观点 | OPINION CHINA OFFSHORE
产品，也不是提供机构，而是独特的 体验模式。他能为客户厘清家族信托 的层层规划逻辑，再针对不同的资产 类别细化规划。这是最核心的竞争力， 毕竟工具是古板的，遵循正确的逻辑 才能把工具更好地应用在执行层面。 下面举例简单说明。 • 资产类别：股票资产 • 遵循逻辑：把未来的现金流直接引导 至他人身上，递延税收，合理节税。 大多数上市公司每年最为苦恼的是为 分红缴纳所得税的问题。身为大股东， 获得分红之后是需要缴纳所得税的。 但根据笔者多年的服务经验，很多高 净值客户并不需要使用每年的分红， 甚至计划将其累积后留给后代使用。 需要警惕的是，未来如果赠与税出台， 交给下一代时还需扣除税率可能高达 40%-50% 的赠与税，实际交到下一 代手里最多就只剩一半了。因此，为 了防患于未然，不如直接将这笔分红 现金流导入家族信托，待累积到一定 期限再分配给下一代。不但可以递延 个人所得税，还能起到降低税基，合 理节税的效果。当然，设立家族信托 并非为了避税，但可以透过良好的信 托架构合理节税。 理论上，将财产置入家族信托都会产 生一定成本，但如果置入的时间节点 不同，可能花费的成本就会大为不同。
good synergy. Family trust expands the capacity of the structure and creates greater potential for extension and flexibility. And, most importantly, clients’ demands are fully satisfied. High-quality family trust structures can also result in a self-cycle system. For example, reasonable insurance planning can be introduced into the family trust structure. Through such insurance, time value of each generation of family members will be realized and monetized in the family trust structure to support allocation or expenditure for the next generation. These proper arrangements of capital lay a firm foundation for long-term operation of family trust. From the perspective of service provider, it facilitates the building of long-term stable relationship with family members for generations and allows the service provider to offer more customized services. 2. Logic-based, refined planning and accurate services An outstanding family wealth planner can offer high-end clients with individualized services – not as products or institutions – as a unique experience. The planner can clarify the logical planning of family
trusts at all levels and then develop refined strategies for different types of assets. This is also the core of their competitiveness. After all, tools are inflexible. Only by following a logical system can tools be effectively implemented and leveraged. This shall be briefly illustrated as below. • Asset class: stocks • Logic to be followed: lead future cash flow directly to others for the purpose of deferring taxes and reasonable tax saving. What bothers listed companies the most is income taxes on dividends every year. Major shareholders are required to pay income taxes after having obtained dividends. According to my years of experience, most of the high-net-worth clients don’t need such yearly distribution, and even plan for accumulating them for descendants. One thing to be mindful is that, if gift taxes are to be introduced in the future, such taxes may be at a rate as high as 40-50%, which will impact the wealth to be passed on to the next generation - only half the value would actually be delivered, at most. Therefore, to prevent such a risk, it would be wise to funnel such
2016 China Offshore Trusts & Foundations Guide CHINA OFFSHORE
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