As Greater China’s regulatory climate grows increasingly complex, private wealth advisers are facing rising demand for clarity, caution, and customisation. The traditional appetite for opacity has diminished, replaced by a new expectation for legitimacy and foresight. In this climate, structuring is no longer a one-size-fits-all exercise, it is a multi-jurisdictional, multidisciplinary process requiring precision and integrity. At a recent Hubbis Wealth Planning & Structuring Forum – Hong Kong 2025, legal and advisory professionals convened to explore how tax enforcement, Common Reporting Standard (CRS) implementation, and residency planning are reshaping client behaviour. Speaking from the frontlines of Singapore’s trust and wealth management ecosystem, Tan Woon Hum, Partner at Shook Lin & Bok, laid out a measured but urgent case for early planning, jurisdictional bifurcation, and professional accountability. His message was clear: compliance is not a constraint, it is the new foundation for long-term wealth preservation.
A Rising Tide of Complexity, and the Response Must Match
Tan opened his remarks with a candid admission: “The challenges are real, and they are only getting more complex.”
In his view, the pressures facing wealthy families are not limited to China. “It is the same for every jurisdiction where taxes are being imposed more strongly and widely,” he said. Whether from the OECD, European Union, or Asia’s own evolving standards, the direction of travel is clear: regulation is accelerating, and the implications are structural.
Against this backdrop, Tan warned against prescriptive or cookie-cutter solutions. “If any adviser tells you ‘this is the model, A, B, or C, and here is the fee,’ I would be very concerned,” he said. “Planning must begin with a deep understanding of the ultimate beneficial owner, their needs, their age, health, family dynamics, and asset footprint.”
This bespoke approach, he argued, is not just prudent, it is essential to achieving compliant, durable outcomes.
Structuring Across Jurisdictions: Bifurcation as a Defensive Strategy
A recurring theme in Tan’s commentary was the risk of over-concentration. “If every asset and business interest is concentrated in one or two jurisdictions, the risk is amplified,” he warned. “If that jurisdiction fails or enacts punitive changes, everything could fall together.”
To mitigate this, Tan advocates for bifurcation, allocating structures across at least two or three trusted jurisdictions. “Many of my clients have implemented this strategy,” he noted, “allocating part of their wealth to hubs like Singapore, Hong Kong or Switzerland.”
But not every jurisdiction that markets itself as a wealth centre will suffice. Tan stressed the need to select hubs that are competent, compliant, and supported by robust professional ecosystems. “Choose jurisdictions with credible legal infrastructure, mature trustee networks, and regulatory coherence,” he advised.
A Team Sport: Legal, Tax, Banking and Fiduciary Coordination
In Tan’s experience, effective planning requires interdisciplinary collaboration. “I’m a lawyer, but I do not work alone,” he said. “We work closely with tax advisers, trustees, bankers, independent professionals who bring specialist knowledge to the table.”
This cross-functional approach is necessary, he said, to capture both the letter and the spirit of global regulations. “Clients need to understand what is being imposed now and what may come next. That insight comes from having a full bench of advisers who are aligned and experienced.”
Residency Planning: Substance Over Optics
Tan shared several case studies highlighting how clients often misunderstand the concept of residency, particularly in the context of CRS reporting and tax exposure.
“Many clients assume that having a Singapore mobile number and renting a local apartment make them residents here,” he explained. “But when I ask if their golf clubs, dogs, and handbags are in Singapore, they admit everything is still in China.”
This anecdotal test, though delivered with humour, drives home a serious point: documentation alone is insufficient. Substance matters. “Residency is not about where you say you are,” Tan stressed. “It is about where you actually live, where your personal and economic ties reside.”
This insight is particularly important given the growing use of technology and behavioural indicators by tax authorities. “The era of superficial residency claims is over,” he said.
The Cost of Non-Compliance: Personal and Professional Risk
Reflecting on the growing regulatory pressure across Asia, Tan spoke with candour about the risks faced by practitioners themselves. “I only have one job, one wife, and one family,” he said, “and I do not wish to lose my licence to practise law.”
While said in jest, the underlying sentiment was clear: “As licensed professionals, we bear the risk of any misstep. If something goes south, we lose our licences, our livelihoods.”
Tan’s response has been to impose the highest internal standards. “From day one, we have been taught to ensure everything we say or write is honest, correct, and defensible,” he said. “Whether via WhatsApp, email, on the phone or in person, we speak and act as though our statements could be reviewed by regulators, clients, and even the courts.”
This culture of accountability, he believes, is what separates competent advisers from opportunistic ones.
“Pay Caesar What Is Due”: Tax Planning, Not Tax Evasion
For Tan, the key distinction is between illegal evasion and legitimate planning. “Tax avoidance and tax evasion are illegal in Singapore,” he stated plainly. “But tax mitigation, structured planning in line with the law, is entirely legal and advisable.”
He invoked the biblical phrase “give to Caesar what belongs to Caesar” as a guiding principle. “Our job is to help clients understand what the law allows, and to navigate within those boundaries.”
This extends to guiding clients on difficult but strategic decisions, such as changing citizenship or absorbing exit taxes. “Take Eduardo Saverin, for example,” Tan said, referring to the Facebook co-founder who relinquished his US citizenship before the company’s Initial Public Offering (IPO). “He paid the exit tax, moved to Singapore, and benefitted from a more favourable tax regime thereafter. That was well-advised, well-timed, and fully compliant.”
Speed Cameras, Not Speed Limits: The New Enforcement Paradigm
Tan offered a compelling metaphor to describe today’s compliance environment: “The speed limit has not changed, but there are now more speed cameras.”
This analogy illustrates the challenge facing clients: laws may be longstanding, but the tools for enforcement, data sharing, Artificial Intelligence (AI) audits, inter-agency cooperation, have evolved rapidly. “You must understand where the cameras are, what the limits are, and plan accordingly,” he advised.
Ignoring these realities is no longer viable. “If a client tries to argue by the book with Chinese tax authorities, they will lose,” he warned. “You do not fight by the book, you negotiate, strategically and humbly.”
Education Is the Best Insurance
Ultimately, Tan sees education as the most powerful tool available to advisers. “We must help clients understand the difference between form and substance, between optics and compliance, between superficiality and strategy,” he said.
This includes guiding clients through practice reviews, examining the consistency of information across institutions, trustees, and reporting jurisdictions. “If your banker is reporting different residency information than your trustee, that inconsistency can trigger unnecessary scrutiny,” he explained.
Consistency, transparency, and early preparation are no longer best practices, they are imperatives.
From Risk to Resilience: Structuring in the New Reality
Tan’s insights offer a compelling framework for families navigating today’s wealth planning landscape. As regulatory enforcement tightens across Greater China and beyond, the need for rigorous, multi-jurisdictional, and integrity-driven structuring has never been clearer.
The offshore world is not disappearing, but it is evolving. And only those advisers and clients who evolve with it, who embrace compliance, prioritise substance, and collaborate across disciplines, will succeed in preserving and growing wealth across generations.
In Tan’s words, “We hope you live a long life, make a lot of money, and enjoy it with your family. But do it right. Structure it right. And pay what is due, so that everything else can flourish.”
