Why trusts translate poorly here
The trust splits legal and beneficial ownership — a concept civil-law systems process through registers, tax fictions and case-by-case recognition. The result on the continent: friction at banks, opaque treatment at tax offices, and paperwork that never quite settles. The need behind the trust — control here, value there — is legitimate; the instrument travels badly.
The civil-law answer: certification
The Dutch STAK delivers the split natively: the foundation holds and votes the shares under a statute you write; family members hold certificates carrying the full economic value. Control concentrated in a board you design, value already with the next generation, dividends flowing through — and everything registered, recognised and bankable: the mechanism in full.
Where each instrument still wins
Common-law assets and common-law heirs: the trust keeps its home game. Continental companies, EU banking and civil-law heirs: certification wins on recognition alone — and pairs with the governance stichting for the family charter: the governance layer, above the holding: the value layer. Mixed families run both, one per hemisphere.