Case study · Private Wealth
Comparing trusts, foundations and family investment companies
We compared three international wealth-holding models for a family whose members, assets and future plans connected Spain with several common-law and civil-law jurisdictions.
The family was receiving different recommendations in different countries, each technically sound within its own legal system.
Our task was to show how each option would be understood in Spain and which model best matched the family’s governance objectives.
The challenge
- No direct Spanish equivalent for some overseas structures.
- Different treatment of control, distributions and succession.
- Reporting requirements for founders and beneficiaries.
- The risk of choosing a familiar structure for the wrong reason.
Our approach
Technical precision, focused on the client.
Common comparison
Each option was tested against the same criteria: ownership, control, taxation, succession, administration, privacy and adaptability.
Spanish lens
We explained how Spanish tax and reporting rules could characterise the arrangement over its full lifecycle.
Governance fit
Family decision-making and future residence scenarios were given equal weight with the initial tax analysis.
The outcome
The family selected a proportionate structure and rejected additional layers that did not add meaningful protection or governance value.
A concise governance and reporting manual helped the family and its advisers administer the chosen model consistently.
The right wealth structure is the one the family can understand, govern and sustain across every jurisdiction that matters.
The Lullius approach



