Institutional Isomorphism and the Geopolitics of Wealth Defense: A Comparative Legal and Political Economy Analysis of Family Office Regimes in Indonesia, Singapore, and Hong Kong

Abstract

The early 21st century has witnessed a significant migration of global capital accumulation to the Asia-Pacific region, precipitating a concurrent rise in the demand for sophisticated wealth management vehicles. This trend has catalyzed a fierce "regulatory competition" among jurisdictions seeking to position themselves as the premier domicile for Ultra-High-Net-Worth (UHNW) capital. This study provides an exhaustive, multi-disciplinary analysis of Indonesia’s emerging initiative to establish a domestic Family Office (FO) regime, juxtaposed against the mature, dominant ecosystems of Singapore and Hong Kong. Grounded in Institutional Theory—specifically the mechanisms of mimetic isomorphism—and the political economy of the Wealth Defense Industry, this study interrogates the structural viability of Indonesia’s proposal. Central to this inquiry is the profound jurisprudential incompatibility between Indonesia’s Civil Law tradition—rooted in the unitary concept of ownership (Eigendom)—and the Common Law trust structures that underpin global wealth preservation. The article critically examines the Omnibus Law on the Development and Strengthening of the Financial Sector (UU P2SK) as a legislative attempt to bridge this divide through the statutory creation of "Trustees". Furthermore, it evaluates the efficacy of fiscal incentives, particularly the tax holidays proposed for the Nusantara Capital City (IKN), in the context of the OECD’s Global Minimum Tax (Pillar Two) framework. The study argues that while Indonesia possesses the economic base to sustain a domestic FO industry, its success is contingent upon a fundamental restructuring of legal certainty, beneficial ownership transparency, and the successful mitigation of "institutional voids." Without these structural reforms, the FO initiative risks devolving into a mechanism for legitimizing tax avoidance and entrenching oligarchic wealth defense rather than serving as a catalyst for genuine economic development.