In the world of cross-border wealth planning, the choice of jurisdiction can be a complex and critical decision. At the Hubbis Wealth Planning & Structuring Forum - Singapore 2026, Dr Irina M. Francken and Derrick Kew presented a compelling case study on the use of New Zealand Foreign Trusts for families with Singapore-resident beneficiaries. Their presentation highlighted the importance of going beyond investment management alone to address succession issues, and the role of New Zealand as a stable and reputable jurisdiction for cross-border wealth planning.
Personally, I think the presentation was a fascinating insight into the complexities of international family wealth planning. What makes this particularly interesting is the way it showcases the importance of governance and the role of New Zealand as a stable and reputable jurisdiction. In my opinion, the case study serves as a powerful reminder that succession planning is not just about investment management, but also about creating a structure that can preserve wealth, support governance, and remain tax-efficient across generations.
One thing that immediately stands out is the central message: investment portfolios alone do not resolve succession issues. This is a critical point, as many families may be tempted to leave their assets in personal ownership, but this can leave them exposed to probate, succession disputes, creditor claims, and cross-border complications. From my perspective, this highlights the need for a comprehensive approach to wealth planning that takes into account the unique needs and circumstances of each family.
What many people don't realize is that governance is the missing piece in many family wealth planning strategies. The case study illustrates how a New Zealand Foreign Trust can provide the necessary governance structure to preserve wealth and support succession across generations. This is a key insight, as it shows that the right structure can make a significant difference in the success of a family's wealth planning efforts.
If you take a step back and think about it, the choice of New Zealand as the jurisdiction for this trust is not arbitrary. New Zealand's reputation as a politically stable, common law jurisdiction with a strong legal and judicial system makes it an attractive choice for families looking for a long-term succession structure. Additionally, its OECD and CRS compliance makes it familiar and acceptable to private banks, particularly in Europe and Switzerland.
A detail that I find especially interesting is the role of New Zealand trust law in providing the trustee with meaningful powers and flexibility. This allows the trustee to address certain trust deed, beneficiary, and administrative matters without routinely going to court, which is a key advantage in succession planning. This flexibility is what I am talking about when we talk about succession planning, as it allows the structure to adapt to changing family circumstances.
What this really suggests is that the choice of jurisdiction and structure is not just about tax neutrality, but also about the overall strength and flexibility of the governance framework. This is a critical point, as it shows that the right structure can provide a solid foundation for a family's wealth planning efforts, even in the face of changing tax laws and regulations.
In my opinion, the case study serves as a powerful reminder of the importance of matching the tool to the family's objectives. New Zealand Foreign Trusts, Singapore Family Offices, and Singapore Trusts are all complementary tools, each with its own strengths and weaknesses. The key is to choose the structure that best supports the family's goals, rather than treating them as interchangeable solutions.
One thing that many people don't realize is that the choice of structure can have a significant impact on the family's overall wealth planning strategy. For example, a New Zealand Foreign Trust may be more suitable for mobile families with offshore wealth, while a Singapore Family Office may be more appropriate for families looking for an onshore investment platform with Singapore substance. This highlights the need for a tailored approach to wealth planning that takes into account the unique needs and circumstances of each family.
A surprising angle to this case study is the role of Singapore tax analysis in the overall structure. While the New Zealand tax position is an important part of the structure, the Singapore tax treatment of the beneficiary is also critical. The analysis should begin with the trust mechanics, not with a search for exemptions, as the starting point is the trustee, not the beneficiary. This is a key insight, as it shows that the tax treatment of the beneficiary is not just a separate consideration, but an integral part of the overall structure.
From my perspective, the case study serves as a powerful reminder of the importance of substance over form in cross-border wealth planning. The integrity of the tax position depends on how the structure is managed, and if control and management drift back to Singapore, or if the trust is treated like a personal bank account, the ground beneath the analysis weakens. This highlights the need for genuine trustee independence, robust governance, clear source-of-wealth documentation, and ongoing compliance with the relevant legal and tax requirements.
In conclusion, the case study serves as a powerful reminder of the complexities and challenges of cross-border wealth planning. It highlights the importance of governance, the role of New Zealand as a stable and reputable jurisdiction, and the need for a tailored approach to wealth planning that takes into account the unique needs and circumstances of each family. For advisers, the lesson is to begin with the family's objective, then choose the structure that can support it across jurisdictions, generations, and future tax change.
