When can the tax authority challenge a holding structure? The CJEU’s judgment in “Neo Group” (C-203/25)
28 October 2026
Read More
Succession Planning
Succession is not merely a transfer of ownership - it determines who controls the business, how cash flows are structured, and whether the value of the enterprise is preserved. Without proper planning, succession gives rise to conflict, tax risk, and value destruction.
Our strength lies in approaching succession from multiple perspectives simultaneously - ownership, tax, legal, and governance - and integrating them into a single, clear, and coherent solution.
Our Approach
Our Approach
Succession is not a one-time decision - it is a structured, phased strategy that is implemented and reviewed over time.
01
Assessment of the Current Position
- Ownership structure, decision-making arrangements, and dependencies on key individuals.
- Identification of legal, tax, and governance risks.
Mērķis -Identify critical risks before they materialise.
02
Defining the Target Structure
- Ownership, control, and management model.
- Clear delineation between shareholders and operational management.
Mērķis -Agreement on control and decision-making following the transition.
03
Tax and Financial Structure
- Scenario modelling focused on outcomes and cash flow.
- Impact on the current and future generation.
Mērķis -Predictable outcomes and sustainable cash flow.
04
Legal and Governance Implementation
- Articles of association, shareholders' agreements, structural and control mechanisms.
- Alignment with personal succession instruments - wills, inheritance agreements, and similar.
Mērķis -A functioning and legally sound structure.
05
Implementation and Monitoring
- Phased transition and gradual handover of responsibilities.
- Regular review and adaptation of the structure.
Mērķis -Succession as a continuous process, not a one-off transaction.
Our Services
Our Services
Succession Strategy Development
Analysis of the current position and clear definition of objectives.
Ownership and Control Structuring
Voting rights, control mechanisms, and shareholder relations.
Tax and Financial Modelling
Comparison of solutions with a focus on net outcomes.
Corporate and Legal Implementation
Articles of association, agreements, holding vehicles, and other structuring instruments.
Governance Model Design
Separation of ownership and management functions.
Transition Implementation and Monitoring
Controlled handover and long-term stability.
When It Is Needed
When It Is Needed
- Where control of the business and critical decisions are concentrated in the hands of a single individual
- Where there is no clearly defined ownership and management succession plan for the next generation
- Where there are multiple heirs or diverging interests within the family
- Where there are no established rules for voting rights, decision-making, and shareholder relations
- Where it is unclear how cash flow will be maintained following a generational transition
- Where the interests of the business, owners, and family have not been structurally separated
Outcomes
Outcomes
- A clear, structured, and sustainable succession strategy
- A controlled transition of ownership and management without conflict
- Predictable tax impact and financial outcome
- Protected business and family interests over the long term
- A structure that works in practice - not merely on paper
