Starting Point
Casa von Liechtenburg (anonymised) is a 6th-generation Spanish-German aristocratic family with a patrimony of ~CHF 350M. The patriarch (64, of German descent) and the matriarch (61, of Mallorcan descent) have lived in Palma de Mallorca (the Son Vida plateau) for 28 years — the family has traditionally maintained a summer estate on the Costa Brava and, until now, a winter chalet in the Bernese Oberland. Three children (29, 33, 38) are spread across Madrid, Munich and Milan, with five grandchildren (aged 3-12) between them.
Trigger for engaging Beherzig: the 2026 reform of Spanish inheritance tax in the Balearic Islands (the removal of the previous quasi-exemption for Class I family members) combined with the desire for multi-generational security across at least three generations (a grandchildren track). The family sought a dual strategy:
- Preserving the Palma anchor (Mallorcan cultural roots, the La Almudaina festival calendar, the family bodega in Llucmajor)
- A Swiss cross-border heritage anchor — Sils-Maria/Engadin as the Northern European counterpart, with Swiss tax stability
- Cross-border inheritance tax optimisation between Spain and Switzerland (the bilateral Spain-Switzerland double taxation treaty of 1966, revised in 2014)
- A multi-generational Liechtenstein foundation structure as a three-generation vehicle (patriarchs, 3 children, 5 grandchildren)
The Beherzig Solution: A 6-Phase Mandate (complex, dual-jurisdictional)
Phase 1: Cross-Border Tax Discovery (months 1-3)
- Analysis of Spanish inheritance tax in the Balearic Islands for 2026 with Garrigues Palma (the removal of the 99% reduction for Class I family members)
- Preliminary Swiss lump-sum taxation opinion for the Canton of Graubünden with Wenger Vieli Zurich (assessment base of CHF 720,000)
- Bilateral Spain-Switzerland treaty 1966/2014: the credit method vs. the exemption method for asset income clarified
- Preparation of a Liechtenstein foundation with First Advisory (Vaduz) as a three-generation holding vehicle
Phase 2: Restructuring the Palma Anchor (months 3-5)
- Palma Son Vida plateau villa (CHF 22M market value) transferred into a Spanish family trust
- Lifelong right of residence (usufructo vitalicio) for the patriarch and matriarch secured by will
- The family bodega in Llucmajor (CHF 4M market value) carved out as cultural heritage — gifted to the eldest daughter (33, in Madrid)
- Beherzig coordinated the disposal of the less-used Costa Brava summer estate with Sotheby's Mallorca (CHF 8M proceeds, reinvested in the Liechtenstein foundation)
Phase 3: Sils-Maria Property Sourcing (months 5-8)
- Beherzig Confidential Pool: 4 NDA-protected Sils-Maria/Sils-Baselgia candidates identified
- The previous Bernese Oberland chalet sold via Beherzig Off-Market (CHF 14M proceeds; no cultural anchor remaining)
- 3 private viewings in Sils-Maria with the patriarch and eldest daughter (summer, Q3 2025)
- Preference for a Sils-Baselgia Engadin chalet (built in 1881, 920 m² of living space, 4,600 m² of land, views of Lake Silvaplana)
- Off-market negotiation with a Swiss patrician family (4 generations of ties to the Engadin, a cultural handover atmosphere)
- Final price: CHF 19M (BOMPI +18% relative to the public level of the Sils-Maria plateau in Q4 2025)
Phase 4: Liechtenstein Foundation + Swiss Closing (months 8-10)
- Casa von Liechtenburg Liechtenstein foundation established (a three-generation vehicle: patriarchs, children, grandchildren)
- Foundation council: 2 First Advisory lawyers + the patriarch + the eldest daughter (an advisory board as NextGen preparation)
- Sils-Baselgia chalet acquisition directly through the foundation (Lex Koller authorisation granted by GR — Sils-Maria recognised as a premium tourism location)
- Lump-sum taxation ruling for the Canton of Graubünden signed (CHF 720,000 assessment base, effective from Q1 2026)
- The patriarchal couple officially relocated their primary residence to Sils-Maria (Q1 2026), with Palma as a secondary residence
Phase 5: ESG Retrofit + Heritage Integration (months 10-13)
- Sils-Baselgia chalet Minergie-standard retrofit (CHF 3.2M, 12-month build period, UNESCO Engadin compliant)
- Grisons larch façade restored, the historic parlours (Stuben) preserved in their original state, heat pump and photovoltaics integrated
- Cresta Run + Engadin Wolf Network membership (a cultural anchor element for the NextGen of 5 grandchildren)
- Beherzig coordinated the Italian-Mallorcan furnishing (transfer of family furniture from Palma)
Phase 6: Multi-Generational Governance + Charity (months 13-14)
- A three-generation family council established (patriarchs + 3 children + advisory foundation council), with quarterly meetings rotating between Palma and Sils-Maria
- NextGen sub-allocation: CHF 12M per child in a Liechtenstein foundation sub-fund + CHF 2M per grandchild in an education trust
- The Casa von Liechtenburg Heritage Foundation (CHF 5M seed capital) finances cultural projects in the Engadin and Mallorca (bilateral heritage restoration)
- Beherzig runs an annual 3-day workshop on multi-generational governance in Sils-Maria
Outcome 16 Months Post-Closing (Q2 2026)
Cross-Border Tax Optimisation
- Spain, pre-reform Balearics 2025: quasi-exemption for Class I family members (~0.95% effective)
- Spain, post-reform Balearics 2026 (hypothetically, without migration): ~CHF 38M inheritance tax exposure on the transfer of a CHF 350M patrimony
- Switzerland, Graubünden forfait post-2026: ~CHF 290,000/year (assessment base of CHF 720,000 × 32% effective)
- Cross-border inheritance tax effect: the Liechtenstein foundation + Swiss primary residence fully neutralise the Spanish inheritance tax reform on the foundation's assets
- Palma anchor in a Spanish trust: remains under Spanish law — structured succession with usufructo vitalicio + clases de propiedad
Multi-Generational Anchor Strategy
- Palma anchor: Mallorcan cultural roots — the La Almudaina festival calendar, the Llucmajor bodega, the summer family council in Q3
- Sils-Maria anchor: Swiss stability, Engadin heritage, the winter family council in Q1, Cresta Run cultural membership
- Three-generation vehicle: the Liechtenstein foundation secures the multi-generational patrimony without inheritance tax fragmentation
- Grandchildren track: 5 education trusts (CHF 2M per grandchild) operational from 2026 — locked until age 25
Heritage + Charity
- The Sils-Baselgia chalet becomes the Northern European heritage anchor — heating energy -76% after the Minergie retrofit
- The Casa von Liechtenburg Heritage Foundation finances bilateral Engadin-Mallorca heritage projects (CHF 5M seed capital, CHF 200,000 distributed annually)
- Mallorcan family-furniture heritage integrated into Sils-Baselgia — a visual multi-generational story
Key Learnings for Cross-Border Aristocratic Clientele
1. The 2026 Balearic inheritance tax reform in Spain is a substantial trigger. The previous quasi-exemption for Class I family members falls away — families with a patrimony ≥CHF 100M must respond structurally. Cross-border structuring with a Swiss primary residence + a Liechtenstein foundation is the most effective strategy.
2. Dual-residence models require dual-jurisdictional coordination. A Palma anchor + a Sils-Maria anchor works only with precise application of the Spain-Switzerland treaty 1966/2014. Beherzig coordinates with local Spanish, Swiss and Liechtenstein advisers in parallel — 14 months rather than 8 for a pure single-jurisdiction mandate.
3. The Liechtenstein foundation as a three-generation vehicle. Unlike Spanish family trusts, the Liechtenstein foundation offers multi-generational security across 3+ generations without inheritance tax fragmentation. A foundation advisory board with NextGen involvement is a multi-generational anchor element.
4. Cultural anchor points matter more than tax ones. Aristocratic families do not migrate for tax — they migrate for the cultural stability of their family heritage. Beherzig prioritises the choice of cultural anchor (Suvretta, Sils-Maria, Saanen, Cologny, Verbier) ahead of tax optimisation. Families come to us for heritage; they stay for tax efficiency.