What is the structure that allows income splitting between beneficiaries and ease of succession?

The structure that allows for income splitting between beneficiaries and ease of succession is a discretionary trust. Discretionary trusts provide flexibility in income distribution, as the trustee has the authority to decide how the income and capital are allocated among the beneficiaries. This means that income can be split among beneficiaries in a tax-effective manner, taking advantage of lower tax brackets for individuals if the income is distributed proportionally.

Moreover, discretionary trusts facilitate succession planning, as the trust can continue to operate beyond the life of the original trustee or beneficiaries. The structure allows for a seamless transition of assets and management without the need for probate, as the trust's assets are not personally owned by the beneficiaries but are held in trust. This feature makes them particularly appealing for family businesses or investment purposes, where continuity and tax efficiency are important objectives.

In contrast, the other options offer different characteristics. A sole trader has limited capacity for income splitting and can pose challenges during succession due to a direct link between business ownership and individual liability. A cooperative is designed for group ownership and community benefit rather than individual income splitting. A public company involves shareholders and typically operates under more stringent regulations, making it less flexible in terms of addressing the specific needs of beneficiaries and succession planning.