Automatic exchange
CRS and FATCA report accounts held by structures, and their owners, to tax authorities in over 100 countries.
Protect, consolidate and pass on wealth on your terms.
Foundations, trusts and holding companies, explained plainly. The jurisdictions families use most, what each does well, and how Okami manages the wealth inside the structure.
Why structure
Four jobs a good structure does for you.
ProtectSeparate your assets from personal, business and political risk.
SucceedPass wealth on your terms, without probate delays, disputes or forced heirship.
ConsolidateHold portfolio, property and companies under one roof, with one set of accounts.
OptimiseUse treaties and exemptions lawfully to reduce leakage on dividends and exits.
Structures work best when built calmly, in advance, not once a claim has arrived.
The 2026 rulebook
Secrecy is gone.
Structure is what protects.
Modern structures are transparent to tax authorities and banks by design. Protection now comes from proper legal separation, governance and substance.
Beneficial-owner registers
Major centres record who ultimately owns or benefits. Banks verify it at onboarding and at every review.
Economic substance
Low-tax entities must show real local directors, decisions and records, or lose benefits and face penalties.
Blacklists move
BVI and Panama sit on the EU's tax watch list (October 2026); BVI and Monaco are under FATF increased monitoring.
The building blocks
Three vehicles, three different jobs.
A foundation is an ownerless legal person, a trust is a promise enforced by courts, and a holding company is an ordinary company you own.
| Foundation | Trust | Holding company | |
|---|---|---|---|
| Legal personality | Yes, its own legal person | No, a legal relationship | Yes, a company |
| Who owns the assets | The foundation itself | Trustee, for the beneficiaries | The company; you own its shares |
| Who controls | Council, with a guardian | Trustee, with a protector | Directors and shareholders |
| Founding document | Charter and regulations | Trust deed, letter of wishes | Articles of association |
| Best for | Protection and succession | Protection and succession | Consolidation and exits |
FounderYou, endowing the foundation
↓FoundationCouncil runs it, guardian oversees
↓BeneficiariesNamed in the charter or by-laws
A legal person that owns itself
Strengths
- Separate legal person: owns and contracts in its own name
- Founder can reserve defined rights in the charter
- Familiar to civil-law families
Limits
- Registered and more formal, so more visible than a trust
- Thinner case law than trusts in most centres
- Tax treatment varies widely between countries
SettlorYou, moving assets in
↓Trustee + protectorLegal owner, acts for the family
↓BeneficiariesYour family, per deed and wishes
You give up ownership, not the purpose
Strengths
- Assets leave your estate: shielded from creditors and probate
- Flexible distributions, guided by your letter of wishes
- Recognised by courts and banks worldwide
Limits
- You give up legal ownership; too much control can void it
- No legal personality: the trustee contracts for the trust
- Not recognised in some civil-law countries
ShareholdersYou, or a foundation or trust
↓Holding companyOwns and consolidates
↓PortfolioPropertyBusinesses
One roof for everything you own
Strengths
- One roof for portfolio, property and businesses
- Treaties and exemptions can cut tax on dividends and exits
- Simpler banking, reporting and eventual sale
Limits
- No succession on its own: shares still pass via your estate
- Your personal creditors can seize the shares
- Needs real substance to keep tax benefits
Jurisdictions
Where to set it up.
We start with Mauritius, our home jurisdiction, and compare it with the centres our clients ask about most. The final choice still depends on where the family lives, where the assets are, and which job matters most.
| Jurisdiction | Advantages | Watch-outs |
|---|---|---|
| MauritiusOkami’s home jurisdiction | Foundations Act 2012: a trust-company hybrid with its own legal personality; pairs naturally with a Mauritius GBC holding and the island's treaty network; OECD white-listed, with no exchange controls | Lower global profile; tax depends on the residence of the founder and beneficiaries |
| UAE (ADGM, DIFC) | Close to family and assets; family foundations can seek UAE tax transparency | Recent regimes, limited case law; transparency conditions must be kept up |
| Liechtenstein | Nearly a century of foundation law; EEA member, AAA-rated; PAS status can limit tax to a minimum | Among the most expensive to set up and run; formal governance and supervision |
| Panama | Fast and low-cost; territorial tax, so no tax on foreign-source income; flexible by-laws | On the EU tax watch list (October 2026); reputational legacy; harder banking |
| Malta | EU member with EU-law protections; statutory foundation regime; English-speaking courts | Tax and registration complexity; heightened EU scrutiny of Maltese structures |
| Jersey & Guernsey | A familiar civil-law vehicle backed by Channel Islands courts; a guardian adds oversight | Premium cost; a licensed local council member or agent is required |
| Jurisdiction | Advantages | Watch-outs |
|---|---|---|
| MauritiusOkami’s home jurisdiction | Trusts Act 2001 firewall: Mauritian courts will not recognise foreign judgments on trust property in marriage, succession or insolvency claims; forced heirship can be mitigated; no registration, high confidentiality; a non-resident trust is not taxed on foreign-source income; can own a Mauritius GBC directly | At least one FSC-licensed qualified trustee is required; non-purpose trusts are limited to 99 years; lower global profile than the Channel Islands |
| UAE (DIFC, ADGM) | English-law-based courts on your doorstep; supports Sharia-aligned succession | Younger case law; UAE corporate tax filings for underlying companies |
| Jersey & Guernsey | Deep case law and Privy Council appeal; firewall laws resist foreign heirship and divorce claims | Premium fees; trustees expect real governance; slower onboarding |
| Cayman Islands | No direct taxes; STAR trusts allow purpose trusts and flexible enforcement | Higher set-up and running costs; substance rules for underlying companies |
| British Virgin Islands | VISTA trusts let the family keep running a business held in trust; low cost | On the EU tax watch list and under FATF increased monitoring (2026); bank friction |
| Singapore | Strong courts and rule of law; licensed trustees; natural base for Asian assets | Rigorous, slower onboarding; higher cost; tighter AML scrutiny since 2023 |
| Cook Islands | Foreign judgments not enforced; short limitation periods and a high bar for creditors | Can look defensive to banks and courts; remote; assets usually banked elsewhere |
| Jurisdiction | Advantages | Watch-outs |
|---|---|---|
| Mauritius (GBC)Okami’s home jurisdiction | 80% partial exemption caps tax at 3% on qualifying foreign income; a wide double taxation treaty network; gateway to Africa and India; no exchange controls | Substance tests on directors and spending; anti-abuse rules narrow treaty use |
| UAE | 9% corporate tax above AED 375,000, 0% possible in free zones; no withholding tax | Strict qualifying free-zone tests; real substance and annual tax filings |
| Cyprus | EU directives and wide treaties; non-dom regime; low withholding on outbound dividends | Corporate tax rose from 12.5% to 15% on 1 January 2026; substance expected |
| Luxembourg | Participation exemption on dividends and gains; deep funds and banking ecosystem | Headline rate around 24%; high running costs; strict substance |
| Netherlands | Participation exemption; one of the widest treaty networks; legal certainty | 25.8% headline rate; withholding on payments to low-tax jurisdictions |
| Singapore | 17% headline, no capital gains tax, tax-free dividends; ideal for Asian holdings | Some foreign disposal gains now taxed; substance and higher cost |
| BVI & Cayman | Zero tax, fast and inexpensive; flexible company law; the standard for SPVs | BVI on EU and FATF lists (2026); substance rules; home-country CFC rules may apply |
Jurisdiction information as at October 2026 and subject to change. Lists and tax rates are reviewed before every client meeting.
Putting it together
A typical layered family structure.
Each layer has one job. Keep them separate, and the structure stands up to banks, tax authorities and courts.
The top and middle layers often sit in different jurisdictions: an ADGM foundation owning a Mauritius GBC, for example, or a Jersey trust owning a Singapore holding company.
FamilyFounder and beneficiaries
↓
Foundation or trustProtects, governs succession
↓
Holding companyConsolidates, optimises
↓
PortfolioManaged by Okami
Real estate
Business interests
What undoes a structure
Four mistakes courts and banks look for.
We do not sell secrecy. A structure that ignores these points can be unwound by a court, challenged by a tax authority or refused by a bank.
Keeping too much control
If you still direct every decision, a court may call it a sham and treat the assets as yours.
Moving assets too late
Transfers made once a claim is foreseeable can be reversed. Protection must come first.
Empty boxes
No local directors, decisions or records means lost treaty benefits, penalties and closed accounts.
Ignoring home-country rules
Your tax residence usually decides the outcome. CFC, exit-tax and US-person rules can override it.
How we work
From first meeting to a managed structure.
- 01
Discover
Family, assets, residences and goals, mapped in a confidential session.
- 02
Advise
Independent tax and legal counsel confirm the position in each relevant country.
- 03
Design
Structure and jurisdiction shortlisted, with costs and trade-offs side by side.
- 04
Establish
Licensed partners incorporate; we open custody accounts and complete KYC.
- 05
Manage
Okami invests and reports on the portfolio, with an annual structure review.
Trustee, foundation council and incorporation services are provided by licensed third-party partners. Tax and legal advice comes from independent counsel whom you appoint or we introduce. Okami coordinates the process and manages the investments.
Where Okami fits
We manage the wealth inside the structure.
Once the structure exists, it needs an investment manager. Okami offers three ways to hold its assets.
48–72hours
Personal IBAN at Okami
Client receives his personal IBAN at Okami’s custodian bank.
7–14days
In the structure's name
At our custodians, under mandate, with preferential custody and execution rates.
Variesby bank
At your existing bank
We manage the structure's current account under mandate.
Independent, no in-house productsOne relationship manager, for lifeRegulated by the FSC Mauritius
For information only. This page is not legal, tax or investment advice. Any structure must be assessed against your personal circumstances and tax residence with independent advisers. Please read our Full Disclaimer.
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If you are looking for a more disciplined, more transparent and more considered approach to your capital, we would welcome a conversation.
The Okami Letter
Wealth that lasts generations deserves considered reading.
Notes on structuring, succession and long-term investing, written for families and their advisers.