PCD x STEP Isle of Man Conference — The Comis Hotel, 6 May 2026

For years, the private wealth story around Africa has been told almost entirely as an outbound narrative — capital and families leaving, structures set up offshore, a steady drain of talent and assets. The third session at the Comis Hotel complicated that story considerably.

The panel brought together four practitioners with extensive boots-on-the-ground experience across the continent: Julie Howard of Boodle Hatfield (UK tax and wealth structuring for African clients), Ben Arthur of IQEQ (South Africa and Crown Dependencies market development), Mark Swart of Simon Fleming (family offices and ultra-high net worth across South Africa and Canada) and Hanneke Farrand of Farrand Global (trusts and tax law in South Africa). What emerged was a nuanced picture of a market in genuine transition — with the Isle of Man well-positioned to play a meaningful role, if it moves with purpose.

The Outbound Story Has Changed Shape

Hanneke Farrand, whose practice spans decades of South African cross-border work, provided the long view. The early era of offshore structuring was driven by exchange control allowances and, before that, by more creative means of moving capital. The subsequent decade saw families — particularly second-generation members — emigrating and taking funds with them through formal exchange control processes, funding offshore structures as they went.

Today the picture is more nuanced. The dominant trend she now observes is not individual emigration but business globalisation: South African-founded businesses expanding internationally, setting up operational entities offshore while maintaining their home base. "Families are already well-established. They're already here," she said. "Now it's the businesses that are internationalising."

That trend is running alongside a genuine return flow. Julie Howard, who travels to South Africa for client work, noted that the non-dom regime changes effective from April 2025 have prompted some South Africans in the UK to fundamentally reconsider their position. Those who had relocated to take advantage of the remittance basis — a cornerstone of UK tax legislation for over a century — are now weighing up whether the UK remains attractive. Some are returning to South Africa; others are exploring alternatives. Cape Town, in particular, has become visibly more cosmopolitan and significantly more expensive, with property prices reflecting genuine international demand.

South Africa Still Works — If You Structure Early

For families returning to South Africa, the tax environment can be surprisingly favourable — but only for those who have structured correctly before resuming residency. Farrand explained that South African tax law recognises offshore trusts and distinguishes between capital, capital gains and income distributed to South African beneficiaries. If structures are established and optimised ahead of the return, capital can be distributed to beneficiaries with minimal tax consequence, provided trustees are willing to continue making distributions.

The political environment drew a characteristically frank response. "In South Africa, we know what the issues are," Farrand said. "South Africans learn to live with the uncertainty and plan around it." The country's sophisticated private banking infrastructure, high-quality private healthcare and strong professional services base were cited as genuine draws — alongside the immeasurable factor of family and place.

Jurisdiction Selection: DTA, Asset Protection and Cultural Fit

Mark Swart mapped the jurisdictional landscape as South African families and first-generation wealth creators look to externalise. The UK remains a primary destination — not just for lifestyle and education, but as a genuine operational base. "The UK works as a jurisdiction for operating entities," Howard confirmed. "The UK offers an extensive double tax treaty network and works very well for that purpose."

Mauritius retains relevance for structures seeking a DTA with specific African markets and for investment vehicles entering Africa from offshore. However, Cyprus is emerging as an increasingly interesting option — partly on the basis that EU membership remains a live prospect, which would give Cyprus-based residency holders access to an EU resident card. "That's a tangible jurisdictional benefit, not just a tax play," Swart noted.

The Isle of Man, meanwhile, holds a particular resonance with the South African market that goes beyond technical criteria. Cultural familiarity matters: the ability to speak with advisers who understand the client's background, share a legal heritage and can navigate the specific nuances of South African exchange control and cross-border planning is a genuine differentiator. Swart was direct on the IOM's pitch: "Asset protection, skilled professionals, an active professional body. We should be thinking collectively about how we target this market and put the jurisdiction first."

Nigeria, Kenya and the Wider Continent

South Africa dominated the discussion, but the panel gave substantive time to the rest of the continent. Nigeria is the most developed of the emerging markets for private wealth structuring, with a strong appetite for UK real estate and growing interest in sophisticated trust and succession structures. The complexity, however, is considerable: many Nigerian families have US-connected children, requiring US tax advice to be integrated from the outset.

Howard also flagged the statutory residence test traps for Nigerian parents whose children are at UK boarding schools — patterns of parental visits and time spent by the children in the UK during school holidays can inadvertently create UK family ties, which along with other ties can trigger residency depending on day counts.

West Africa more broadly presents a different risk profile: currency devaluation in Nigeria of around 70% over five years is a powerful driver of externalisation, but the market is less sophisticated and the desire to structure quickly can cut against proper governance. "That's the downside gap," Arthur noted.

Kenya was flagged as the market to watch. Arthur's observation was striking: Covid changed everything. Before the pandemic, Kenyan families had little tradition of succession planning — a cultural assumption of invincibility, as he described it. Post-Covid, that changed sharply, and the local professional infrastructure for structuring and governance has been developing in parallel.

First-generation business founders are increasingly thinking about how to transition ownership to a second generation that may not share the same operational capability. "Kenya is going to be one to watch," Arthur said. Having a presence on the ground and access to the large Indian community — historically the anchor of private wealth in East Africa — remains essential for meaningful market access.

Investment Back into Africa: The Offshore Fund Play

One of the more commercially interesting observations came from Swart on the flow of capital back into Africa through offshore structures. Crown dependencies and other tax-neutral or transparent jurisdictions are increasingly being used as holding platforms for investment vehicles — LP/GP structures and similar — through which offshore and international investors can deploy capital into African markets. The returns remain attractive by developed-market standards, and the demographic outlook is compelling: projections suggest a 65% growth in the number of millionaires across Africa over the next decade.

"If you want to sell something, you want to sell it to people who have money to spend," Swart said. "Africa is generating that wealth at pace." The entrepreneurial culture across the continent — particularly visible in Nigeria and Kenya — is producing first-generation wealth creators whose offshore structuring needs are only beginning to be served.

Trump, Geopolitics and the Quiet Question of US Appetite

The geopolitical dimension surfaced through a discussion of South Africa's unusual position on the world stage. Swart described arriving at a Cape Town hotel to find Chinese military and Russian military delegations both in residence — a vivid illustration of South Africa's navigation between competing global blocs. The country's historical non-alignment, its current political leadership and its relationships with both Western and Eastern powers create a complex backdrop for wealth planning.

The Trump administration's posture toward South Africa has introduced a new layer of uncertainty. Farrand was candid: in the past six months, South African clients have become more sceptical about the US as a destination — for structuring, for lifestyle and for investment. The tariff environment, the bilateral tensions and the uncertainty about US economic direction have made the calculation more complicated. "It's a sad thing," she said. "Just as you see all this amazing energy in Cape Town, something else hits."

Philanthropy: Substantial, Quiet and Underreported

The session closed on the question of charitable giving — and the panel's view was consistent: the scale of philanthropy among South African wealthy families is significant and almost entirely invisible. It does not flow through formal fundraising events or publicised campaigns. It is direct, community-rooted and driven by a personal sense of obligation. "We have no idea how much is actually happening," Farrand said. "The families just give." Swart echoed the point: the majority of his clients are actively giving back — to community upliftment, religious causes or local needs — either personally or through their structures, without any desire for recognition.

For advisers, this represents both a planning opportunity and a relationship dimension that should not be overlooked. The values that drive quiet philanthropy often align closely with the values driving succession and legacy planning — and understanding those values is where the most durable client relationships are built.

Session 3 was moderated by David Bell. Panellists: Julie Howard (Boodle Hatfield), Mark Swart (Simon Fleming), Ben Arthur (IQEQ) and Hanneke Farrand (Farrand Global).