Case study · Private Wealth
Pre-arrival review of an established offshore structure
We reviewed a long-established offshore structure before a beneficiary moved to Spain, resolving classification, control and reporting questions before residence began.
The arrangement had been created for legitimate family and succession reasons many years earlier and had never been designed with Spanish residence in mind.
The move required a fresh analysis of documents, historic transactions and the client’s practical relationship with the structure.
The challenge
- Historic documents from different service providers.
- Uncertainty over Spanish classification and attribution.
- Potential distributions before and after arrival.
- Coordination with trustees and counsel overseas.
Our approach
Technical precision, focused on the client.
Reconstruct the history
We assembled the constitutional documents, additions, distributions and decision-making record into a reliable chronology.
Analyse control and benefit
Formal powers and actual practice were reviewed separately to identify the relevant Spanish tax consequences.
Plan the arrival
Available actions were sequenced before residence, with future reporting and distributions documented for the client and trustees.
The outcome
The client moved with a clear position on the structure, its reporting and the treatment of future benefits.
Trustees and advisers received a shared implementation note, reducing the risk of inconsistent action after Spanish residence began.
An established structure should be understood before it is changed. History, documents and practical control all matter.
The Lullius approach
