Wealth structuring and protection · international trusts

A well-structured estate is a protected estate.

The structuring and protection of estates with an international element: trusts and foundations across multiple jurisdictions, choosing the right structure and jurisdiction, protecting the estate through compliance and dispute prevention — and, where appropriate, its orderly transfer between generations. By a consultant present in the international STEP network, specialising in international trusts.

Why it matters

An estate is built over years. It can be lost much faster.

More and more entrepreneurs and families today have a significant estate, businesses or assets abroad, accounts and property across several jurisdictions. But few have structured this estate so that it is protected — from future risks, from litigation, from instability, from poorly conceived taxation or from its own disordered dispersal.

Without a structure, the estate is exposed. Assets held directly, in the person's name, mixed with those of the business, without a considered legal architecture, are vulnerable to claims, to disputes between partners or within the family, to risks that did not exist at the time of accumulation but can arise at any moment. And the international dimension adds a further layer: different jurisdictions, clashing tax rules, ever stricter compliance and transparency requirements.

Wealth structuring means building, in good time and lawfully, the architecture that keeps the estate safe: choosing the right instruments, the right jurisdictions, the right level of protection and control. It is a mature discipline in the West, still rare in Romania — and those who approach it early, before the problem arises, gain the greatest advantage.

Florin Hrițuliac, wealth structuring adviser
Florin HrițuliacSTEP member · Arabia branch
What it covers

Structuring, protection and — finally — transfer.

An integrated approach, legal and tax, built around the protection and structuring of the estate — transfer being the natural consequence of a well-laid structure.

Trusts and foundations across jurisdictions

My area of specialisation: structuring, administering and defending international trusts and foundations — instruments of foreign law, non-existent as such in Romanian law — together with their taxation and the company law applicable to asset-holding structures. Domestically, I bridge to the fiducia of Romanian law, the local equivalent of the fiduciary mechanism.

Structuring the estate

Analysing and building how the assets are held — directly, through a holding, through a trust or foundation, through international structures — from the perspective of protection, governance and tax efficiency, in full compliance with substance and transparency rules.

Asset protection

Building, in good time and in good faith, an architecture that keeps the estate safe from future risks — litigation, claims, instability — through the separation of legal from beneficial ownership and robust holding levels.

Compliance and defending the structure

Keeping the structure compliant with international standards (FATCA, CRS, beneficial owner, economic substance) and anticipating trust disputes — preventing litigation and protecting the parties, including in a cross-border context.

Corporate holding structures

Forming and administering private asset-holding companies — capital structure, directors' obligations, beneficial-owner control, company migration — as vehicles for structuring the estate.

The orderly transfer of the estate

When the structure is in place, transfer between generations becomes a natural consequence: succession planning, international succession and the taxation of the transfer, without chaotic procedures and without double taxation.

The STEP network

A discipline with an international standard.

STEP — the Society of Trust and Estate Practitioners — is the international professional body for specialists in estate and succession planning: attorneys, tax advisers, trust administrators and fiduciary professionals worldwide.

I am currently the only professional from Romania present in the international STEP directory (verify here). I am affiliated to the STEP Arabia branch — the regional branch covering one of the world's most dynamic areas of wealth structuring — which, although I operate from Europe, reflects the orientation of this practice toward international and mobile clients with cross-border interests.

My specialisation, within this route, is in international trusts — their structuring and administration, the applicable company law, the taxation of international trusts and the defence of trusts in disputes — which I deepen through the advanced STEP certificates in progress, on the route toward the Diploma in International Trust Management.

The four advanced certificates of the route cover exactly the dimensions of wealth structuring and protection: Trusts: Law and Practice (International) — the trust concept, the trust instrument, the choice of applicable law, asset-protection trusts and private foundations; Company Law and Practice — how companies are used as asset-holding vehicles; Principles of International Taxation, AML and Compliance — the global regulatory, tax, anti-money-laundering and transparency framework (BEPS, economic substance, beneficial owner), recognised as the "gold-standard" qualification in the international trust industry; and Trust Disputes — anticipating and preventing trust litigation, protecting the structure including in a cross-border context.

Completing these certificates is scheduled for 2027, through obtaining the STEP Diploma in International Trust Management and full membership — Trust and Estate Practitioner (TEP), the top level of the network, reserved for practitioners who have completed the entire route and practise to the professional standard of the field.

Membership of this network means access to the field's international standards, training and collaborators — essential precisely because serious wealth planning almost always crosses the borders of a single country.

STEP · Arabia branch

The international network of the field — Affiliate member, affiliated to the Arabia branch

Advanced STEP certificates (in progress)

Trusts: Law and Practice · Company Law and Practice · International Taxation, AML & Compliance · Trust Disputes

Objective 2027 — TEP

The Diploma in International Trust Management and full membership (Trust and Estate Practitioner)

ADIT (in progress)

Principles of International Taxation · Transfer Pricing · UK — CIOT London

Attorney and tax adviser

The legal and tax framework of the transfer

Wealth structuring

A solid structure holds because it is correctly built.

The real protection of an estate does not come from a trick, but from a legal and tax architecture designed in good time, in good faith and with full transparency. A correctly built structure holds precisely because it is lawful — not because it hides something.

Building it starts from your objectives and assets and goes through a few essential decisions: which instrument suits the purpose, in which jurisdiction, with what level of retained control and what degree of protection. Each choice has legal, tax and reporting consequences that must be weighed together.

Choosing the right structure

Trust, foundation, holding, family partnership or a combination — depending on the objectives: protection, transfer between generations, family governance, tax efficiency. There is no universal structure, only one suited to each situation.

Choosing the right jurisdiction

The regulatory environment, legal stability, reporting requirements, applicable treaties and international implications — criteria that decide whether a jurisdiction brings real benefits or, on the contrary, constraints.

Layers of legal protection

Separating legal from beneficial ownership, separating personal from business assets, holding levels built so that the structure is robust against future risks — litigation, creditors, instability.

Compliance and transparency

Observing international standards — exchange of information, beneficial-owner reporting, economic-substance rules. A modern structure is protective precisely because it is compliant, not opaque.

The line that is not crossed. Legitimate wealth structuring protects the estate from future risks — and works only if it is done in good time, in good faith. It is not, and cannot be, a means of removing assets from existing creditors, hiding assets or evading obligations already incurred. A structure built for such purposes not only fails to protect, but attracts serious legal risks. This is precisely why the right moment to build is before the problem arises — not after.

Frequently asked questions

What those planning their estate ask.

I have an estate and assets in several countries. Where do I start?

From an overview: which assets you hold, in which jurisdictions, through what means, and what risks are associated with each. Only after this map can one speak of a structure — because a suitable structure starts from your real objectives and exposures, not from a standard model.

The next steps concern choosing the instruments (trust, foundation, holding, a combination), the right jurisdictions and the desired level of protection and control. The whole exercise is built around two objectives: protecting the estate from future risks and a compliant, transparent structure that lasts.

What does wealth planning mean, concretely?

It means deciding in good time, in a structured way, how your estate is held and how it will be transferred — instead of leaving these matters unresolved, to default law and to heirs. It can include wills, gifts, the choice of the law applicable to succession, the structuring of assets and the tax planning of the transfer.

The purpose is twofold: that your wishes are respected and that the heirs are protected from conflicts, costly procedures and a heavier tax burden than necessary.

Can I set up a trust in Romania?

The trust, as an institution, does not exist in Romanian law — it is an instrument of Anglo-Saxon law, recognised, however, in numerous other jurisdictions. For a Romanian client with an international estate, this does not make it irrelevant, quite the opposite: the trust or foundation is set up in the right jurisdiction, not in Romania.

This is where my specialisation comes in: structuring, administering and defending international trusts and foundations, the company law applicable to holding structures and their taxation. I work on the foreign-law instrument where it exists and produces effects, in coordination, where appropriate, with professionals in the relevant jurisdiction. What I do not claim is to set up a trust 'in Romanian law', because Romanian law does not know the institution as such.

Is tax planning of an inheritance legal?

Yes, as long as it is lawful optimisation — the correct use of the rules, of double-taxation treaties and of national regimes so as not to pay more than the law requires. This is distinct from evasion, which involves concealing or falsifying reality.

Correctly done wealth planning rests on transparency and real substance — the very opposite of concealment. It is a mature and legitimate practice worldwide.

Is there anything in Romanian law equivalent to a trust?

Yes, to a certain extent: the fiducia, regulated by the Civil Code. Through a fiducia, a person (the settlor) transfers rights or assets to a fiduciary, who administers them for a specified purpose, for the benefit of one or more beneficiaries. It is the closest local equivalent of the fiduciary mechanism, even if it is not identical to the Anglo-Saxon trust and has its own limitations — among them the restricted circle of persons who can act as fiduciary.

For a client with interests in several jurisdictions, the value lies precisely in mastering both worlds: the trust or foundation, where foreign law fully recognises them, and the fiducia, as a domestic instrument when appropriate. The analysis starts from your objective and chooses the instrument — and the jurisdiction — that serves it best, lawfully.

Does such a structure protect my estate from creditors and lawsuits?

A well-built structure can offer protection from future risks — litigation, claims, instability — when it is created in good time, in good faith and properly funded. Assets held through a legitimate structure can, in many cases, be less exposed to future claims.

There is, however, a firm limit, which I state clearly to any client: protection works only for future and uncertain risks, not against debts or claims already existing. Structuring is not, and cannot be, a means of removing assets from current creditors or hiding assets — such transfers are null and attract liability. Built correctly and in time, a structure protects precisely because it is lawful.

What exactly are you specialised in, in the area of trusts?

My specialisation covers four directions of international trusts: structuring and administration (international trust management), the company law applicable to holding structures (company law and practice), the taxation of international trusts, and the defence of trusts in disputes (trust disputes).

These are directions I deepen through the four advanced STEP certificates in progress, on the route toward the Diploma in International Trust Management. Completion is scheduled for 2027, when I will also obtain full STEP membership — Trust and Estate Practitioner (TEP), the reference qualification in the field internationally.

What does it mean that you are in the STEP network?

STEP is the international professional body for specialists in estate and succession planning. Presence in its international directory means access to the field's global standards, training and collaborators — important because serious wealth planning almost always involves several jurisdictions.

I am currently the only professional from Romania present in this directory, as an Affiliate member and affiliated to the STEP Arabia branch. I am following the advanced certification route, which I anticipate completing in 2027 through obtaining full membership — TEP (Trust and Estate Practitioner).

Who, in practice, is wealth planning useful for?

For anyone with a significant estate, a family business, or an international element — property, accounts, children or activities in another country. The more complex or geographically dispersed the estate, the more value early planning brings and the more problems it prevents.

It is not necessary to be at the end of your career: most beneficiaries of good planning are those who start early, when they have the most options available.

Contact

Do you have an estate with an international element you want to protect?

A first, confidential conversation clarifies the estate situation, the risks at a possible succession and the planning directions available — tax and legal, in an international context.

E-mailrolegal@pm.me
Phone+40 799 597 410
AvailabilityInternational · video or in person