2025 Overview

As we enter 2025, the global structuring landscape continues to evolve rapidly. Regulatory harmonization efforts, changing tax policies, and shifting geopolitical dynamics are reshaping how families and institutions approach cross-border wealth management.

This outlook identifies the key trends that will shape structuring decisions in the year ahead, providing guidance for advisors and clients navigating an increasingly complex environment.

"2025 will be defined by the tension between increased transparency requirements and the enduring need for legitimate privacy and asset protection."

Key Regulatory Changes

Several significant regulatory developments will impact structuring strategies in 2025.

Global Minimum Tax Implementation

The OECD's Pillar Two framework continues its global rollout:

  • 15% minimum tax now effective in most major jurisdictions
  • Qualified Domestic Minimum Top-up Tax adoption expanding
  • Substance requirements increasing across traditional planning jurisdictions
  • Carve-outs for certain activities requiring careful structuring

Transparency Initiatives

Information exchange continues to expand:

  1. Common Reporting Standard (CRS) now covers 100+ jurisdictions
  2. Ultimate beneficial ownership registries becoming standard
  3. DAC6/MDR reporting requirements expanding mandatory disclosure
  4. Real estate transparency initiatives in key markets

Market Trends

Beyond regulation, market dynamics are influencing structuring decisions.

Interest Rate Environment

The interest rate environment affects planning strategies:

  • Higher rates favor certain trust structures and annuity planning
  • Debt financing for acquisitions remains viable but costlier
  • Fixed income allocations becoming more attractive in portfolios
  • Currency hedging costs impacting cross-border cash flows

Digital Assets

Cryptocurrency and digital asset planning matures:

  1. Regulatory clarity emerging in major jurisdictions
  2. Institutional custody solutions now widely available
  3. Estate planning for digital assets becoming standard practice
  4. Tax reporting requirements crystallizing globally

Planning Implications

These trends suggest several planning priorities for 2025.

Structure Reviews

Existing structures should be reviewed against new requirements:

  • Minimum tax impact on holding company arrangements
  • Substance sufficiency in key jurisdictions
  • Transparency compliance and disclosure readiness
  • Succession planning updates for regulatory changes

Jurisdiction Selection

Jurisdiction choice requires updated analysis:

  1. Traditional offshore centers adapting to new requirements
  2. Onshore alternatives gaining attractiveness
  3. Treaty networks becoming more important
  4. Regulatory stability as a key selection criterion

Key Takeaways

2025 will reward those who proactively adapt their structuring to the evolving landscape.

  1. Review existing structures against new regulatory requirements
  2. Emphasize substance in all planning jurisdictions
  3. Prepare for transparency with robust documentation
  4. Consider digital assets as a mainstream planning element
  5. Engage advisors with current cross-border expertise

At Beekman Strategic, we continuously monitor regulatory developments to ensure our clients' structures remain optimized. Contact us to discuss how these trends affect your planning.