The word trust travels easily between English and Spanish. The institution it names does not. Colombia has answered the difficulty by statute, most recently by decree in May 2026, while Spain answers it through administrative practice alone. What follows examines why the fiducia mercantil is not a trust, and what a patrimonio autónomo means for a family with a member resident in London.
Continue Reading Neither fiducia nor fideicomiso is a trust. A Colombian and Spanish perspective
Choosing between London and Madrid is a matter of pure portfolio arithmetic, not political ideology. Compare the UK’s 4-year FIG regime against Spain’s 6-year Beckham window to see where your wealth thrives. Discover how the ultimate balance between annual wealth taxes and inheritance taxes changes the return you need.
Continue Reading Taxing Income or Taxing Wealth? The Real Arithmetic of an Anglo-Spanish Move
Using a company to own property in Spain is a highly debatable topic. This article is focused on international private clients acquiring prime Spanish real estate above €3 million, the historic playbook of using offshore holding companies to shield assets from wealth taxes is effectively dead. Spain’s strict “look-through” rules now aggressively pierce foreign corporate wrappers, meaning your tax exposure depends entirely on the specific Double Taxation Treaty between Spain and your home country—a test that UK, US, and Irish residents categorically fail. Facing aggressive audits and the realization that Spain does not recognize common-law trusts, savvy investors are increasingly abandoning complex offshore structures in favor of direct personal ownership, prioritizing transparency and direct access to lucrative regional tax exemptions over the illusion of anonymity.
Malaysia rewards a second look from internationally mobile clients. A territorial tax system, no estate or general capital gains tax, a foreign-income exemption now extended to 2036, a mature double tax treaty with the United Kingdom, four residence routes and a natural fit with the Gulf, assessed by a dual-qualified barrister and Spanish abogado.
I have spent much of my working life at the seam between two legal traditions, and I know of few instruments that sit on that seam as uneasily as the trust. To a common law adviser it is the most ordinary thing in the world. It separates legal title from
Continue Reading Anglo-Saxon trusts in Spain: the problem of selective transparency
In a recent Financial Times op-ed, Yousef Al Otaiba, UAE Ambassador to the United States, set out why his country has walked away from OPEC after nearly sixty years — confident, unapologetic, sin complejos. For HNWIs and family offices, that is more than a headline; it is a signal. But relocating successfully takes more than sunshine and 0% tax. It takes treaty strategy, legal substance, and advisors who see the whole board.
Continue Reading The UAE Looks Forward. So Must the International Private Client
Your life crosses borders. A home in London, another in Andalusia, children settled in the Gulf, a business with operations in three countries, a will that works under English law but not in Spain. You are bouncing between advisers who rarely speak to each other. After twenty-five years between London, Madrid and the GCC, I write here for you — about the human side of cross-border life, and how the law can serve it.
Continue Reading Welcome to The International Private Client
The era of taxing companies is giving way to the era of taxing wealth. That is the central argument of my latest article, “Why Private Wealth is the Next Tax Frontier”, published this month in Taxation — the LexisNexis/Tolley title that has been the United Kingdom’s leading journal for tax professionals for over a century. You can read the full piece at https://www.taxation.co.uk/articles/why-private-wealth-is-the-next-tax-frontier
Continue Reading Why private wealth is the next tax frontier
The Financial Times interviewed me for its piece on how democracies should tax the super rich without driving them out. My contribution ran with my position unchanged from what I set out earlier this year in the Tax Journal in my article Why Private Wealth Is The Next Tax Frontier
Continue Reading The problem with taxing the rich