds.

For families with heirs and assets distributed across multiple countries, the complexity of wealth transfer becomes much greater. For example, individuals who are not U.S. citizens generally do not have to pay U.S. estate tax unless they own assets situated in the United States. However, if their heirs are U.S. residents or citizens, those assets could be taxed in the next generation, emphasising the importance of careful planning to prevent double taxation.

Other factors raise challenges in developing intergenerational wealth transfer strategies. These include:

• International Tax Transparency: Tax authorities are increasing enforcement by employing enhanced reporting under the CRS and FATCA, which requires a greater focus on compliance.
• Jurisdictional Differences: Many countries impose their own estate or inheritance taxes, with broadly varying exemption limits and rates. For example, in Japan, long-term residents may face an inheritance tax of up to 55% on their global assets, whereas in European countries, such as France, 50-75% of an estate is typically allocated to children due to forced heirship laws.
• Forced Heirship and Local Succession Laws: In regions with forced heirship laws, a specific part of the estate is allocated to designated heirs, regardless of the terms specified in the will. This legal requirement can override the testator's wishes and complicate international estate planning.
• Multi-Jurisdictional Wills and Trusts: Families often need to coordinate different wills or consider multi-jurisdictional estate plans to ensure their assets are distributed in accordance with their wishes while adhering to local laws.

The most effective approach to wealth transfer planning emphasises flexibility and informed decision-making. By staying up to date with changing tax laws, utilising available exemptions and planning tools, and working closely with advisors across relevant jurisdictions, families can protect their legacies and ensure a smooth transfer of wealth to their heirs, regardless of their location worldwide.

In conclusion, amid global mobility, careful and proactive planning is essential for successful succession and wealth transfer.

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What’s your take on the debate between onshore vs. offshore structuring in today’s regulatory climate? Is the offshore trust model still alive and well?

The wealth management playbook is evolving. For many years, wealthy investors preferred offshore solutions for privacy, tax benefits, and asset protection. Domestic options are increasingly surpassing offshore choices, attracting attention from a broad range of advisors and wealth planners.

The offshore advantage has diminished due to regulatory reforms. The Common Reporting Standard, FATCA obligations, and beneficial ownership registries have broken down the secrecy that once made offshore structures attractive. Tax authorities now have access to offshore arrangements, turning a strategic advantage into a compliance challenge. The era of "bank secrecy" is essentially over.

Domestic jurisdictions are introducing advanced alternatives that compete with traditional offshore advantages. In the U.S., states like Delaware, South Dakota, and Nevada now offer perpetual trusts, dynasty structures for wealth transfer, and asset protection features rivalling offshore options. Importantly, these onshore solutions provide what offshore structures increasingly lack: predictability, familiar legal frameworks, and regulatory stability for investors. In Asia, jurisdictions such as Singapore, Hong Kong, and Malaysia offer onshore family office, fund, and trust options.

The economics present a straightforward narrative. Offshore structures now entail higher setup costs, complex compliance, and multiple services, alongside vigilance against regulatory and tax changes. Domestic options offer similar benefits at often lower costs and greater certainty. The critical question has shifted from "Why wouldn't I go offshore?" to "Why would I?"

Offshore structures still hold value, particularly for strong creditor protection in the Cook Islands, global family succession planning, and specialised business ventures. The future favours hybrid strategies that blend onshore stability with selective offshore benefits, or fully domestic methods prioritising substance and compliance over form. The transition to onshore structures indicates progress in wealth management. It's a move towards more sustainable, transparent, and more effective strategies.

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Can you share an example of a particularly complex structuring case you’ve worked on, and what it revealed about the future of private tax advisory?

Every case has its own unique aspects, especially with Asian families, which are characterised by complexities across different jurisdictions. Due to the varied tax laws and regulations in each country within the region, no single case can define the future of private tax advisory services.

A composite case  follows:

A Malaysian family holds the majority stake in an Australian-listed company (which owns real estate assets in Malaysia), as well as in a Malaysian-listed company. The total market value of the family’s stake in the two listed companies is EUR 750 million.

The family has significant personal financial investments, including:

• Real estate in Australia, Dubai, Tokyo, London, and the U.S. The real estate is held through offshore companies.
• Private asset investments in technology startups in Southeast Asia.
• Singapore and Swiss private banking accounts.
• Cryptocurrency assets held by various exchanges and platforms.

The founder and his wife, both in their late 60s, live in Kuala Lumpur. They have three children. The eldest, a banker, lives in Singapore with her husband and two children, who are Singaporean citizens. She is a permanent resident there. Their middle child is an entrepreneur in Australia, where he holds Australian citizenship and is married with one child. The youngest is currently in the US, pursuing postdoctoral studies, has a green card, and plans to establish his career there.

The family intends to establish a family office in Singapore to manage their personal financial and real estate holdings, as well as a trust designed to hold shares in publicly listed companies. This trust will serve as a long-term investment vehicle for the family and future generations.

A Labuan foundation will hold a family office for the family members. The daughter based in Singapore will manage the family office due to her background in finance. The son based in Australia will continue to focus on identifying start-up and private asset opportunities for the family to invest in through the family office. He will serve as a director of the family office (along with his sister) and have the authority to conclude transactions on its behalf.

The fact pattern raises a range of complex issues. These include:

• Tax Residency Conflicts: Family members have different tax residencies in Australia, Malaysia, Singapore, and the US, causing overlapping tax issues, particularly regarding the proposed trust and foundation, as well as reporting requirements.
• Singapore Family Office: The structure and operations of the family office, including the application process for the Section 13O/U tax incentive and the tax implications associated with transferring assets, particularly real estate, into the family office structure.
• Tax Residence of the Family Office: The control and management of the family office must be established in Singapore to benefit from Singapore’s tax treaties.
• Permanent Establishment Risk: The risk of a permanent establishment in Australia related to the middle son’s authority to conclude transactions for the family office.
• Trust Location: The preferred location and governing law for the trust*.*
• Trust Features: The primary features and terms of the trust, including the settlor's wishes.
• Trust Taxation: Key factors to consider include taxes (and other regulations and listing rules) related to transferring shares of a publicly listed company into the trust, as well as the tax implications for both the settlor and beneficiaries (and protector), depending on their tax residency.
• Foundation Tax Treatment: The tax implications for the foundation and beneficiaries based on the family members' tax residencies.
• Pillar Two Considerations: Assessing whether the proposed trust meets the criteria for a UPE and the significance of OECD Pillar Two and the 15% Global Minimum Tax.
• Crypto Reporting: Transactions involving cryptocurrency may be reported under the CARF.

Cases like this have always required careful planning, ongoing management, and review. This will only become more difficult. Complex tax regulations, transparency demands, revenue pressures, and increased audits will collectively subject structures like the one described to scrutiny in all relevant locations.

There is a growing focus on avoiding unnecessary tax exposures rather than solely seeking advantageous tax outcomes in a particular jurisdiction. This trend is significant when multiple jurisdictions are involved, as in the case study.

The complexity of fact patterns like this demands a holistic approach rather than individual or isolated solutions.

Private tax advisors now must:

• Simultaneously manage corporate, trust, and personal tax positions.
• Model scenarios for Pillar Two impacts.
• Incorporate reputational safeguards into structures and tax risk management frameworks.
• Monitor regulatory and tax updates across various locations.
• Ensure tax compliance and reporting utilising appropriate technology tools.

In other words, a forward-looking and adaptive approach is required.

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If you had to predict, how will the role of a private tax advisor evolve in the next decade? What skills or specialisations will define the next generation of tax professionals?

The private tax advisory sector is evolving due to technological advancements (especially AI), complex regulations, and shifting client needs. Tax is now a year-round strategic partnership that requires new skills, better tools, and innovative ways to serve clients. Over the next decade, private tax professionals will need to combine technical expertise with analytical skills, effective communication, and a commitment to learning new technologies. This involves investing in technology skills, improving advisory abilities, and developing specialised expertise.

These elements are analysed in more detail below:

• Automation and AI: Both automation and AI are transforming taxation by handling data entry, document processing, and tax research. Tax advisers need to master platforms that analyse data for real-time insights. Firms will have to invest in AI-enhanced client portals to provide personalised services and seamless digital experiences, which clients will increasingly expect as standard.
• Strategic Partner: As automation takes over routine filings and tax research, tax professionals will develop into strategic partners, supporting clients through transitions, honing tax strategies, and identifying tax planning opportunities. Ongoing engagement will replace the traditional seasonal approach, as clients increasingly seek continuous strategic advantages and effective tax management.
• Specialisation: The complexity of tax law requires a focus on emerging areas. Taxation of digital assets is vital due to the rise of cryptocurrencies and non-fungible tokens (NFTs). International tax expertise is increasingly necessary with the growth of global mobility. The complexity of state and local tax increases, as jurisdictions compete for revenue, necessitates the need for specialists to address challenges related to nexus.
• Human-centred skills: As technology automates tasks, the importance of human factors increases. Success depends on effective communication and relationship management, which require professionals to simplify complex ideas and build strong client relationships. Emotional intelligence and leadership are essential for the next generation of tax advisors, enabling them to effectively guide clients through complex decisions and evolving regulations. The ability to analyse regulations and forecast trends, while keeping clients informed, sets exceptional advisors apart.