• Change of Control Notifications via GFSC Portal

As of the 1^st June 2026, Change of Control notifications pursuant to the Financial Services Act 2019 (“FSA”) may be submitted to the GFSC via the GFSC’s online portal (“GFSC Portal”). Accordingly, notifications relating to acquisitions, increases, reductions or cessations of control in respect of Gibraltar Regulated Firms may now be submitted via the GFSC Portal.

Key features introduced by the GFSC Portal include logic-driven forms, automated information requests, the development of structure charts, as well as live status tracking. This will enable for an overall streamlining of such notifications with added efficiencies and benefits for firms, proposed acquirors and advisors, as well as for the GFSC itself.

In order to assist with these changes, the GFSC has made comprehensive guidance available on its website outlining the functionality of the GFSC Portal, including video tutorials and FAQs.

• Change of Control – GFSC Guidance Notes

The GFSC has also published, on 1^st June 2026, a new set of Guidance Notes on Change of Control: Assessment of Acquisitions and Increases in Control (“COC Guidance Notes”). The COC Guidance Notes are relevant to all Gibraltar regulated firms and replace previously applicable EU Guidelines with a set of Gibraltar specific guidelines.

As those familiar with the Gibraltar Authorisation Regime (“GAR”) regulatory alignment process will note from the publication of recent GFSC guidance notes, these COC Guidance Notes are largely consistent with UK FCA/PRA equivalent guidance. This includes on matters such as conditional approvals, aggregation of holdings, practical guidance on submitting notifications and approach to financial crime assessments.

By way of summary, the COC Guidance Notes set out the GFSC’s expectations on the following issues:

• identifying controllers, including the concepts of significant influence, aggregated holdings and indirect controllers;
• the submission of a section 111 notice and the approach to completeness;
• the notification obligations of Gibraltar-regulated firms;
• the assessment criteria; and
• the GFSC’s use of its statutory power to attach conditions to an approval where doing so advances any of its regulatory objectives.

Should you have any queries on or require assistance with change of control matters, please contact Partner, Christian Caetano. Christian may be reached directly at christian.caetano@isolas.gi.

This informative session will explore the evolving landscape of artificial intelligence regulation, data protection, and compliance under the GDPR and the EU AI Act, providing practical guidance for organisations navigating this fast-developing area.

Attendees will gain practical insights into AI governance, regulatory obligations, and compliance in an increasingly digital workplace.

Join us on Thursday, 25th June from 16:30 – 18:00pm, followed by drinks and networking.

Limited spaces available.

RSVP today – events@isolas.gi

Family Office Structures: Built Years Ago, Still Right Today? For Summary Q&A click here. 

Most family offices don’t start with a blank page.

They inherit something: a trust settled years ago, a holding company that has quietly sat at the centre of things, together with a set of arrangements that made perfect sense at the time they were put in place.

They continue, adapt slightly and expand around the edges.

And slowly, almost without noticing, the structure stops being a decision and becomes part of the background.

It works. It is familiar. No one is entirely sure when it was last reviewed, but it is not causing any obvious problems – so it remains as is.

This is how many family office structures evolve, not through deliberate design, but through continuity, and continuity is powerful. It carries institutional memory, preserves stability and avoids unnecessary disruption.

But it also carries assumptions.

The context in which many of these structures were originally created has shifted, often significantly. Families are more international, assets are more complex, and the expectations of the next generation are different from those of the previous. Transparency, governance and control are no longer side considerations, they are central issues.

Yet the structures themselves often remain anchored in an earlier version of the same family.

The uncomfortable question, rarely asked directly is simple: if we were setting up this structure today, would we do it this way?

That question tends to open the door to jurisdictions that are not always part of the immediate conversation.

Gibraltar is one of them.

Not because it presents itself as a default or an obvious first choice, but because it invites a more deliberate assessment of what the structure is actually trying to achieve.

When families explain why their arrangements sit where they do, the reasoning is usually framed in terms of certainty, established jurisdictions, recognised legal systems and deep pools of advisers. All of these are important.

But beneath that is something more human, a preference for what is known. Structures that are easy to explain, easy to replicate, and unlikely to raise questions at the wrong moment.

That instinct is entirely rational, but is not always aligned with what works best over time.

Family office structuring today is less about preserving assets in a static environment and more about managing change across generations. Governance matters more. Flexibility matters more. The ability to adapt without rebuilding from scratch is often the difference between a structure that lasts and one that slowly becomes constraining.

This is where Gibraltar’s profile becomes interesting.

It combines a legal system that is immediately recognisable, common law, English derived, predictable in its reasoning, with a scale that changes how advice and regulation actually feel in practice.

Decisions are not abstract. The people advising on a structure are often directly involved throughout its life. Engagement with regulators is not filtered through layers of process. There is a directness with how things operate that is difficult to replicate in larger centres.

More than that, in a smaller jurisdiction the key participants tend to be visible and accessible. Regulators, banks, advisers and, where needed, even policymakers are not distant institutions but reachable individuals. Conversations happen earlier, issues are addressed more directly, and structures can be shaped with a clearer understanding of how they will be treated in practice.

For a family office, that has real value. It changes the experience from navigating a system to engaging with it.

A structure is not just defined by how it is set up, but by how it behaves over time. How quickly can it respond to change? How straightforward is it to refine governance as the family evolves? How accessible are the individuals who help navigate those decisions?

These questions rarely feature in initial jurisdiction comparisons, but they tend to surface later, when the structure is under pressure.

In a smaller jurisdiction, continuity is not just a characteristic of the structures, but of the advisers behind them. ISOLAS, having been established in Gibraltar since 1892 maintains relationships with families, which often extend across generations. Advisers are not introduced at the point of a transaction, but much earlier, with successive generations becoming familiar with the structure and the decision-making process over time.

That continuity has practical value. When moments of transition arise, succession, governance changes, or the need to revisit long-standing arrangements, those advising are not approaching matters in isolation. They understand the history, the context and the family dynamics, allowing the conversation to move more quickly from explanation to solution.

And when you look more closely at how modern family office structures are actually used, certain features start to matter more than headlines.

The ability to use private trust companies to retain a degree of family control without undermining governance. The flexibility of trust law that accommodates multi-generational planning without constant restructuring. The availability of foundations as an alternative for families less comfortable with traditional trust concepts, while still seeking permanence and clarity of purpose.

Alongside this sits the corporate layer, often overlooked but critical. A system where companies are taxed on a largely territorial basis creates a different dynamic for globally held assets, particularly where underlying income is not sourced locally.

For principals and senior executives within the family office, personal structuring also becomes part of the equation. Specialist tax regimes, such as Category 2 Status and High Executive Possessing Specialist Skills (HEPSS) are not, in themselves, the reason to choose a jurisdiction, but they reflect a broader philosophy with an ecosystem designed around mobile families and key decision-makers.

In practical terms, Category 2 Status provides a capped tax exposure, with tax payable on a maximum assessable income of £118,000, resulting in a maximum annual liability of approximately £42,380, regardless of actual worldwide income. HEPSS, by contrast, is focused on senior executives, capping taxable earned income at £160,000 per annum.

These are not headline features in isolation. They illustrate a consistent theme, namely that the jurisdiction is structured with an understanding that capital, control and individuals do not move independently of one another.

Set against that is lifestyle, which is often treated as peripheral, but rarely is in practice. The anticipated UK–EU treaty arrangements, including the proposed removal of the land border between Spain and Gibraltar and the potential for Gibraltar to participate in a Schengen-style framework, would further reinforce what is already a distinctive proposition, a stable legal base combined with seamless access to a broader Mediterranean environment.

There is also a broader dynamic at play.

Larger, more established jurisdictions excel at standardisation. They offer depth, consistency and a degree of institutional familiarity that is hard to match. That is why they dominate.

But scale brings inertia.

Change is slower, innovation is more considered, and structures tend to follow well-trodden paths. That works well when the objective is predictability. It is less effective when the objective is adaptability.

Smaller jurisdictions operate differently. They are closer to the clients they serve, quicker to engage with new ideas, and more willing to shape solutions around specific circumstances rather than fit circumstances into existing templates.

Gibraltar sits firmly in that category.

Its approach to areas such as digital assets has demonstrated how that responsiveness can be translated into practical frameworks; however, for family offices, the more relevant consideration is cultural rather than technical.

There is an embedded willingness to engage with complexity, rather than defer it.

That matters when dealing with multi-generational wealth, where the questions are rarely standard and the answers rarely sit neatly within pre-existing structures.

What makes this slightly counterintuitive is how much effort families typically invest elsewhere.

Investment strategies are scrutinised in detail. Managers are selected carefully. Asset allocations are debated at length.

The structure that holds all of it together, often the single longest-lived element of the entire ecosystem, is given comparatively little attention once it is in place.

It becomes part of the scenery.

Revisiting it feels unnecessary, until it becomes necessary.

Gibraltar is not the answer in every case. Sometimes the existing arrangements remain entirely appropriate. Sometimes the benefits of familiarity outweigh the advantages of change.

But what Gibraltar does, quietly, is prompt a reassessment.

It is sufficiently different to make the decision an active one again. It requires the family and its advisers to revisit the fundamentals, what the structure is for, how it is meant to operate, and whether it still reflects the reality of the family it serves.

That exercise, in itself, is where most of the value sits.

Because in family office structuring, the risk is rarely that nothing exists. It is that what exists is no longer aligned with what is needed, and no one has paused to notice.

And that is not a question of jurisdiction.

It is a question of whether the structure is still doing its job.

For those establishing family office structures today, the question is slightly different, but no less important. It is not about revisiting what exists, but about getting it right from the outset. Jurisdiction, governance and flexibility are not decisions that sit at the margins, they shape how a structure will operate across generations.

In that context, this may be the moment to consider alternatives more deliberately. Gibraltar, for the reasons outlined above, is not always the default answer. But it is increasingly a considered one.

On 15 July 2026, the UK–EU Agreement in respect of Gibraltar enters provisional application. It is the most significant development in Gibraltar’s relationship with the European Union since Brexit, but its practical effect is often misunderstood. For summary Q&A click here. 

For fund managers, the starting point is clear: the treaty does not change Gibraltar’s fund framework. The EIF and Private Fund regimes remain domestic legislation. They were unaffected by Brexit and are unaffected by the treaty.

It also does not restore financial services passporting across the European Union – we will not be within the single market of the EU. Fund managers marketing into EU member states will continue to do so on a private placement basis, as before.

The post Brexit UK–Gibraltar passporting arrangement, which provides Gibraltar authorised firms with unique access to the UK market, remains separate and unchanged.

Set out in those terms, the treaty appears to do very little for the funds industry.

That, however, is not where its significance lies.

The treaty does not change the framework itself. What it changes is the environment in which that framework operates, and, more importantly, the equation for where fund principals choose to base themselves.

Historically, Gibraltar’s principal constraint in this respect has been practical rather than structural. The Gibraltar–Spain border has been a persistent friction point, with uncertainty around post Brexit arrangements creating hesitation for individuals considering Gibraltar as a long term base.

The treaty removes that uncertainty. Border controls are eliminated, Schengen checks are relocated to Gibraltar’s port and airport, and cross border movement is placed on a stable and permanent legal footing. For fund principals and senior executives and their staff, that is a material shift.

More significantly, the treaty introduces a mobility advantage that did not previously exist in this form. Gibraltar residents are not subject to the EU’s Entry/Exit System or ETIAS, and are not constrained by the 90 day Schengen limit within Gibraltar applicable to UK nationals.

In practical terms, this creates a meaningful distinction. A fund manager based in London travelling regularly to meet investors across Europe operates within a constrained framework. A fund manager resident in Gibraltar does not.

This sits alongside a residency proposition that was already well established. Gibraltar offers a common law framework, a stable fiscal environment, and well understood personal tax regimes for internationally mobile individuals.

In particular, high net worth individuals relocating to Gibraltar may benefit from the Category 2 regime, under which personal income tax is capped regardless of worldwide income, and the High Executive Possessing Specialist Skills (HEPSS) regime, which provides a separate framework for senior executives relocating to Gibraltar to take up roles requiring specialist expertise.

The practical effect is that Gibraltar already presented a compelling proposition for fund principals and senior executives from a personal tax and lifestyle perspective. The treaty adds a further dimension to that proposition in the form of Schengen mobility, which is not currently available to UK based individuals in the same way.

Taken together, the combination of mobility, personal tax structuring, and an established fund framework presents a position that few competing jurisdictions can offer in parallel.

There is also a broader signal. The agreement reflects a settled political consensus between the UK, Spain and the EU as to Gibraltar’s long term position. For some managers, that removes a residual uncertainty which, while not always decisive, has been a factor in decision making since Brexit.

Seen in that context, the treaty does not make Gibraltar’s fund regime more attractive than it was. What it does is remove the peripheral constraints that sat alongside it.

For fund managers who have previously looked at Gibraltar, the conclusion is not that the underlying structures have changed. It is that the reasons not to use them have been reduced.

The question is no longer whether the regime works, but whether there remains a barrier to locating both the fund and the manager there. The change is happening.

 

Partner James Montado participated in the panel discussion on Innovation & Regulatory Sandboxes at the Gibraltar Regulatory Authority’s data protection workshop, “Data Protection Today for a Trusted Tomorrow.”

Joined by industry experts, the panel explored how regulation can encourage innovation while maintaining robust data protection standards and trust in the digital economy.

A valuable and timely discussion on the future of data protection.

There is a moment in every fund formation when someone in the room says “we’ll just do it in Cayman” with the same energy someone orders the house wine at a restaurant they’ve never been to before. Safe. Familiar. Probably fine.

And like the house wine, it usually is fine. Which is exactly the problem.

Jurisdiction selection has become a habit dressed up as a decision. Managers reach for Cayman or Luxembourg not because they’ve evaluated the alternatives but because the last fund was there, the investors recognise it, and the lawyers have the documents on file. The actual question of what structure best serves this strategy, these investors, and this manager goes largely unasked.

Gibraltar is interesting not because it’s an obvious choice. Some managers never consider it. It’s interesting because of why they don’t, and what that reveals about how the industry actually makes decisions.

Ask an investor why they prefer Cayman structures and you’ll get answers that sound like analysis: established legal precedent, deep service provider ecosystem, institutional recognition. These are real. They’re also largely circular. Cayman has institutional recognition because institutions use it. Institutions use it because it has institutional recognition.

What investors are really expressing is a preference for legibility. They’ve seen the documents before, their lawyers know the regime, the risk is comprehensible even if it isn’t necessarily lower. This is rational. It is not the same as optimal.

Gibraltar funds carry a comprehensibility discount, not because they’re riskier, but because they require someone to do new reading. In a world where investment committees are time-constrained and legal budgets are fixed, “I haven’t seen this before” functions as a veto that has nothing to do with the merits.

The implication for managers is underappreciated: jurisdiction selection is partly an investor relations decision, not just a legal one. The best structure for a strategy is sometimes not the one you can actually raise money into.

Strip away the familiarity discount and Gibraltar has a genuinely unusual profile. It is a common law jurisdiction, English-derived, judicially competent, politically stable, attached to a regulator (the GFSC) that is small enough to be genuinely accessible. Partners at law firms in Gibraltar take calls. The regulator has views and shares them. For a manager navigating a novel structure or an edge-case asset class, that accessibility has real economic value that doesn’t appear on any term sheet.

The DLT framework, the world’s first purpose-built regulatory regime for distributed ledger technology businesses, is the clearest example of what a small, nimble jurisdiction can do that a large one cannot. Luxembourg cannot pass a bespoke crypto regulation in two years. It has too many stakeholders, too many in-built interests, too much existing infrastructure to protect. Gibraltar can, and did, because the decision involved one room, not twenty.

Small jurisdictions innovate at the edges. That’s not a bug.

Here’s the unexpected part: the most interesting thing about Gibraltar isn’t Gibraltar. It’s the question of why the fund industry, an industry that prides itself on rigorous analysis, asymmetric thinking, and finding value where others aren’t looking, applies almost none of those instincts to its own operational infrastructure.

A manager will spend months on a single line in a spreadsheet. The same manager will spend approximately one meeting deciding where to domicile a fund that will operate for ten years, hold hundreds of millions in assets, and shape the legal relationship with every investor they have.

The house wine gets ordered. The fund goes to Cayman.

Gibraltar is a useful provocation because it forces the question. It’s unfamiliar enough that you can’t default. You have to actually decide. And in deciding, you might discover that the answer is still Cayman. But you’ll know why, which is a different thing entirely from just knowing where.

The rock doesn’t move. But the assumptions we build on top of it should.

 

Delighted to share highlights from a presentation delivered by Partner Steven Caetano to Entain on the Gibraltar Gambling Act 2025.

The session explored the significant regulatory transformation underway in Gibraltar’s gaming sector, including expanded regulated activities, updated marketing requirements, the incoming regulated individual’s framework, strengthened enforcement powers and supply chain approvals.

The presentation also covered the strategic implications of recent fiscal changes for operators servicing the UK market, upcoming new codes of practice and the EU Treaty as Gibraltar continues its evolution as a leading international gaming jurisdiction with a strong focus on transparency, compliance and long-term sustainability.

Thank you to the Entain team for the positive feedback engaging and insightful discussion.

“The knowledge-sharing session delivered by Isolas offered valuable perspectives for stakeholders across our key business areas. Steven Caetano presented insights into Gibraltar’s evolving gaming landscape and recent legal and regulatory changes. The session provided clarity and practical guidance that supported our teams’ understanding of these important developments. We appreciate the session delivered by Steven and thank the ISOLAS team” Entain

ISOLAS LLP hosted another successful Women in Enterprise breakfast in partnership with the Gibraltar Federation of Small Businesses marking the final quarterly session of the series before it resumes in September.

The May session, Building Resilience as a Female Leader, included a panel discussion with Hayley Xerri (Chartered MCIPD), Chief Operating Officer of ISOLAS LLP, alongside Katie Muldoon and MJ Feeke.

The discussion explored how resilience is strengthened through adaptability, continuous development, and supportive workplace cultures.

Hayley shared reflections from her leadership experience, including balancing senior responsibilities with family life while raising two young children, and the importance of support systems and prioritisation in sustaining performance and wellbeing.

The session was well attended, with strong engagement throughout.

Thank you to Women in Enterprise and the Gibraltar Federation of Small Businesses for organising.

Congratulations to GibSams on another well attended and thoughtfully delivered Wellbeing at Work Conference 2026, which brought together professionals from across Gibraltar to discuss workplace wellbeing and organisational culture.

The session, moderated by ISOLAS LLP Senior Partner, The Hon Albert J. Isola CBE, brought together senior voices from financial services, social care, and the private sector to consider how organisations balance performance and productivity with the wellbeing of their people.

A consistent theme throughout the discussion was that wellbeing at work is most effective when embedded in leadership behaviour, workplace culture, and day to day decision making, rather than treated as a standalone initiative.

The conference provided a timely forum for these discussions, alongside a continued focus on advancing mental health awareness and promoting wellbeing across Gibraltar.

 

Periods of geopolitical uncertainty often prompt internationally mobile individuals and families to reassess where they live, work, and hold their wealth. Recent developments across global markets and geopolitics have once again led many advisers and families to revisit that discussion.

In that context, Gibraltar is increasingly re‑entering the conversation.

Not as a reactionary solution, but as a jurisdiction that has quietly built a reputation over several decades for stability, certainty, and accessibility.

A Jurisdiction Built on Certainty

One of Gibraltar’s long‑standing attractions for high net worth individuals is its clear and predictable personal tax framework, together with the well-established Category 2 Status regime. Gibraltar provides a clear and predictable tax position for individuals, with well‑defined rules on what income is subject to Gibraltar taxation.

 Understanding Category 2 Status – With an Eye on Future Developments

The Category 2 (“Cat 2”) regime has long been part of Gibraltar’s offering for high net worth individuals seeking residency with a clear and predictable tax position. The Government of Gibraltar has recently announced a periodic review of the Cat 2 framework. No draft proposals have been published, and no changes have been announced.

Historically, such reviews have focused on modernising or refining existing criteria, such as an increase in regards to the minimum net assets required, rather than altering the underlying regime.

The current rules are as follows:

Cat 2 applicants must:

• Demonstrate minimum net assets of £2 million
• Own or rent an approved Cat 2 property
• Maintain private medical insurance for themselves and any dependants

Taxation of Cat 2 Individuals

Cat 2 status provides a predictable and capped Gibraltar tax exposure:

• Minimum annual tax liability: £37,000
• Maximum annual tax liability: £42,380
  (calculated on the first £118,000 of worldwide income)

This means that Cat 2 individuals pay Gibraltar tax only within this defined band, regardless of overall worldwide income.

Key points include:

• Only the first £118,000 of worldwide income is considered for the purpose of calculating the maximum liability.
• Gibraltar source income, such as Gibraltar rental income or income from trade, business, or employment carried out in Gibraltar, is not subject to the Cat 2 cap and is taxed instead under standard Gibraltar tax rules.

A Stable and Long Standing Regime

Gibraltar’s Cat 2 framework has historically remained stable and consistent over several decades. Any future refinements arising from the current review are expected to build on this long standing approach, maintaining the clarity and predictability that internationally mobile individuals and families value.

A Stable and Long‑Standing Regime

Unlike many jurisdictions where tax frameworks have been subject to repeated revisions, Gibraltar’s Cat 2 regime has remained consistent for decades. This stability is a key differentiator, particularly for families planning multi‑year or multi‑generation strategies.

Other Advantages

Alongside Cat 2 status, Gibraltar offers several features familiar and attractive to internationally mobile families:

• No capital gains tax
• No wealth tax
• No inheritance tax
• A common law legal system based on English law
• English as the language of business and law

For many advisers and families, these create a level of legal and fiscal certainty that is increasingly valued in today’s environment.

Accessibility and Lifestyle

For many individuals considering relocation, lifestyle considerations carry equal weight to fiscal ones.

Gibraltar offers a distinctive blend of Mediterranean climate and lifestyle with British legal, cultural, and institutional structures. Its international financial services sector is mature and well regulated, with a reputation for credibility and professionalism.

Accessibility is another important factor. Direct flights connect Gibraltar with London in around two hours, allowing individuals to maintain strong ties with the UK while enjoying a markedly different lifestyle on the southern edge of Europe.

A Changing European Context

Another development attracting attention is the evolving relationship between Gibraltar and the European Union following Brexit.

A recently published draft treaty text outlines a proposed framework between the United Kingdom, Spain, and the EU governing Gibraltar’s future relationship with the surrounding region.

While the arrangements still require ratification, the framework envisages:

• Fluid movement between Gibraltar and Spain, with the removal of routine checks at the land frontier
• A mobility model broadly aligned with Schengen Area travel arrangements
• Greater ease of access into the wider European region for Gibraltar residents

If implemented, residents would benefit from seamless connectivity across the frontier while Gibraltar retains its constitutional relationship with the United Kingdom.

For internationally mobile families, this potential combination of British governance and enhanced European mobility is particularly noteworthy.

Stability and Safety

Another factor increasingly raised by families considering relocation is personal security and political stability.

Gibraltar has long been regarded as a safe, well‑regulated jurisdiction supported by a stable political environment and a strong rule‑of‑law framework. In recent global safety assessments, Gibraltar has been ranked among the world’s safest jurisdictions – reflecting both low crime levels and a stable civic environment.

For families relocating internationally, particularly those with children, this sense of safety and community is often as important as fiscal considerations.

A Quietly Attractive Proposition

In many respects, Gibraltar’s appeal lies in its consistency.

It is a jurisdiction with a long‑established financial services sector, a robust regulatory framework, and a reputation for political stability. In an environment where global mobility and wealth planning are increasingly shaped by geopolitical developments, that stability is often what internationally mobile families value most.

For some individuals, Gibraltar may represent a primary residence. For others, it may serve as a strategic base within a broader international footprint.

Either way, it remains a jurisdiction that continues to quietly merit consideration.