Cross-Border Investment Structure: Saudi Family Builds European Holding Platform

Client Profile

A prominent Saudi family with $420 million in global assets seeking to consolidate their European investments (UK, Germany, Spain, France) under a single, tax-efficient holding structure.

Business Challenge

The family's European investments were held through a patchwork of personal accounts, a Cayman vehicle, and a UK LLP — a structure that was tax-inefficient, provided no estate planning protection, and was increasingly scrutinised under UK and European anti-avoidance legislation. The family required a clean, defensible platform.

Strategic Solution

ILS Consultancy designed a Spanish ETVE (Entidad de Tenencia de Valores Extranjeros) holding company structure — a Spanish holding regime that exempts qualifying dividends and capital gains from non-Spanish subsidiaries from Spanish corporate tax. The structure accessed the Spain-Saudi Arabia double tax treaty to reduce Saudi-source withholding taxes. A UAE family trust was established as the ultimate holding vehicle with a professional trustee.

Outcome

The ETVE structure qualified for full exemption on dividends received from the UK, German, and French subsidiaries. The effective group tax rate on European income reduced from an estimated 31% to 8%. The family trust provides generational wealth transfer protection recognised under both Saudi and Spanish law.

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