Cluster A · Cross-Border Multi-Generational Anchor

Casa von Liechtenburg — Mallorca Sils-Maria Cross-Border

Anonymised case · Patriarch 64, matriarch 61, 3 children (29-38), 5 grandchildren · ~CHF 350M patrimony · Palma anchor + Sils-Maria heritage chalet · 14-month mandate (Q2 2025–Q2 2026)

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:

CHF 22M
Palma anchor family trust
CHF 19M
Sils-Maria heritage chalet
14 months
Mandate duration
CHF 350M
Total patrimony

The Beherzig Solution: A 6-Phase Mandate (complex, dual-jurisdictional)

Phase 1: Cross-Border Tax Discovery (months 1-3)

  1. 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)
  2. Preliminary Swiss lump-sum taxation opinion for the Canton of Graubünden with Wenger Vieli Zurich (assessment base of CHF 720,000)
  3. Bilateral Spain-Switzerland treaty 1966/2014: the credit method vs. the exemption method for asset income clarified
  4. Preparation of a Liechtenstein foundation with First Advisory (Vaduz) as a three-generation holding vehicle

Phase 2: Restructuring the Palma Anchor (months 3-5)

  1. Palma Son Vida plateau villa (CHF 22M market value) transferred into a Spanish family trust
  2. Lifelong right of residence (usufructo vitalicio) for the patriarch and matriarch secured by will
  3. The family bodega in Llucmajor (CHF 4M market value) carved out as cultural heritage — gifted to the eldest daughter (33, in Madrid)
  4. 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)

  1. Beherzig Confidential Pool: 4 NDA-protected Sils-Maria/Sils-Baselgia candidates identified
  2. The previous Bernese Oberland chalet sold via Beherzig Off-Market (CHF 14M proceeds; no cultural anchor remaining)
  3. 3 private viewings in Sils-Maria with the patriarch and eldest daughter (summer, Q3 2025)
  4. Preference for a Sils-Baselgia Engadin chalet (built in 1881, 920 m² of living space, 4,600 m² of land, views of Lake Silvaplana)
  5. Off-market negotiation with a Swiss patrician family (4 generations of ties to the Engadin, a cultural handover atmosphere)
  6. 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)

  1. Casa von Liechtenburg Liechtenstein foundation established (a three-generation vehicle: patriarchs, children, grandchildren)
  2. Foundation council: 2 First Advisory lawyers + the patriarch + the eldest daughter (an advisory board as NextGen preparation)
  3. Sils-Baselgia chalet acquisition directly through the foundation (Lex Koller authorisation granted by GR — Sils-Maria recognised as a premium tourism location)
  4. Lump-sum taxation ruling for the Canton of Graubünden signed (CHF 720,000 assessment base, effective from Q1 2026)
  5. 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)

  1. Sils-Baselgia chalet Minergie-standard retrofit (CHF 3.2M, 12-month build period, UNESCO Engadin compliant)
  2. Grisons larch façade restored, the historic parlours (Stuben) preserved in their original state, heat pump and photovoltaics integrated
  3. Cresta Run + Engadin Wolf Network membership (a cultural anchor element for the NextGen of 5 grandchildren)
  4. Beherzig coordinated the Italian-Mallorcan furnishing (transfer of family furniture from Palma)

Phase 6: Multi-Generational Governance + Charity (months 13-14)

  1. A three-generation family council established (patriarchs + 3 children + advisory foundation council), with quarterly meetings rotating between Palma and Sils-Maria
  2. NextGen sub-allocation: CHF 12M per child in a Liechtenstein foundation sub-fund + CHF 2M per grandchild in an education trust
  3. The Casa von Liechtenburg Heritage Foundation (CHF 5M seed capital) finances cultural projects in the Engadin and Mallorca (bilateral heritage restoration)
  4. 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

Multi-Generational Anchor Strategy

Heritage + Charity

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.