How rising mobility is reshaping tax and cross-border planning

Rising global mobility brings tax, compliance and cross-border wealth planning challenges for Indian business families and family offices.

In brief

• Unintended shifts in residency and uncoordinated cross-border succession planning are major blind spots for globally mobile Indian families.
• Family offices that move capital offshore must comply with Exchange Control rules and economic substance requirements across global hubs.
• Post-liquidity planning requires early decisions on tax treatment, ownership structuring and cross-border capital management to build durable wealth platforms.
• Family offices are now treating philanthropy as a long- term institutional commitment, measuring outcomes with the same rigor applied to investment decisions.

Surabhi Marwah, Partner and Co-Leader, Private Tax and People Advisory at EY India, brings over two decades of experience in family succession planning, employee mobility and advisory for high-net-worth individuals (HNIs) and family businesses. She was recently featured in the March 2026 edition of the Campden Wealth expert series, where she examined the growing tax and regulatory blind spots facing globally mobile Indian families — from unintended residency shifts and foreign asset reporting risks to Exchange Control misalignment and economic substance challenges. She also outlined critical structuring decisions following liquidity events, key jurisdictional considerations beyond tax efficiency, and how families can build compliant, impact-driven philanthropic vehicles that support long-term wealth continuity.

With increasing global mobility among Indian business families, what are the biggest tax and regulatory blind spots you are currently observing? 

As Indian business families’ presence becomes increasingly global, several tax and regulatory blind spots are emerging, often quietly but with significant long-term impact. A key vulnerability is unintended residency shifts. Families often underestimate how global travel, extended stays abroad, or children studying and settling overseas can trigger residency or permanent establishment exposure, leading to global income taxation and increased compliance requirements. Cross-border succession is another growing concern. While domestic ‘wills’ or ‘trusts’ may be in place, foreign assets are often held without coordinated succession planning structures. This creates exposure to estate taxes, probate complexities and fragmented control.

Additionally, India’s regime for foreign asset reporting remains stringent. Even small lapses can lead to disproportionate penalties and reputational risks.

Finally, expanding globally without adapting governance and holding structures often results in gaps with Exchange Control and substance requirements. 

For globally mobile families, addressing these blind spots is no longer just a matter of compliance hygiene; it is a form of strategic risk management, essential for protecting legacy and enabling seamless cross-border wealth continuity. 

What foreign exchange and cross-border compliance risks do business families most frequently underestimate, and how can they proactively mitigate these exposures? 

As Indian business families globalize, the most underestimated risks lie at the intersection of Exchange Control rules and cross-border compliance (tax and regulatory). 

A major blind spot is the misalignment with Exchange Control regulations when moving capital offshore. Families often treat overseas investments, gifts to non-resident relatives, or contributions to foreign trusts as routine, overlooking limits under the Liberalised Remittance Scheme (LRS) and the need for specific Exchange Control approvals. These gaps usually surface during restructuring, audits, or liquidity events, when remediation becomes more costly. 

Another underestimated exposure is economic substance requirements in preferred jurisdictions, specifically Singapore, the UAE and Mauritius. Holding entities with minimal on-ground presence increasingly face challenges around beneficial ownership, treaty eligibility and tax residency, risks that can erode both tax efficiency and credibility.

Additionally, global transparency frameworks have elevated scrutiny. Even inadvertent non-disclosure of offshore accounts or beneficial interests can trigger tax penalties and reputational consequences.

Mitigation requires a shift from transactional compliance to holistic cross-border governance — integrating Exchange Control, tax, substance and reporting requirements into a single, future-ready architecture. Families that embed compliance into structure design, rather than retrofitting it later, are better positioned to preserve flexibility, legitimacy and intergenerational continuity.

Following liquidity events, what are the most critical tax and structuring decisions families should address at the outset?

Following a liquidity event, families often focus on investment deployment but overlook several foundational tax and structuring decisions that have the greatest long-term impact.

The first critical step is defining the nature and timing of proceeds — capital gains, buyback income, deferred payouts and earn-outs; each carries distinct tax treatments. Early clarity enables families to optimize advance tax positions, manage surcharge exposure and align proceeds with future investment vehicles.

Equally important is establishing a post-liquidity ownership architecture before funds disperse. Decisions around family trusts, investment entities and governance frameworks are far more effective when made at the outset, enabling wealth to be channeled into structures that support control, succession, tax optimization and global mobility.

Families must also design a cross-border capital strategy early, aligning Exchange Control rules, LRS utilization and jurisdictional tax considerations when planning global investments. Missteps here can limit flexibility or create regulatory friction later.

Addressed proactively, these early decisions convert liquidity into a durable, multi-generational wealth platform rather than a one-time financial milestone.

Which international jurisdiction currently presents the most strategically advantageous landscape? Beyond tax efficiency, what structural and long-term considerations should influence their choice of destination for business and investment purposes? 

2025 set an all-time high with ~14,20,001 millionaire relocations and projections climbing to ~16,50,001 in 2026 as jurisdictions compete on tax, residency and stability.¹

These drivers are expected to persist in 2026 and in the years to come. Some of the top destinations include the UAE, Singapore, and select European hubs such as Switzerland and the Netherlands, consistently being the destination of choice for globally mobile business families. Singapore, for instance, continues to top global rankings for stability, competitiveness and reputation, underpinned by transparent governance and a highly innovation-driven economy.²

However, the choice of jurisdiction must extend well beyond tax efficiency. Long-term structural resilience depends on evaluating regulatory transparency, economic stability, access to global markets and the jurisdiction’s reputation — now a measurable driver of capital flows and investor confidence. 

Families should also weigh legal robustness, including the strength of contract enforcement, intellectual property protection and dispute-resolution frameworks — critical in sectors driven by technology, capital markets and cross-border transactions. 

Further, long-term considerations include talent access, residency pathways, governance expectations and compliance culture, especially as global transparency norms tighten. 

As family offices increasingly move toward outcome-driven philanthropy, how can business families structure their vehicles to achieve regulatory compliance, tax efficiency and measurable long-term impact?

As family offices pivot toward outcome-driven philanthropy, it is essential to enable regulatory compliance, tax efficiency and measurable long-term impact. Increasingly, leading families are adopting investment-style discipline in their giving — using data-driven frameworks, real-time impact dashboards, and professional assessment teams to evaluate whether philanthropic capital is truly moving the needle. This shift mirrors the broader institutionalization of family offices, where decisions are measured not only by intent but also by demonstrable results. These vehicles are also undertaking regular audits.

Families often undertake philanthropic activities through Section 8 Companies, Charitable Trusts and Societies. These vehicles enable blended strategies that combine investment returns with targeted social outcomes, allowing philanthropic capital to operate more dynamically. 

Crucially, durable impact requires embedding philanthropy within the family’s broader governance system. Aligning strategy, values, reporting and oversight enables philanthropic commitments to survive leadership changes and remain consistent across generations. When the right structures are paired with disciplined governance and cross-border compliance, families transform philanthropic intent into sustained, verifiable societal impact.

*This article was originally published on Campden website in their newsletter -https://www.campdenfamilyconnect.com/files/newsletter/CMD_Mar_2026.pdf