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Podcast: Offshore Tax with HTJ.tax
Episode: Structuring Around CRS for Russians
Description: Top Company (Custodial Institution)The company’s articles and memorandum allow its shares to transfer automatically to designated third parties (typically family members) upon the shareholder’s death.This mechanism does not create a trust, because there is no fiduciary relationship—only a custodial structure.Therefore, it does not fall under EU trust-related sanctions, which target fiduciary and trust-like arrangements.The company’s place of effective management (POEM) is in Svalbard, a CRS non-participating jurisdiction.As a result, the top company is treated as a Non-Re...