Why common-law funds translate poorly here
The common-law family fund splits legal and beneficial ownership between a fiduciary and the beneficiaries. Civil-law systems process that split through registers, tax fictions and case-by-case recognition. The result here is friction at banks and opaque treatment at tax offices. The paperwork never quite settles. The need behind the fund, control in one place and value in another, is legitimate. The instrument itself does not transfer well to civil-law countries.
The civil-law answer: certification
The Dutch STAK provides that split by design. The foundation owns and votes the shares under a statute you write. Family members receive certificates for the full economic value. A board you design controls the foundation, while the next generation already has the value. Dividends still reach the family, and everything is registered, recognised and bankable. See the full explanation.
Two Dutch companies, one above the other, each with its own deed of incorporation: the Dutch holding structure for non-residents. The shareholder register, the board decisions and the yearly filings of both: corporate secretarial services in the Netherlands.
The holding, the STAK foundation and a foundation for giving: the three building blocks of a family office in the Netherlands, and the three ways families organise the decisions.
Where each instrument still works best
For common-law assets and common-law heirs, the common-law fund still works best. For continental companies, EU banking and civil-law heirs, certification is the better choice, based on recognition alone. Certification also pairs with a separate governance foundation for the family charter (explained here), placed above the holding company itself (the details here). Mixed families often use both together.