Does the global minimum tax affect my family holding?

For most families, no. Pillar Two's 15 percent global minimum tax applies only to multinational groups with consolidated revenue of at least 750 million euro, so the great majority of family holdings are out of scope. Very large family-owned groups can be caught and should take specialist advice, but for most a low-tax base remains available if chosen with substance and disclosure.

Is a low-tax jurisdiction still worth using in 2026?

Yes, for most families, provided it is chosen for fit and used transparently. CRS means the holding is reported, and substance rules must be met, but a tax-neutral or low-tax base is legitimate and common. What has ended is using such a base for secrecy; what remains is using it for neutrality, treaty access and efficiency, with full disclosure.

What substance does a holding jurisdiction require?

It varies, but credible jurisdictions expect genuine governance, decision-making and adequate resources where the entity is registered, and a pure holding may face lighter requirements than an active one. Banks test for substance during onboarding regardless. The practical question is whether the family can maintain real substance there; if not, the jurisdiction is the wrong choice.

Cross-border structuring

What to Consider Before Choosing a Holding Jurisdiction

The choice of holding jurisdiction turns on a short set of practical tests: where the owners are resident and taxed, treaty access to where the assets are, the legal system and its certainty, banking acceptance, the substance the family can maintain, transparency obligations such as CRS, and total cost. The global minimum tax matters only for very large groups, above 750 million euro of revenue. Decide on fit and defensibility, not on the lowest headline rate.

Key points

Residence of the owners and location of the assets come first; they usually narrow the field on their own.
Treaty access to the operating countries can matter more than the holding's own tax rate.
Banking acceptance and maintainable substance decide whether a structure actually works in practice.
CRS makes the holding transparent; the global minimum tax hits only groups above 750 million euro.
Choose the most defensible fit, the structure a bank, a regulator and your counsel would each accept.

The criteria that decide it

A holding jurisdiction is a fit, not a prize, and a handful of tests usually settle it. Where are the owners resident and taxed, because that governs their personal tax whatever the holding does. Where are the assets and operating businesses, and does the candidate jurisdiction have tax treaties that reach them, since treaty access can matter more than the holding's own rate. Is the legal system certain and respected, so that ownership and succession will hold up. Will banks onboard a structure based there without friction.

Only after those come the softer factors: privacy from the public, the features of the available vehicles, and cost. A jurisdiction that scores well on the first tests and poorly on none is worth far more than one with the lowest tax and a banking problem.

The 2026 landscape

Two shifts define the current environment. Transparency is now the default: the Common Reporting Standard, committed to by more than 120 jurisdictions and upgraded to version 2.0 from January 2026, reports a holding's accounts to the owners' home authorities, with crypto assets following under CARF in 2027 to 2028. And the global minimum tax has arrived, but narrowly: Pillar Two's 15 percent floor applies only to multinational groups with at least 750 million euro of revenue, leaving most family holdings out of scope while changing the arithmetic for the very largest.

The figures below summarise that landscape. The practical reading is that a low-tax base is still available and legitimate for most families, provided it is chosen with substance and full disclosure, not as a hiding place.

The 2026 transparency and tax landscape

Measure ↑	Value	Year	Type	Source
CRS reportable jurisdictions (2025 to 2026 period)	about 112 to 113	2026	Survey	National tax authorities, CRS lists, 2026
CRS version 2.0 in force	from 1 January 2026	2026	Survey	OECD; national tax authorities
Crypto-Asset Reporting Framework (CARF) start	2027 to 2028	2026	Projection	OECD Global Forum, 2026
Jurisdictions committed to CRS	more than 120	2026	Survey	OECD, 2026
Pillar Two global minimum tax rate	15 percent	2026	Survey	OECD Inclusive Framework
Pillar Two revenue threshold	750 million euro group revenue	2026	Survey	OECD; PwC and BDO trackers

Pillar Two applies only to multinational groups at or above the revenue threshold, so most family holdings are out of scope. CRS applies broadly. Confirm current lists and thresholds with advisers.

Substance and banking

Two practical constraints decide whether a chosen jurisdiction actually works. The first is substance: can the family maintain genuine governance, decision-making and, where required, local presence there. A jurisdiction whose substance requirements the family cannot meet is the wrong jurisdiction, however attractive on paper. The second is banking: will the family's banks, and the banks it will need, onboard and service a structure based there. A structure a bank will not open is not a structure.

These two tests eliminate more candidates than tax ever does. Run them early, before falling for a headline rate.

A decision checklist

Before committing, confirm each of the following. Residence and tax position of every principal. Treaty access from the candidate jurisdiction to each country where assets sit. Legal certainty and the standing of the courts. Banking acceptance, ideally tested with the actual banks. Substance the family can genuinely maintain. Transparency obligations under CRS and any local registers. The vehicle's succession and privacy features. And the all-in cost of setup and annual maintenance.

If a candidate passes all of these, it is a defensible home. If it fails any that matters to the family, no tax advantage rescues it. The right jurisdiction is the one that a bank, a regulator and the family's own counsel would each accept without a second look, and that will still fit a generation from now.

Frequently asked questions

Residence of the owners and location of the assets come first, then treaty access to the operating countries, legal certainty, banking acceptance and maintainable substance. Transparency under CRS applies broadly, and cost matters, but the lowest headline tax rate is rarely decisive. The goal is the most defensible fit, not the cheapest rate.

Sources: OECD Common Reporting Standard, more than 120 committed jurisdictions and about 112 to 113 reportable for the 2025 to 2026 period, with CRS version 2.0 in force from 1 January 2026 and CARF for crypto assets in 2027 to 2028 (OECD and national tax authorities, 2026). OECD Pillar Two global minimum tax of 15 percent applying to groups with at least 750 million euro of revenue (OECD Inclusive Framework; PwC and BDO trackers, 2026). Educational content; confirm current lists, thresholds and any structure with qualified advisers.

This Resource is provided by Caelius for general information and educational purposes only. It does not constitute investment, legal, tax or financial advice, nor an offer or solicitation. It is general in nature, may not apply to your circumstances, and may change without notice. Take any decision only after advice from qualified professionals who know your situation.