Continuity in a family business starts with clear rules about ownership, decision-making and remuneration. Tax planning needs to be developed alongside legal analysis and the family’s actual objectives.
A loan between group companies needs an economic rationale and terms that can be explained. The interest rate is only part of the assessment, alongside repayment capacity, risks and tax treatment.
A holding structure makes sense when it addresses a clear need for organisation, investment or continuity. The tax treatment of each step needs to be considered alongside its legal and operational effects.