Yip Ho Ying was named as the winner of the Judges Prize at the Sovereign Art Foundation’s 2026 Hong Kong Students Prize at the Awards Ceremony held at Art Central in the city’s iconic Central Harbourfront on 28 March, with Lam Man Hei of receiving the Public Vote Prize.

Now in its 14th year, this annual award is designed to celebrate the importance of art in the education system and showcase young artistic talent to a wider audience. It also enables the Sovereign Art Foundation (SAF) to engage with local organisations that share its aim of promoting arts in the community and encouraging cultural development.

Teachers in secondary schools across Hong Kong were invited to nominate their best art students to submit artworks to the competition. 20 were then shortlisted for the Finalists’ Exhibition that ran at Art Central during Hong Kong Art Week from 25 to 29 March.

The depth and creativity of the artworks on display in SAF’s booth captivated visitors; with each piece interwoven with personal narratives, social critique and reflections on identity. Together, the works offered a glimpse into the experiences shaping Hong Kong’s youth. Click here to view the shortlist!

Ho Ying’s acrylic painting titled Shelter? was awarded the Judges Prize. The work reflects how a sanctuary within the home becomes unsettling when stress strips this final place of refuge of its former sense of tranquillity. She received HKD8,000, with a further HKD20,000 being donated to Pooi To Middle School as a grant for the wider benefit of all students and their creative pursuits.

Man Hei’s Modern Instructions of Women, which employs acrylic on canvas and polymer clay, attracted the most public votes, either in person at the exhibition or online. The work appropriates the format of a Chinese calendar to reinterpret traditional women’s roles. She received HKD4,000, with Po Leung Kuk Tang Yuk Tien College receiving a grant of HKD10,000.

Both winners will now go through to the Global Students Prize, which brings together the winning artworks of all SAF’s Students Prize competitions around the world to select a Global Judges Prize winner and Global Public Vote Prize winner.

Selected artworks were available for bidding through a charity auction, which raised over HKD40,000 for the students and SAF’s Make It Better programme in Hong Kong.

Congratulations to the winners and all the finalists. We were delighted to have the opportunity to celebrate at Art Central, our Venue Partner. And thank you again for our judging panel of Janet Fong, curator and Assistant Professor at the Academy of Visual Arts at Hong Kong Baptist University, Sharon Cheung, journalist, curator and Director of SC Gallery, Ngai Wing-Lam, a Hong Kong-based artist, and SAF Founder and Chairman Howard Bilton.

Through its global network of student awards, SAF continues its mission to celebrate the importance of art in the education system. With prizes now established in 13 countries, its exhibitions not only showcase the creative energy of each region but also reaffirm SAF’s longstanding commitment to nurturing young voices.

Stay tuned for the announcement of the 2026 Sovereign Asian Art Prize finalists! Follow us on Instagram so you don’t miss it.

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1. What is a Trust?
A trust is a way of managing assets (money, investments, land or buildings) for people. It is an arrangement, recognised under common law, by which property or assets are transferred from one person (the ‘settlor’) to another person (the ‘trustee’) to hold the property for the benefit of a specified list or class of persons (the ‘beneficiaries’).

A trust can be created solely by verbal agreement but it is usual for a written document (the ‘trust deed’) to be prepared. This evidences the creation of the trust, sets out the terms and conditions upon which the trustees hold the trust assets and outlines the rights of the beneficiaries.

Unlike a company, a trust is not a legal person; it is a relationship. The practical advantages of a trust are gained from the distinction that is drawn between the formal or legal owner of property, the trustee, and those people that have the use or benefit of the property, the beneficiaries.

2. Who should set up a Trust?
APAC Wealth Creators – Asia’s Economic Growth in 2025 proved unexpectedly resilient, weathering tariffs and uncertainty, and will remain the biggest driver of global growth, contributing about 60% this year and next. The shock from trade tensions has been cushioned by a front-loading of exports ahead of new levies, stronger-than-expected investment in artificial intelligence, ongoing supply-chain reconfiguration within the region, and policy easing in some countries.

2025 saw Asia Pacific IPO proceeds surge to USD90 billion (+73% year-on-year), with Hong Kong/China and India accounting for over half of the region’s activity. Hong Kong led with 32% of IPO volumes, while India posted its highest annual tally ever at 25%, delivering five USD1 billion+ IPOs.

According to McKinsey analysis, between 2023 and 2030, ultra-high-net-worth (UHNW) families with personal financial assets more than USD50 million and high-net-worth (HNW) families with personal financial assets between USD1 million and USD50 million in the Asia–Pacific region are set to undergo an intergenerational wealth transfer estimated at USD5.8 trillion. UHNW families are expected to account for about 60% of the total wealth transfer.

With many such families in the Asia-Pacific region owning operating businesses, effective succession planning is even more essential for preserving wealth and ensuring a smooth transition of assets across generations.

3. Why would you set up a Trust?
Trusts are set up for a number of reasons, including:

• Wealth preservation – to control and protect family assets.
• Succession planning – to pass on assets while a settlor is still alive.
• Estate planning without public probate – to pass on assets when a settlor dies (a ‘will trust’) with enhanced confidentiality.
• Business continuity – allows a business to continue functioning normally, while beneficiaries continue receiving benefits from the business.
• Avoidance of forced heirship laws.
• Tax efficiency and futureproofing.
• Asset protection – litigation/divorce.
• Caring for vulnerable beneficiaries – minors or incapacitated.
• Family governance.
• Philanthropy.
• Legacy planning.

When assets are spread across different countries, a trust can eliminate the complexities of managing multiple probate processes across different jurisdictions, which can be time-consuming and costly, with each country’s legal system imposing its own requirements. The trustees can immediately act to distribute the assets according to the deceased’s wishes.

Trusts also provide a centralised asset management platform, allowing settlors to consolidate their global assets under one legal structure. This simplifies the management of these assets, reduces administrative burdens and ensures they can be managed and distributed from a single jurisdiction. It also ensures that wealth accumulated over a lifetime can be retained as one fund to accumulate further.

If the assets are centralised in a politically and economically stable jurisdiction, and denominated in hard currencies, it provides security from volatility in the home country as well as providing flexibility and potential for diversification.

Assets held in trust do not necessarily need to be liquidated upon the settlor’s death. This can be advantageous during market downturns, because the trust structure allows assets to be retained rather than sold at a loss, preserving their value and benefiting the beneficiaries in the long term.

For business owners, the trust structure is particularly effective in avoiding disruption during a generational handover of a business. By transferring ownership and control of the business into a trust, founders can ensure that the enterprise remains within the family while safeguarding it from personal financial issues, divorce or external threats.

A trust also introduces the option of professional oversight. Trustees with commercial expertise can be appointed to manage or co-manage the business alongside family members, ensuring operational competence even where successors may lack experience.

4. When should you set up a Trust?
It’s never too early. An effective succession plan enables a smooth transition of both ownership and management while maintaining segregation of business assets and personal wealth. Early leadership transition helps family enterprises stay relevant and grow as the next generation introduce new ideas while still benefiting from the older generation’s experience and guidance.

The direct transfer of business ownership via shares not only grants dividend rights but also voting control, which can create shareholder disagreements or impede business operations. Trusts, which hold the company shares, can provide a useful mechanism for separating legal ownership, control and management, and economic benefits. In this way, only family members actively involved in the business will have control over business decisions, but passive family members will still receive economic benefits through trust distributions.

Alternatives to intergenerational succession of the business – a sale or public offering – may provide a more suitable path forward if the next generation is keen to pursue interests outside the business. It is critical to establish an estate plan early in the sale or IPO planning phase because the opportunities will generally diminish as a deal moves toward closing.

Families should also consider succession plans for their personal wealth, which may be very different from the succession plans for business assets, especially if there may be plans to appoint heirs to be business successors.

Families may also choose to consolidate their financial asset holdings through a private investment company (PIC) or family office that allows family members to be involved through bespoke shareholding and directorship structures. Holding the PIC through a trust can be useful to help address issues like incapacity planning, tax planning, wealth management and protection, and confidentiality.

5. Where should you set up a Trust?
When selecting the best offshore jurisdiction for establishing a trust it is important that it should offer:

• Politically, economically and socially stable
• A strong tradition of enforcing trusts.
• An English common law system.
• An established reputation for trust business.
• Modern trust legislation, including contemporary trust concepts.
• Tax neutrality – low or no taxation for trusts.
• Good international reputation that is aligned with your family’s long-term interests.
• International connectivity.
• Privacy and confidentiality.
• Deep professional sector.
• Access to global investment opportunities.

Hong Kong and Singapore score highly in all these areas and both have the added benefit of a convenient location in Southeast Asia. However, there can be many reasons – security, confidentiality, discretion, legal protections – to position your trust further away from your place of residence or doing business. Sovereign generally recommends Guernsey, the Isle of Man, Gibraltar, Cyprus, Malta and Mauritius as among the best available trust jurisdictions.

Guernsey’s proximity to London and continental Europe offers a powerful strategic advantage, while modern legislative and regulatory framework accommodates a wide range of structures that can be tailored to a client’s specific requirements, including:

• Trusts and private trust companies (PTCs): Discretionary trusts, non-charitable purpose trusts and charitable trusts support succession planning and asset protection, while customary protective mechanisms (e.g. reserved powers and protector roles) are well understood and respected
• Foundations and private trust foundations (PTFs): These structures provide legal personality and offer an alternative to trusts for families from civil law countries seeking more control than a traditional trust provides. Governance can be tailored to the family’s unique requirements
• Corporate/investment vehicles: Guernsey supports private investment funds, family limited partnerships and family investment companies (FICs) to hold investments in a corporate structure. This allows families to crystallise their investment strategies into entities they control, which is especially useful for ESG or impact portfolios
• Custom hybrids: Families often create bespoke structures made up of more than one trust or entity, with each holding different asset types or benefitting different parts of a family.

6. Other questions you need to ask
Families today are facing increasingly complex questions around how to protect their wealth, preserve their values and empower future generations. Trusts offer a powerful solution, but before setting up any trust it’s essential to ask the right questions.

• Who do you wish to ultimately benefit from the Trust and under what circumstances?
• How much control are you willing to give up now to ensure stability for tomorrow?
• Are you clear about whether the trust is purposed for your own interests, for current or future family members or for charitable causes?
• Is the trust purely a financial mechanism, or do you also want to also encourage education, hard work, entrepreneurship, philanthropy, family life or family leadership?
• Have you considered issues of fairness and managing expectations among heirs?
• Are you truly comfortable letting trustees make decisions according to the trust deed and any guidance you have provided by way of a letter of wishes?
• Does the trust allow for mechanisms like protectors, powers of appointment or the ability to amend?
• Do you understand the different types of Trust – ‘fixed interest trusts’, discretionary trusts, reserved powers trusts and purpose trusts)
• Who should serve as the trustees of the Trust?

Choosing the right trustee(s) is a crucial part of setting up a trust because trust law imposes strict obligations and rules on trustees. Corporate trustees that are appropriately licensed, like Sovereign, are held to a standard of providing responsible ethical conduct, careful exercise of discretionary powers, competent investment management, expertise in tax and legal matters, and continuity in the administration of the trust for its duration.

As the Asian region continues to grow as a hub for HNWIs, the need for sophisticated wealth management and preservation strategies has never been greater. Sovereign Group is well-positioned to assist HNWIs and families in navigating the complexities of wealth management and legacy planning in this dynamic region.

Sovereign has more than 30 years’ experience of setting up and managing various types of trust around the world. We offer trustee, wealth management, succession planning and tax advisory services to internationally mobile families and entrepreneurs, with an emphasis on cross-border asset management and family governance.

Sovereign is fully licensed to act as professional trustee in Singapore and Hong Kong, Guernsey, the Isle of Man, Gibraltar, Cyprus, Malta and Mauritius.

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Financial Secretary Paul Chan delivered Hong Kong’s 2026-27 Budget on 25 February. Themed as ‘Driving High‑quality, Inclusive Growth with Innovation and Finance’, the Budget is focused on sustaining growth momentum, advancing long‑term capability building and positioning Hong Kong to capture new opportunities.

Hong Kong’s economy grew by 3.5% in 2025, marking the third consecutive year of expansion, supported by strong external trade and a recovery in domestic demand. It is forecast to grow by 2.5%-3.5% in the year ahead, while the headline inflation rate is expected to remain below 2%.

Chan said a buoyant economy and capital market had driven higher tax revenues, while a reinforced fiscal consolidation programme had helped public finances improve sooner than expected. To preserve the SAR’s simple and low-rate tax regime, the government will introduce and extend a series of modest tax relief measures for households in 2026, along with a package of preferential tax policies for targeted businesses and industries.

To raise revenue, the government is to raise stamp duty rates from 4.25% to 6.5% on high-value residential property transactions valued above HKD100 million (USD12.8 million). It will also continue to implement the OECD Pillar Two Global Minimum Tax, which has been in force since financial years (FYs) starting on or after 1 January 2025.

Under the rules, multinational enterprise (MNE) groups with consolidated annual revenue of at least €750 million are required to pay top-up taxes if their effective tax rate falls below the minimum 15%. According to Chan, implementation of these rules is expected to bring in an additional HKD15 billion (USD1.9 billion) in tax revenue per year starting from FY 2027-28.

To align Hong Kong’s economic future with its development goals, the focus of investment in the Budget was in the innovation, artificial intelligence and international financial sectors, with initiatives including:

• Asset and Wealth Management – to increase the number of single-family offices in Hong Kong, which currently exceeds 3,300, and attract funds to set up in Hong Kong, the HK government will introduce an amendment bill in the first half of this year to enhance the tax regime and expand the scope of ‘fund’ to cover specific funds-of-one, as well as classifying digital assets, precious metals, specified commodities as qualifying investments eligible for tax concessions; it will also legislate to enable privatisation of Real Estate Investment Trusts (REITs) and to amend the law next year to provide stamp duty waiver for transferring non-residential properties into REITs seeking to list.
• Corporate Treasury Centres (CTCs) – the HK government to relax criteria for stamp duty relief for intra-group transfer of assets, applicable to instruments signed from Budget day. Further measures to strengthen Hong Kong as a base for CTCs to be announced in the middle of this year, including additional tax incentives, greater flexibility for CTCs and associated companies, and the introduction of a pre-approval mechanism.
• Company Re-domiciliation Regime – with the approval of 22 re-domiciliation applications since commencement of the regime in 2025 and a further 20 applications being processed, the government will step up publicity to attract more enterprises to establish in Hong Kong.
• Development of Digital Assets – CMU OmniClear, which operates Hong Kong’s central securities depository (CSD) for fixed-income, to establish digital asset platform in the year to support issuance and settlement of digital bonds. The government will introduce a bill this year to establish licensing regimes for, among others, digital asset dealing and custodian service providers.
• Intellectual Property Trading – the HK government to introduce legislation this year for ¬tax deduction arrangements for capital expenditure in purchasing intellectual property; to invest HKD28 million in the Hong Kong Technology & Innovation Support Centre for patent evaluation and implement a two-year Pilot Patent Valuation Support Scheme; to invest HKD52 million for Intellectual Property Academy on two-year pilot.
• Trade Centre – the HK government to introduce amendment to tax law this year for preferential policy packages, including preferential arrangements on land grants, financial subsidies and tax incentives. Preferential tax rates at half rate or 5%; to set up Advisory Committee on Tax Policy; to set up cross-sectoral professional services platform to support Mainland enterprises expanding overseas using Hong Kong as a base; and to invest HKD100 million to attract international, large-scale exhibitions with new elements.
• Mutual Market Access – the HK government to expedite the launch of Chinese Government Bond futures in Hong Kong, inclusion of REITs in mutual access, and inclusion of RMB trading counter under Southbound Stock Connect.
• Driving AI+ Development – the HK government to establish Committee on AI+ and Industry Development Strategy to transform industries; the Hong Kong AI Research & Development Institute to operate in second half of year to support R&D and transformation of outcomes.
• Small and Medium-sized Enterprises (SMEs) – the HK government to inject a further HKD200 million into the Dedicated Fund on Branding, Upgrading and Domestic Sales (BUD Fund) to assist Hong Kong-based companies capitalise on opportunities in the Chinese Mainland and ASEAN countries, and raise the funding ceiling of ‘Easy BUD’ to HKD150,000 per application; to increase the total loan guarantee commitment to enterprises through the SME Financing Guarantee Scheme by HKD20 billion and extend the application period for the 80% Guarantee Product to the end of March 2028 and the application period for the principal moratorium arrangement to mid-November this year.
• Aviation, Shipping and Logistics – the HK government to launch a Future Innovative Logistics Acceleration Scheme this year to enhance interconnectivity of logistics data; to introduce legislation this year to enhance tax-concession measures for maritime services industry, provide half-rate tax concession to eligible commodities traders, revamp existing ship registration arrangements, extend current arrangements under Air Transhipment Cargo Exemption Scheme.
• Supporting Emerging Industries – the HK government to set up HKD10 billion I&T Industry-Oriented Fund to begin operation this year to channel market capital into strategic and emerging industries, including life and health technology, AI and robotics, and future industries; to review and enhance tax arrangements for R&D expenditures; to push for R&D and applications in embodied AI, quantum technology and new materials; to direct Office for Attracting Strategic Enterprises (OASES) to attract aerospace enterprises and Stock Exchange of Hong Kong (HKEX) to review listing requirements for aerospace enterprises; Hong Kong Investment Corporation (HKIC) and enterprises to establish Hong Kong RISC-V Alliance, forging collaboration among industries, academia and the investment sector in microelectronics.
• Gold Trading – the HK government to explore tax concessions for eligible institutions conducting gold trading and settlement in Hong Kong.
• New Industrialisation – the HK government to launch a New Industrialisation Elite Enterprises Nurturing Scheme this year to support high-growth enterprises; to allocate HKD220 million to establish the first national manufacturing innovation centre outside the Mainland at Yuen Long InnoPark, which will be led by the Hong Kong Microelectronics Research and Development Institute and focus on semiconductor R&D.
• Northern Metropolis for I&T – the HK government to set aside HKD10 billion each for the Hetao Hong Kong Park, the San Tin Technopole and the Hung Shui Kiu Industrial Park to accelerate the megaproject through the government’s partnership with developers and tech enterprises.

The government has launched a public consultation on the implementation of the OECD’s new Crypto-Asset Reporting Framework (CARF) and related amendments to the Common Reporting Standard (CRS 2.0) for the reporting and automatic exchange of information in respect of crypto-assets. It plans to complete the necessary legislative amendments in 2026 to implement the CARF rules to be effective on 1 January 2027 and the CRS 2.0 rules on 1 January 2028.

The government is committed to expanding Hong Kong’s network of Double Taxation Agreements, which currently comprises 55 agreements, including those signed last year with Jordan, Maldives, Norway and Rwanda.

In view of the evolving global tax environment, the Financial Secretary is to establish and chair an Advisory Committee on Tax Policy to gather views from commercial, industrial and professional sectors, so that Hong Kong’s tax policy can reinforce economic development.

2026 marks the first year of China’s 15th Five-Year Plan. Chan announced that Hong Kong will, for the first time, formulate its own local five-year plan, indicating that the region’s development trajectory will align more closely with national policy priorities in the coming years.

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The UK Autumn Budget, presented on 26 November 2025, introduced a number of measures that will have an impact on UK and international private clients with interests offshore. It followed the wholesale dismantling of the longstanding non-domiciled and the ‘protected trust’ tax regimes from the UK tax system last April.

As of 6 April 2025, the UK government replaced ‘domicile’ as a connecting factor for liability to applicable UK taxes, including inheritance tax (IHT), and adopting a residence-based regime instead. Individuals who have been UK resident for at least 10 out of the past 20 tax years are classified as a ‘Long-Term Resident’ (LTR) and exposed to IHT on their worldwide assets.

To ensure that LTRs do not escape tax obligations immediately upon leaving the UK, the legislation includes a ‘tail’ provision. This means that, if the LTR dies within the residence tail period, their worldwide estate will still be subject to UK IHT for up to 10 years after they cease to be a UK resident.

The length of the tail will depend on the duration of the individual’s residence in the UK. The minimum length of the tail is three years, which applies to individuals who have been UK resident for 10 to 13 of the past 20 UK tax years. The length of the tail increases by one tax year for each additional year of residence, up to a maximum of 10 years.

Individuals who do not meet the criteria for LTR status generally remain liable for IHT on UK-based assets only. This aligns with the previous system, under which non-UK domiciled individuals were taxed on UK situs assets but non-UK assets were out of scope for IHT purposes.

A new Foreign Income and Gains (FIG) regime was also introduced for people moving to the UK for the first time or after living abroad for at least 10 years. Foreign income and gains are tax-free for the first four years in the UK but are then subject to standard UK tax rules.

Under the old rules, trusts set up by non-doms were free from UK IHT forever. This shelter was removed. Once the settlor is classified as an LTR, the trust falls within the UK’s ‘10-year charging regime’, which imposes a tax charge of up to 6% every 10 years or when assets leave the trust – even if the settlor is excluded as a beneficiary of the trust.

The recent Autumn Budget announced a cap for these charges: for certain trusts created before 30 October 2024, all charges for each 10-year period – including the 10-year charge and any exit charges – will be limited to £5 million. Unfortunately, the £5 million cap applies only per trust, so multiple smaller trusts settled by one settlor will not get relief.

The Budget also introduced, with immediate effect, a measure to prevent the possibility of avoiding the exit charge on non-UK assets held in trust when a settlor ceases to be an LTR by converting non-UK relevant trust property into UK-situs assets immediately prior to the exit.

From 6 April 2026, it will also no longer be possible for an individual who is not an LTR to shelter UK agricultural property from IHT by holding it via a non-UK entity. It will now be subject to the same IHT treatment that was introduced for residential property under the IHT anti-enveloping legislation in 2017. UK commercial property can still be sheltered by non-LTRs using an offshore structure.

As we have previously highlighted, the main beneficiaries of all these changes to the UK’s IHT regime, are long-term UK expatriates. Before 6 April 2025, the worldwide estates of individuals with a UK domicile of origin remained subject to IHT unless they had succeeded in shedding their domicile of origin and acquiring a new domicile of choice in a distinct jurisdiction.

This involved moving to a country and forming a permanent or indefinite intention to remain there, which created difficulties for globally mobile individuals who did not settle in any one location. It was not possible to obtain a domicile ruling from HMRC, so the IHT position of many British ex-pats was uncertain.

With the UK’s new statutory residence test in place, British ex-pats have certainty as to their residence status. If they have at least 10 tax years of non-UK residence, they can set up an overseas excluded property trust (offshore trust) without any risk of an upfront IHT charge. This may be advantageous for asset protection or succession planning, as well as managing assets for future generations.

Furthermore, subject to the tax regime in their country of residence, gains and income accumulated within the trust may not be exposed to personal taxation. Many countries, even EU states such as Italy, Greece, Cyprus and Malta, have non-domicile tax regimes that only impose tax on income and gains that are either sourced locally or are remitted to the country of residence. Income and gains that remained within an offshore trust would not therefore be subject to taxation.

Consideration will only need to be given to the IHT treatment of the trust if the expat returns to live in the UK. Previously, an individual with a UK domicile of origin in the UK who then became UK resident was immediately treated as domiciled in the UK, and taxable on their worldwide income or gains. Now their foreign assets will not be in scope of IHT until such time as they become classified as an LTR, and they can also benefit from the new FIG regime for four years.

British expats living abroad can take advantage of this favourable new regime to return to the UK for a short period, for business reasons, to care for elderly parents or to cease being resident in another jurisdiction for foreign tax planning reasons. And, because they can clearly identify their first year of UK residence, they can take the steps necessary to cease UK residence again, if and when desired.

Please contact Simon Denton sdenton@sovereigngroup.com or David Griffiths dgriffiths@sovereigngroup.com at Sovereign UK for further information or to arrange a non-obligatory call or virtual meeting to examine your circumstances and requirements.

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The UK and the European Union jointly published, on 26 February, the draft legal text of the UK-EU treaty to govern Gibraltar’s post-Brexit relationship with the EU. Now awaiting ratification by the respective parliaments, the expected implementation date is 10 April 2026 when the EU’s new Electronic Entry/Exit System (EES) is scheduled to go into fully operation.

The EU-UK Agreement in respect of Gibraltar will complete the legal framework of the relations between the EU and the UK. Gibraltar was not included in the scope of the EU-UK Trade & Cooperation Agreement (UK-EU TCA), which was signed in 2020 and has been in force since May 2021.

The main objective of the EU-UK Agreement in respect of Gibraltar is to remove all physical barriers on persons and goods circulating between Spain and Gibraltar, while fully safeguarding Gibraltar’s sovereignty, the EU’s Schengen area, Single Market and Customs Union, and the autonomy of key British military facilities.

The government of Gibraltar formed an integral part of the UK’s negotiating team at every stage of the negotiations and has given its full support to the Agreement.

There is no direct application of EU law to Gibraltar through the Agreement or enforcement role for the Court of Justice of the European Union in Gibraltar. There are, however, provisions confirming how Gibraltar’s domestic legal system will incorporate EU law where alignment is required and confirms it will be enforced by Gibraltar’s own authorities and courts.

Customs Union

The Agreement creates a customs union between the UK and the EU in respect of Gibraltar. Gibraltar is not joining the EU Customs Territory; it is entering into a bespoke arrangement that enables the free circulation of goods between Gibraltar and the EU without customs checks at the land frontier.

Gibraltar businesses will be able to access the EU Customs Union market. They will be able to sell to customers across the EU, and EU consumers will be able to buy from Gibraltar, without customs barriers. All goods sold on in Gibraltar must be EU compliant, subject to a three-month transition period, from 10 April, for goods already on the market in Gibraltar.

Transaction Tax

Gibraltar’s current import duty regime will be replaced by a new Transaction Tax (TT), which will be applied initially at a transitional standard rate of 15%. This rate will be increased to 16% for year two and for year three will be aligned to the lowest standard rate of VAT being applied in the EU, which is currently 17%.

The TT will be levied at the point of importation or manufacture, or when goods are brought out of bond, rather than applied at the point of sale. The tax rate will be applied to the customs value of the goods. All revenue from the TT and excise duty will be charged in Gibraltar.

A reduced rate of 5% and a super reduced rate of 0% will apply to certain goods as listed in Annex III of the EU VAT Directive. The choice will be determined by that list. Bunkering fuel, ship supplies and goods that are not to be put up for sale in Gibraltar will be exempt from the TT and from excise duties.

EU minimum excise rates will apply to tobacco products and alcoholic drinks. By 10 April 2029, excise duties for fuel, alcohol and tobacco in Gibraltar are to be within 6% of the equivalent Spanish excise rates.

If goods are imported from the UK that do not meet the UK-origin rules contained in the UK-EU Trade & Cooperation Agreement, EU Common External Tariff rates will be applied. The TT would also be applied if the goods are to be placed on the market in Gibraltar.

Gibraltar businesses purchasing wholesale goods from suppliers in the EU for sale in Gibraltar should not pay VAT but will pay the TT on importation, or if applicable, when the goods leave a bonded warehouse in Gibraltar. Individuals in Gibraltar purchasing goods in the EU will pay VAT and will not be able to reclaim this. However, they will not pay the TT in Gibraltar on those goods.

Movement of Persons

The Agreement establishes a new system for the movement of persons, designed to remove all routine immigration checks and physical barriers at the land border while maintaining stability and security across Gibraltar and the Schengen Area.

Gibraltar will remain outside both Schengen and the EU, but Schengen border rules will apply at its external border under a tailored arrangement between the UK and EU. The Agreement provides that all necessary immigration checks will take place at Gibraltar’s airport rather than at the land border.

Gibraltar residents can stay in any Schengen EU member state for 90 days in any 180 without requiring a visa. EU citizens and third country EU residents can stay in Gibraltar for 90 days in any 180 without requiring a visa. Visas may be required for anyone carrying out a paid activity, but exemptions include business travel, sportspersons and artists, journalists and intra-corporate trainees.

Residence Permits and Visas

Gibraltar residence will be evidenced by an ID card or residence permit. Gibraltar residents are exempt from passport control and both the Entry/Exit System (EES) and the obligation to register under the European Travel Information & Authorisation System (ETIAS). Gibraltar residents also have the right to transit through Schengen EU Member States to return to Gibraltar unless specifically excluded.

Under Article 45, a legal right to reside in Gibraltar will be subject to a person holding a valid identity card or residence permit issued in Gibraltar by the UK competent authorities on the condition of the person having been resident in Gibraltar for a continuous period of at least ten years immediately prior to the date of application for the card or being able to demonstrate a ‘genuine connection’ with Gibraltar. A ‘genuine connection’ is defined as being “able to demonstrate actual and regular physical presence in Gibraltar over an appropriate period of time or on the basis of other objective and verifiable criteria”.

Under Article 45 (6) these conditions will not be met “on the basis of predetermined investments having been made in Gibraltar’s economy or real estate; or as a result of any predetermined financial payments having been made to the Gibraltar authorities.”

The issue or renewal of residence permits for foreign nationals seeking to reside in Gibraltar will remain, under Gibraltar law, exclusively a matter for the Gibraltar authorities subject to the conditions in Article 45. However, the grant of residence permits will be subject to consultation with the Schengen authorities in respect of issues of public health, public security or public policy. This is to ensure that residence permits that will allow access to the Schengen area are granted in line with key provisions of EU law.

Nationals of third countries required to be in possession of a short stay visa to enter and stay in the EU will also be required to be in possession of a visa to enter and stay in Gibraltar. Nationals of third countries exempt from the requirement to be in possession of a short stay visa to enter and stay in the EU will not be required to be in possession of a visa to enter and stay in Gibraltar.

Frontier Workers

The Agreement defines the rights of cross-border workers, who live in Spain and work in Gibraltar or vice versa, to provide a secure framework for employment, supporting the integrated labour market between Gibraltar and the surrounding region. It provides mechanisms for social security coordination so that contributions, entitlements and benefits can be administered without disruption.

Under Article 291, frontier workers are defined as either EU citizens legally residing in the Kingdom of Spain or UK nationals legally residing in Gibraltar who pursue an economic activity as an employed person (or as a self-employed person under the respective UK and Spanish laws) either in Gibraltar or in Spain and who return at least once a week to Spain or to Gibraltar, respectively.

Frontier workers’ rights are also extended to their family members – spouses, registered partners, dependant children under 21, and dependant direct relatives – provided they also legally reside in Spain or Gibraltar respectively.

Law Enforcement and Judicial Co-operation

The Agreement includes a law enforcement and judicial co-operation framework, modelled on the UK–EU TCA. It provides for reciprocal intelligence sharing, operational cooperation between the Royal Gibraltar Police and Spanish law enforcement, and joint protocols for cross-border security.

Gibraltar officials will always accompany Spanish officials in any joint operation on Gibraltarian soil. The Agreement also sets out the conditions for arrest warrants and extraditions as well as for freezing and confiscation orders, and the sharing of banking information if someone is suspected of criminality.

Standards’ equivalence

The treaty includes a ‘level playing field’ chapter, based on the UK-EU TCA but going further in certain areas. Under this framework, Gibraltar commits to maintain equivalence on labour standards, tax transparency, anti-money laundering, environmental protection, climate commitments and state aid control.

Aviation and Maritime

In addition, the Agreement contains an aviation chapter that will provide for ‘enhanced’ use of Gibraltar airport by flights between Gibraltar and EU destinations, which have previously been restricted. Only EU carriers or those authorised by the EU will be able to fly these routes. Only UK carriers or those authorised by the UK will be able to fly from Gibraltar to the UK.

A joint venture company will be established between Gibraltar and Spain to select and supervise an airport manager, which will ensure Gibraltar’s agreement for any changes. Gibraltar will incorporate a certain EU civil aviation rule into its domestic regime. The British military base at the airfield is not in scope of the Agreement.

There are further provisions covering maritime and road transport services between Gibraltar and the EU. Notably, there will be no cruise liners calling directly into Gibraltar from any third country other than the UK and the Gibraltar-Morocco ferry will cease operations.

An exemption from visa requirements under EU law will apply to civilian sea crew members when they land to board a ship or go ashore to transit to another country, and who hold a seafarer’s identity document issued in accordance with the relevant international conventions.

Cooperation Council

Finally, the Agreement creates governance structures to manage and oversee cooperation. It establishes a Cooperation Council, with both EU and UK representatives, to supervise and facilitate the application and implementation of the agreement in respect of Gibraltar. It will be co-chaired by a member of the European Commission and a UK government minister and will be supported by three Specialised Committees covering the circulation of persons, the economy and trade, and aviation.

The post The legal draft of the EU-UK Agreement in respect of Gibraltar is published appeared first on The Sovereign Group.

In recent years, Portugal has become an increasingly attractive base for freelancers working with international clients. From digital nomads settling in the Algarve to experienced consultants serving global businesses, the country offers a compelling mix of lifestyle and professional opportunity. However, while foreign companies often benefit from simplified arrangements when engaging Portuguese freelancers, the compliance burden rests firmly on the individual service provider.

Understanding tax and social security obligations is therefore essential for any freelancer operating from Portugal, particularly when working across borders.

Independent Status Under Portuguese Law

Portuguese freelancers are legally classified as independent service providers rather than employees. This distinction is crucial. In a genuine freelance relationship, the responsibility for tax compliance, invoicing, and social security contributions lies entirely with the freelancer, not the client.

This applies regardless of whether the client is based in Portugal or abroad. For international engagements, the rules do not disappear, they simply shift entirely onto the individual.

Personal Income Tax (IRS)

Freelance income in Portugal is taxed under Category B of the Personal Income Tax (IRS) system, which applies to business and professional income.

For those considered tax residents in Portugal, taxation is based on worldwide income. This means that even if a freelancer works exclusively with foreign clients and receives payments from overseas, that income must still be declared in Portugal.

To remain compliant, freelancers must:

• Register their activity with the Portuguese Tax Authority before starting work
• Issue invoices that meet Portuguese legal requirements
• Submit an annual IRS return declaring all income
• Pay income tax at progressive rates based on total earnings

The way taxable income is calculated depends on the chosen tax regime. Many freelancers operate under the simplified regime, where only a portion of gross income is considered taxable. This system assumes a standard level of expenses, removing the need for detailed accounting.

Alternatively, freelancers with higher earnings or more complex activities may opt for organized accounting, where actual expenses are deducted.

In addition, in some cases freelancers are required to make advance tax payments on account throughout the year, helping spread the tax burden and avoid large payments of IRS at year-end. 

Withholding Tax Considerations

Withholding tax rules depend largely on where the client is based.

When services are provided to Portuguese companies, those companies are generally required to withhold tax at a rate of 23%. However, exemptions may apply—particularly for freelancers with lower income levels who can opt for exemption on withholding tax.

For international work, the situation is different. When the client is a foreign company with no permanent establishment in Portugal, there is typically no withholding tax applied at source. In these cases, the freelancer is fully responsible for declaring and paying the appropriate tax in Portugal.

If foreign tax is withheld abroad, double taxation treaties may allow the freelancer to claim a tax credit in Portugal, provided the legal requirements are met. 

VAT Obligations

Value-added tax (VAT) is another key area of responsibility.

Freelancers must register for VAT purposes before starting their activity unless they qualify for an exemption (usually based on low turnover thresholds).  Once registered, they are required to:

• Issue invoices compliant with Portuguese VAT rules
• Submit periodic VAT returns (monthly or quarterly)
• Pay any VAT due within the required deadlines

For cross-border services, when services are supplied to business clients established in another EU country or outside the EU, the general rule is that VAT is due where the client is established. In some cases, Portuguese VAT is not charged, and/or the reverse charge mechanism applies.  Even so, the freelancer must correctly indicate the applicable VAT treatment on the invoice and report the transaction in their VAT return.

Failure to comply with VAT rules can lead to penalties, interest charges, and unnecessary administrative complications, making accuracy and consistency essential.

Social Security Contributions

In addition to tax obligations, freelancers in Portugal must register with the social security system as self-employed workers.

Their responsibilities include:

• Submitting quarterly income declarations
• Paying monthly social security contributions

Contributions are calculated based on 70% of gross income, with a standard rate of 21.4%. This system ensures access to benefits such as healthcare and pensions.

New freelancers typically benefit from a 12-month exemption period when starting their activity. During this time, contributions are not mandatory, although voluntary payments can be made to maintain coverage.

As with tax obligations, non-compliance can result in fines, interest, and enforcement proceedings. Importantly, in a genuine freelance relationship, foreign clients have no responsibility for these contributions.

Practical Compliance Tips

For Portuguese freelancers—especially those working with international clients—staying compliant requires careful attention to detail. Key best practices include:

• Ensuring proper registration with both the Tax Authority and Social Security
• Issuing legally compliant invoices for all services
• Understanding when withholding tax applies
• Submit annual income tax returns and periodic VAT returns on time.
• Meeting all payment deadlines for tax and contributions 

Even when working exclusively with foreign clients, Portuguese freelancers remain fully subject to Portuguese tax on their worldwide income. Cross-border situations may involve additional complexity, particularly regarding double taxation relief and VAT reporting. 

A Balanced Perspective

While foreign companies benefit from a lighter compliance burden in a genuine freelance arrangement, the Portuguese freelancer carries significant individual tax and social security responsibilities.

Proper registration, accurate reporting and timely payment of taxes and contributions are essential to avoid penalties and ensure full compliance with Portuguese law. 

Sovereign – Consultoria Lda can not only assist you with obtaining your residency in Portugal but can provide further guidance or professional support to ensure that you are fiscally compliant.

Sovereign – Consultoria Lda
Parque Empresarial Algarve
Bloco 8 Porta 21
8400-431 Lagoa, Algarve

Tel: +351 282 340 480
Email: serviceinfo@SovereignGroup.com
Website: SovereignGroup.com

The post Tax and Social Security Obligations of Portuguese Freelancers: A Practical Overview for International Engagements appeared first on The Sovereign Group.

Located in Central America, the Republic of Panama is a politically stable nation characterised by its diverse population. The country features a distinctive combination of contemporary urban living in Panama City and is also known for its rich biodiversity and various ecosystems, including tropical rainforests, cloud forests, and numerous islands in the Atlantic and Pacific Oceans.

As the vital junction between the Pacific and Atlantic Oceans, Panama’s high-income, service-oriented economy has experienced sustained economic growth driven by the Panama Canal, logistics and finance. Regarded as the strategic link of the Americas, Panama pro-investment and tax-efficient policies have made it a leading choice for global investors and businesses.

Panama provides new residents with an elevated standard of living, supported by advanced infrastructure, exceptional educational and healthcare institutions, with a low cost of living. Panama offers a fully dollarised economy that is aligned with US financial markets and supports a sophisticated banking and corporate services ecosystem.

As a result, in recent years Panama has emerged as a leading location for primary or alternate residency that enables investors, retirees and expatriates to easily secure permanent residency and, should they choose, to pursue citizenship after five years.

Panama Qualified Investor Permanent Residency Programme

The Panama Qualified Investor Permanent Residency Programme, or ‘Golden Visa’, provides international investors and their qualifying dependants, the right to live, work and study in Panama, with additional benefits including:

• Fast Track Permanent Residency Status – applications are typically processed within 30 to 45 days of submission.
• Option to include Qualifying Dependants – the main applicant can include their spouse and children under the age of 25 who are unmarried and in education.
• Multiple Investment Options – to suit most investor profiles.
• Minimal Stay Requirements – permanent residents are required to visit Panama at least once every 24 months to maintain their residency status.
• Strategic location for business – Panama offers good access to North, Central and South America.
• Significant personal and corporate tax benefits – Panama operates a territorial tax system such that income that does not arise in Panama, such as foreign-source income, is not subject to tax in Panama.
• Pathway to Citizenship – Panamanian residents qualify for citizenship after five years of legal residency.

Qualifying Investments

The Panama Qualified Investor Permanent Residency Programme offers three qualifying investment options:

1. Investment of USD300,000 in qualifying local real estate.
2. Investment of USD500,000 in securities listed on the Panama Stock Exchange BVPSI Index.
3. Deposit of USD750,000 with a local licensed banking institution.

To retain permanent residency status, investments must be maintained for at least five years.

 Territorial Tax System

Panama applies a territorial tax system, meaning individuals and corporations are not liable to taxation on foreign assets or foreign-source income. Key aspects of Panamanian taxation include:

• Zero Tax on Foreign Income – income generated, and assets held outside of Panama are not subject to tax in Panama.
• Foreign Capital Gains – capital gains from the sale of foreign assets are generally not subject to tax in Panama.
• Foreign-Sourced Dividends – dividends distributed from foreign-source profits are subject to a lower rate of 5%.
• No Wealth or Inheritance Tax – Panama does not levy global wealth, inheritance, gift or estate taxes.
• Local Bank Interest – interest earned on savings accounts or time deposits held in Panamanian banks is exempt from income tax.

Planning and Implementation

Working with professional local services partners, Sovereign can provide clients with comprehensive advice and support throughout the residency application preparation and submission process. Depending upon your chosen investment route, this may include:

• Introductions to qualifying investment providers.
• Application preparation and processing.
• Immigration meeting coordination and support.
• Assistance with identifying suitable investment or rental property.
• Setting up a company.
• Establishing local bank accounts (if required).
• Tax efficient planning and structuring.

International Mobility, Private Client and Corporate Services

Sovereign works closely with applicants during each stage of the planning and implementation process. When combined and managed correctly, the following Sovereign Group services enable individuals and families to develop and implement a comprehensive, flexible and tax efficient international Mobility, Private Client and Corporate Service strategy:

• International residency, tax residency and citizenship planning.
• International corporate establishment and management.
• Personal and corporate banking.
• Tax planning.
• Trusts and foundations.
• Estate and succession planning.
• International retirement plans.
• Wealth management.
• International life and medical insurances.
• Yacht and Aircraft registration and management Services.

Strategies are developed and implemented in accordance with each client’s specific needs. Comprehensive quotations will be provided during the planning process.

Contact Sovereign for further information

The Sovereign Group’s global network of offices, experienced client advisers and professional services partners ensures it is well-placed to assist, advise and support individuals, families, businesses and their advisers to plan, implement and manage their assets, as well as to unlock the potential of benefits of alternative residence or citizenship.

For further information or to discuss your or your clients’ requirements, please contact Ceri Pratley, Head of Residency & Citizenship Services.

The post Panama – a prime Tax Efficient location for Primary or Alternative Permanent Residence appeared first on The Sovereign Group.

The world seems to have entered an era of permanent upheaval. Pandemics, geopolitical conflicts, trade barriers, travel and supply chain disruptions, safety and security disturbances, volatility around energy prices and the availability of materials, have created unprecedented uncertainty.

The relative predictability that once underpinned planning for many high net worth individuals and internationally active businesses has been eroded. It’s now clear that strategy is no longer about optimising a smoothly functioning world but about navigating a highly uncertain one. This added complexity will favour those who plan rather than those who react.

Expatriates are often significantly more vulnerable to financial, economic and operational volatility than local residents, due to their reliance on cross-border income, visas, currency fluctuations and lack of a stable ‘home-base’ safety net.

Data from the United Nations and Statistics South Africa’s mid-year population estimates suggest more than one million South Africans now live overseas. The UK, Australia and the US account for more than half this diaspora, according to the survey, followed by the United Arab Emirates, New Zealand and Canada.

The post Navigating uncertainty: the sensible case for South Africans to keep options open appeared first on The Sovereign Group.

The Dubai International Financial Centre has introduced a Variable Capital Company regime, establishing the first framework of its kind in the UAE. The structure allows multiple pools of assets to sit within a single corporate vehicle while remaining legally separated.

The regime follows consultation undertaken in 2025 and forms part of the DIFC’s continued development of investment and wealth structuring frameworks. It introduces a flexible platform designed to support family offices, private investment platforms, and asset managers operating in or through the Centre.

By introducing the VCC, DIFC aligns itself with several leading international financial centres that offer similar variable capital or cell-based investment structures. Jurisdictions such as Singapore, Guernsey and the Cayman Islands have long used comparable vehicles for investment funds and private capital structures. The DIFC regime now provides a domestic alternative for investors seeking similar flexibility within the UAE.

The post DIFC introduces the UAE’s first Variable Capital Company regime appeared first on The Sovereign Group.

The Malta Tax & Customs Administration issued, under Legal Notice 20 of 2026 on 23 January, the Tax Treatment of Highly Skilled Individuals Rules, which introduce a new 15% flat‑tax regime for qualifying employment income of eligible non-domiciled professionals until 31 December 2040.

The new rules, which apply with effect from 1 January 2026, are designed to consolidate Malta’s framework for attracting and retaining highly skilled professionals across key sectors and will supersede existing incentive programmes, such as the Highly Qualified Person Rules.

The 15% flat‑tax applies to qualifying employment income that is taxable in Malta and arises from employment activities carried out in Malta by individuals holding an eligible office. It will apply for an initial period of five years and is renewable for two further five-year periods, subject to conditions.

Eligibility is subject to a minimum annual gross basic salary threshold of €65,000, which increases by €10,000 every five years, and to an upper limit of €7 million per year. Individuals seeking to benefit under the Rules must also satisfy the following conditions:

• Hold the required professional qualifications and experience.
• Perform employment activities within an eligible office and sector in Malta.
• Declare all Malta‑taxable income related to the qualifying employment, including income from related entities.
• Have non-domiciled status in Malta.
• Not have previously benefitted under Article 6 of the Income Tax Act.
• Reside in suitable accommodation in Malta.
• Be in possession of a valid travel document.
• Hold private all risks medical insurance, for applicant and family.

Beneficiaries of the Rules are not entitled to claim any relief, deduction, reduction, credit or set-off of any kind in respect of their qualifying employment income taxed at the 15% flat‑tax rate and are not permitted to access Malta’s social security system.

The rules target senior and specialist roles that drive high‑value economic activity within targeted sectors, including financial services, gaming, aviation, maritime and shipping, offshore oil and gas services, healthcare and STEM (Science, Technology, Engineering and Mathematics).

The list of eligible offices is set out in the Schedules to the Rules, grouped by industry sector. Applications under the Rules may be made by individuals performing activities that qualify as eligible offices with employers that are regulated, licensed or recognised by any of the following competent authorities:

• The Malta Financial Services Authority (MFSA).
• The Malta Gaming Authority (MGA).
• The Authority for Transport in Malta.
• The Office of the Chief Medical Officer to Government.
• Malta Enterprise.

Eligible offices generally include executive roles, senior management positions and specialised functions that fall within the regulatory remit of the employer and are recognised as eligible by the relevant competent authority.

Applications under the Rules must be submitted to the relevant competent authorities and must specify the year of assessment from which the Rules should apply. Applications are to be processed within 90 days, although the competent authority may, at its discretion, request additional information or documentation.

Individuals who, as at 31 December 2025, qualified as beneficiaries under existing incentive programmes in Malta are permitted, subject to conditions, to apply to be beneficiaries under the new Highly Skilled Individuals Rules. These programmes include:

• Highly Qualified Persons Rules.
• Qualifying Employment in Innovation and Creativity (Personal Tax) Rules.
• Qualifying Employment in Aviation (Personal Tax) Rules.
• Qualifying Employment in Maritime Activities and the Servicing of Offshore Oil and Gas Industry Activities (Personal Tax) Rules.
• Senior Employees of Family Offices, Back Offices and Treasury Management Operations Tax Rules.

The post Malta consolidates special 15% flat‑tax regimes for Highly Skilled Individuals appeared first on The Sovereign Group.

Establishing an offshore corporate or wealth management structure is an extremely attractive proposition. Businesses and families develop international structures involving companies and trusts to facilitate cross-border trade and investment, to hold overseas assets, to manage succession planning, to access stable banking environments and hard currencies, or to benefit from favourable treaty networks.

But all too often individuals and businesses do not fully realise the potential value of their offshore structures. They are established to solve an immediate need and then left largely unattended. As a result, opportunities to enhance efficiency, improve governance, strengthen asset protection or adapt to changing events or conditions can be missed.

An international structure should be viewed as a dynamic framework that evolves alongside the client’s business, investments and family circumstances. At each stage of its lifecycle – from formation and operation, through to reorganisation or closure – there are opportunities to improve the benefits it can provide. It must also be capable of adapting to changes in legislation and regulation in the countries where the business operates or where the principal and other family members choose to reside.

1. The Formation Stage – building the right foundation

The formation stage is one of the most critical phases in the life of any offshore structure. The decisions taken at this point will often determine its long-term success and effectiveness.

Anyone considering the establishment of an international structure – whether a Company, Trust, Foundation, Retirement Plan or Special Licence Entity – will need to select the right structuring partner. A Trust and Corporate Service Provider (TCSP) should not simply be an administrative provider, it should also serve as a strategic advisor. Key considerations when selecting a TSCP should include:

• Jurisdictional expertise and regulatory standing.
• Experience and track record in administering international structures.
• Accessibility and quality of client services.
• Independence to operate without constraints, conflicts of interest or incentives.
• Breadth of professional networks and capabilities.

Equally important is the careful structuring of the governance documentation at the outset. One area where many structures fall short is the Shareholders’ Agreement. A well-drafted Shareholders’ Agreement should go beyond basic administrative provisions. It should consider potential future scenarios, such as:

• Shareholder disputes.
• Death or incapacity of a principal.
• Succession issues.
• Exit or buyout mechanisms.
• Deadlock resolution.
• Protection against hostile actions or competing interests.

It may be uncomfortable to consider worst-case scenarios during formation, but anticipating potential challenges at the outset will allow the structure to withstand future pressures. In our experience, disputes are far more common in structures where governance documents were treated as a formality rather than a carefully considered framework.

2. The Operational Stage – ensuring the structure continues to deliver value

Once a structure has been established and begins operating for its intended purpose, the focus should shift to ongoing engagement and strategic oversight.

Each structure is initially created with a clear purpose. For operating companies, this is typically reflected in the business plan and in the Articles of Association, which define a company’s internal rules, governing structure and purpose. For family or discretionary trusts, the objectives are generally captured in the Letter (or Memorandum) of Wishes, a confidential document outlining the settlor’s beneficiary, investment and distribution preferences to guide the trustees.

However, circumstances rarely remain static. Markets evolve, regulations change, currencies fluctuate, and family dynamics shift. A structure that was optimal at inception may require adjustments to remain effective or compliant. For this reason, continuous dialogue between clients and their management company or trustee is essential. Regular engagement ensures that potential risks can be mitigated early and that opportunities are identified as they arise.

At Sovereign, we place significant emphasis on maintaining close relationships with our clients. This includes not just formal interactions such as Board Meetings and Quarterly Reviews, but also ongoing informal engagements. Modern technology has made it so much easier to stay engaged with our clients and obtain real-time feedback on pain points, need for guidance, indications of future intentions or potential new opportunities. These interactions allow us to understand evolving client objectives and provide timely advice.

During the operational phase, a proactive TCSP should continuously look for ways to enhance the effectiveness of the structure. In our experience at Sovereign Trust (Mauritius), we frequently add value in the following areas.

• Professional introductions

Clients can sometimes require specialist expertise across multiple disciplines. Where services fall outside our direct scope, we can introduce clients to trusted professional partners (or provide a panel of options for consideration), including:

• Tax advisors.
• Specialist legal counsel.
• Audit and accounting firms.
• Banks and financial institutions.
• Insurance and risk management specialists.
• Property advisors and developers.
• Recruitment consultants.

Access to a strong professional network can significantly enhance the functionality and efficiency of a client’s structure.

• Structural ‘health checks’

Periodic reviews of a structure often reveal opportunities for improvement. Changes in a client’s residency, regulatory developments or evolving business activities may make it advantageous to refine the structure. In certain circumstances, we have recommended:

• Restructuring ownership arrangements.
• Adding additional entities to the structure.
• Redomiciling a company or transferring a trust to a different jurisdiction.

Such adjustments help ensure that the structure continues to meet the client’s needs while remaining compliant with international regulatory standards.

• Cashflow Management and Trade Finance

Many of our clients operate trading businesses that involve cross-border transactions and extended payment terms, which can create a significant timing gap between shipping and payment. Through our banking relationships, we have assisted clients in accessing various trade finance solutions, including:

• Letters of Credit.
• Import Financing.
• Supplier Credit Facilities.

These instruments help businesses to manage their working capital more efficiently and support continued growth.

• Optimising Treasury Management

It is not uncommon for offshore companies to maintain significant cash balances in non-interest-bearing accounts. By understanding the operational cashflow requirements of the business, we can help clients structure treasury solutions that improve returns on surplus funds, including:

• Fixed deposit placements.
• Liquidity management strategies.
• Introductions to alternative banking solutions.

In many cases, we have been able to negotiate improved terms with financial institutions.

• Enhancing economic substance

International regulatory standards increasingly emphasise economic substance and genuine business activity in the jurisdiction of incorporation. In Mauritius, for example, many of our clients have chosen to strengthen their presence by:

• Relocating to the island.
• Obtaining residence or occupation permits.
• Becoming directors of their Mauritian companies.
• Establishing physical offices and operational teams

We are often involved in facilitating these relocations and assisting clients in developing a genuine operational presence that supports both regulatory compliance and business growth.

• Expanding services as needs evolve

Over time, clients’ requirements often expand beyond the original purpose of the structure. In many cases, clients are not initially aware that additional in-house services can be integrated into their existing arrangements, including:

• Payroll and HR advisory services.
• Intellectual property and trademark protection.
• Pension and retirement planning structures.
• Bank account introductions.
• Immigration and residency programmes.
• Aviation and marine ownership structuring.

By maintaining an ongoing advisory relationship, these additional opportunities can be identified and implemented efficiently.

3. The Wind-Up or Transition Stage – planning the next chapter

Like any business arrangement, offshore structures have a natural lifecycle. Some are established for a specific project or transaction, while others remain in place for many years as part of a broader business or wealth management strategy.

Even discretionary trusts – which are typically multi-generational structures – can outlive their original purpose. This may occur, for example, if family members relocate to jurisdictions that do not recognise the trust concept or where different tax considerations apply.

When a structure reaches the end of its useful life, careful planning remains essential. Rather than simply closing an entity, clients should consider how best to redeploy the capital or assets that it holds.

In many cases, we assist clients with transitioning their wealth into alternative structures, such as:

• Personal pension or retirement plans.
• Investment portfolios.
• Life assurance bonds.
• Residency or citizenship planning strategies.

For entrepreneurs approaching retirement, this stage often coincides with a broader lifestyle transition. Many clients choose to retire in a different jurisdiction to where they built their business, and international structuring can play a key role in facilitating this move efficiently and securely.

Conclusion

Establishing an international structure is only the beginning. To fully realise and maintain the benefits it can provide, clients must view the structure as an evolving tool that adapts to changing business, financial and family circumstances.
Ultimately, the most successful structures are those supported by long-term partnerships between clients and trusted service providers who understand their objectives and are fully engaged with on protecting and growing their interests.

The post A step-by-step Guide to getting the most out of your International Structure appeared first on The Sovereign Group.

South Africa’s 2026 Budget, delivered by Finance Minister Enoch Godongwana on 25 February, signals a period of relative fiscal stability after several years of pressure on public finances, writes Ralph Wichtmann, Managing Director of Sovereign Trust (SA).

Government debt is expected to peak and gradually decline as fiscal consolidation gains traction, while economic growth is forecast to improve moderately over the next few years.

This shift was best illustrated last November, when South Africa secured its first credit rating upgrade in nearly 20 years after S&P Global raised the country’s foreign-currency long-term sovereign rating from ‘BB-‘ to ‘BB’. It cited stronger growth prospects, an improving fiscal outlook and reduced contingent liabilities following better performance at state power utility Eskom.

The other really positive news is that South Africa was officially removed from the Financial Action Task Force (FATF) ‘grey list’ of jurisdictions under increased monitoring last October. The removal recognised South Africa’s progress in strengthening its anti-money laundering and counter-terrorism financing (AML/CFT) frameworks to address the 22 deficiencies identified by the FATF in February 2023.

South Africa is widely regarded as being one of the most significant financial hubs on the African continent. With that comes the expectation that it should meet international standards of governance, oversight and transparency in respect of financial matters.

South African Budget

For South African tax residents with international assets or those considering externalising capital, the Budget did not introduce sweeping new tax measures. However, several updates and policy signals remain highly relevant for offshore structuring, wealth planning and estate strategies. Below are the key implications for clients:

1. No major tax increases – but continued reliance on a narrow tax base

One of the most notable developments is that the previously proposed ZAR20 billion tax increase was withdrawn due to stronger-than-expected revenue collections. At the same time, the National Treasury highlighted the structural reality that a relatively small group of high-income taxpayers contributes a significant portion of South Africa’s tax revenue.

For internationally mobile individuals and families with global wealth, this reinforces a long-standing planning consideration:

• South African tax residents remain taxed on worldwide income and gains.
• Effective international tax planning and asset structuring remains essential.

2. Tax incentives to encourage Investment and Savings

The Budget introduced several measures to encourage domestic investment and savings, including increasing the annual limit for tax-free investment accounts from ZAR36,000 to ZAR46,000 and retirement fund deduction limits were also increased to ZAR430,000 annually.

The Capital Gains Tax (CGT) annual exclusion for individuals is to increase from ZAR40,000 to ZAR50,000 and the CGT exclusion in respect of the disposal of a primary residence is also to increase from ZAR2 million to ZAR3 million. The threshold for exemption from Donations Tax applicable to individuals, will increase from R100 000 to R150 000.

While these measures primarily support domestic savings, they highlight a broader government objective; strengthening South Africa’s investment culture. For high-net-worth families, this reinforces the importance of balancing:

• Onshore tax-efficient vehicles (retirement funds and tax-free investments), and
• Offshore investment structures for diversification and currency risk management.

3. Implications for South Africans with International Income

The Budget reiterates the central importance of tax residency in determining tax obligations.

• South African tax residents are taxed on worldwide income.
• Non-residents are taxed only on South African-sourced income and assets.

For individuals living abroad or planning to emigrate, this distinction remains one of the most important planning considerations. Key areas that requiring careful planning include:

• Timing of tax residency cessation.
• Exit Tax implications of becoming non-resident.
• Structuring foreign income streams through appropriate entities.
• Ensuring compliance with exchange control and tax reporting obligations.

4. Estate Planning and Trust Structures

South African trusts continue to play a central role in wealth planning but remain subject to a relatively high tax rate of 45%. This reinforces the need for careful structuring when trusts are used in cross-border estate planning. Key considerations include:

• Whether a South African trust or offshore trust is more appropriate.
• The role of foreign beneficiary structures.
• The interaction between CGT, Donations Tax and Estate Duty
• Whether assets should be held through offshore companies that are owned by trusts.

International families should also consider the impact of:

• Controlled Foreign Company (CFC) rules.
• Anti-avoidance provisions.
• Tax reporting obligations.

5. Exchange Control and Capital Externalisation

One of the major Budget changes introduced in relation to exchange control rules is the increase in the Single Discretionary Allowance from ZAR1 million per calendar year to ZAR2 million with no tax clearance needed. It should be noted, however, that the Foreign Investment Allowance, which requires SARS Approval for International Transfer (AIT) tax clearance, remains unchanged at ZAR10 million per year. These allowances remain the primary mechanisms for legally externalising capital.

For wealthy families, capital externalisation strategies typically involve:

• Phased transfers of investment capital offshore.
• Offshore trusts or Family Investment Companies (FICs).
• Diversification of custody, banking and asset management.

6. Increased focus on Financial Transparency and Compliance

South Africa’s removal from the FATF grey list was a key milestone and the government has indicated that continued strengthening of AML/CFT frameworks remains a priority. South Africa’s next FATF mutual evaluation is scheduled to begin in the first half of 2026, with the assessment concluding in October 2027. This Fifth Round evaluation will be assessing the sustainability of South Africa’s reforms. For globally mobile families, this is likely to involve:

• Increased reporting obligations.
• Greater scrutiny of cross-border transactions.
• Continued emphasis on increased tax transparency.

The Common Reporting Standard (CRS) was first published by the OECD in 2014 as the global standard for automatic exchange of financial account information. It was designed to promote tax transparency and help tackle offshore tax evasion. Over 100 jurisdictions worldwide have implemented the CRS and most of those have now been exchanging information since 2018.

This year, global tax transparency has been fundamentally expanded by bringing crypto assets, digital money and enhanced due diligence into automatic exchange regimes under the new CRS 2.0 and the Crypto-Asset Reporting Framework. From 2026, financial institutions and crypto service providers must report broader asset classes, transaction-level data and additional client identifiers, closing long-standing reporting gaps and significantly increasing cross-border tax visibility.

This expansion makes compliant structuring more important than ever. For internationally active South African families, the focus therefore remains clear – robust global structuring combined with long-term flexibility.

The post South Africa Budget 2026 – Key takeaways for International Wealth Structuring appeared first on The Sovereign Group.