The failure modes of “good structuring”
Published Date: 19 Jun 2026
Structuring advice is often judged by its technical elegance at inception rather than its ability to withstand real world conditions over time. This article examines how and why well-designed structures fail in practice, distinguishing between design risk (where the structure is inherently misaligned with the client’s circumstances) and implementation risk (where a sound design is undermined by inconsistent execution). Drawing on recurring failure patterns observed across private groups, the article explores breakdowns in banking practices, governance, inter-entity flows and control. It argues that most structural failures arise not from flawed design, but from gradual misalignment between the structure and how the business is actually operated. The article concludes by proposing a practical annual audit approach to identify and address emerging issues before they crystallise into tax, commercial or evidentiary risk.
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- Published By: Russell Krupp
- Published On:19 Jun 2026
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