Assets & Investment Advisory
Strategic advisory on the structuring, holding, and management of international assets and investment portfolios across multiple jurisdictions.
Request a ConsultationInternational Asset Structuring and Investment Advisory
The optimal structure for holding international assets — whether investment portfolios, real estate, operating businesses, intellectual property, or alternative assets — depends on the nature of the asset, the jurisdiction in which it is located, the tax position of the beneficial owner, and the long-term objectives of the holding.
Elaris provides advisory on the structuring and holding of international assets through appropriate corporate, trust, and fund vehicles — drawing on our multi-jurisdiction capability to identify structures that are both tax-efficient and operationally credible.
Advisory Services
Investment Portfolio Structuring
Advisory on holding investment portfolios — listed equities, bonds, funds, and alternative assets — through offshore vehicles that provide tax-efficient accumulation, privacy, and flexibility of distribution. Cayman, BVI, Jersey, and Guernsey vehicles are commonly used.
Real Estate Holding Structures
Cross-border real estate holdings frequently benefit from an intermediate holding company in a jurisdiction with a favourable tax treaty with the country where the property is located. We advise on and implement the holding structure, nominee arrangements, and financing structures.
Intellectual Property Holding
IP holding through jurisdictions with favourable IP box regimes — Ireland (6.25% KDB rate), Luxembourg, Cyprus (2.5% effective rate), and the Netherlands — providing a tax-efficient vehicle for royalty income from patents, software, and trademarks.
Alternative Asset Vehicles
Structuring for alternative assets including private equity co-investments, cryptocurrency and digital asset holdings, commodities, and infrastructure — using appropriate SPV and fund-lite vehicles across offshore jurisdictions.
Family Investment Companies
Family investment companies (FICs) as an alternative to trusts for family wealth structuring — providing control retention, income tax efficiency, and succession planning flexibility through a bespoke corporate constitution.
Investment Fund Formation
Formation of regulated and unregulated investment fund vehicles — from Cayman exempted limited partnerships and BVI professional funds to Mauritius expert funds and Luxembourg RAIFs — for family offices and emerging fund managers.
Structuring for Substance and Sustainability
Asset holding structures that were designed solely for tax efficiency — without genuine economic substance — are increasingly challenged by tax authorities under BEPS, economic substance legislation, and the OECD’s Pillar Two framework. A structure that cannot demonstrate real economic activity in its jurisdiction of registration faces significant risks: denial of treaty benefits, deemed tax residency in the beneficial owner’s home country, and in some cases financial penalties.
Elaris designs asset holding structures that are both tax-efficient and substantively defensible — with real economic activity, genuine decision-making in the jurisdiction, and compliance with all applicable economic substance requirements.
Ready to Begin?
Speak to an Elaris advisor about your specific requirements. Initial consultations are complimentary and without obligation.