Holding company at the top. SPV beneath each property.
The fundamental architecture is straightforward: the client's personal holding structure is the majority owner of each property via SPVs. Nordic Estates Asset Management co-invests its own capital as a minority partner in every SPV. The player therefore retains controlling influence and we keep real skin in the game on every deal. This structure – known as a 'group structure' in Danish company law – is an industry standard in institutional property management and offers four key advantages.
The Four Advantages
Risk Isolation
A dispute or a significant unexpected liability on one property does not impact the others.
Tax Optimisation
Corporate taxation at 22% instead of marginal personal tax on ongoing operations.
Intergenerational Transfer
Shares in a holding company are more easily transferred than property deeds.
Transparency
Banks, auditors, and authorities view one consolidated structure – not scattered personal ownerships.
Risk Isolation in Practice
Should a tenant initiate litigation that escalates into a substantial liability claim, the legal responsibility will reside with the SPV that owns the property in question. This implies that neither the client's private assets, their other properties, nor their holding company can be directly affected.
Similarly: if a property is unexpectedly hit by a major maintenance obligation that exceeds the SPV's own funds, that SPV could, in the worst case, go bankrupt without dragging the rest of the portfolio down. We have never encountered this scenario in practice – precisely because our conservative lending and provisions prevent it – but the structure exists to make it possible.
This is the kind of protection one hopes never to need. It is also why the structure is established on day one, not when the problem has already arisen.
Tax Efficiency Over a Long Horizon
Ongoing operating profits within an SPV are subject to corporate tax (22% in Denmark) instead of marginal personal income tax (up to approximately 55.9% including labour market contribution in 2026). The difference is dramatic over a 30-year horizon – particularly because retained funds can be reinvested within the company without intervening personal taxation.
Personal taxation only applies when the client actually disburses funds from the holding company as dividends or salary. This offers a significant optimisation opportunity: disbursements can be timed to years or jurisdictions where the client's personal tax rate is lower – for example, after career cessation or relocation to a lower-tax jurisdiction.
Frictionless Intergenerational Transfer
In the event of an inheritance or intergenerational transfer, it is simpler – and typically more cost-effective – to transfer shares in a holding company than to transfer deeds for 4–6 individual properties. The entire portfolio can practically be transferred with a single document, whereas deed transfer would necessitate separate registration, valuation, and duty payments per property.
As standard, we establish a marriage settlement and a will that integrate with the corporate structure, ensuring that intergenerational transfer is prepared from day one – not something to be improvised later.
"A good structure is one the client never thinks about. A bad structure is one they call about every quarter."
Read about the SPV structure in detail
The technical aspects of Special Purpose Vehicles.