Tax & Wealth
Tax-residence planning, non-dom regimes, special tax status, and wealth-structuring considerations across jurisdictions.
Tax residency and wealth structuring for new United Arab Emirates residents
The question of when a high-net-worth individual becomes a UAE tax resident has never been more consequential, because the Federal Tax Authority’s enforcemen…
Tax residency and wealth structuring for new Antigua and Barbuda residents
The question of how Antigua and Barbuda taxes its newest residents has become materially more consequential since the Citizenship by Investment Unit (CIU) pr…
Tax residency and wealth structuring for new Australia residents
In April 2026, the Australian Tax Office updated its online residency guidance to clarify that a person holding a temporary visa can still be an Australian r…
Tax residency and wealth structuring for new Canada residents
Canada’s tax system for new residents operates on a fundamentally different premise than the territorial or remittance-based regimes found in jurisdictions s…
Canada departure tax: the deemed-disposition rules on emigration
For a Canadian resident who has built substantial wealth inside the country’s tax-sheltered structures, leaving is not a simple act of boarding a flight. The…
Tax residency and wealth structuring for new Switzerland residents
The Swiss federal tax framework for new residents is not a single regime but a layered system of cantonal and communal laws, federal statutes, and bilateral…
Tax residency and wealth structuring for new Costa Rica residents
Costa Rica’s tax framework for new residents is defined by a territorial system that taxes only Costa Rican-source income, a feature that becomes materially…
CRS (Common Reporting Standard): what HNW migrants should know in 2026
The Common Reporting Standard, or CRS, is not a new regime — it has been operational since 2017 across more than 110 jurisdictions — but a series of 2025-202…
Tax residency and wealth structuring for new Cyprus residents
Cyprus operates one of the most tax-efficient residency regimes in the European Union for high-net-worth individuals, yet the distinction between becoming a…
Cyprus IP Box: how the effective 2.5% rate is computed in 2026
The Cyprus intellectual property box regime has been a fixture of European tax planning since its 2012 introduction, but a 2026-specific recalculation of the…
Tax residency and wealth structuring for new Germany residents
Germany’s tax system for new residents is among the most aggressive in continental Europe for high-net-worth individuals, yet a significant portion of the we…
Tax residency and wealth structuring for new Spain residents
Spain’s tax framework for new residents underwent a material reconfiguration in 2025, and the window for pre-arrival planning has narrowed. The abolition of…
FATCA: US-person designation and the exit-tax trigger under section 877A
The decision to renounce United States citizenship or terminate long-term residency has shifted from a question of lifestyle to one of balance-sheet liabilit…
Tax residency and wealth structuring for new France residents
France’s tax system for new residents is among the most comprehensive in Europe, and the 2026 Finance Act (Loi de Finances pour 2026, promulgated 30 December…
Tax residency and wealth structuring for new Grenada residents
Grenada’s personal tax system is a rare case in the Caribbean: it taxes residents on worldwide income, yet offers no statutory non-dom regime, no territorial…
Tax residency and wealth structuring for new Greece residents
The question of how Greece taxes new residents is no longer a niche curiosity for second-home buyers; it is a live structuring question for any high-net-wort…
Greece non-dom (Article 5A): the EUR 100k annual lump-sum regime
The question of whether Greece’s Article 5A non-dom regime offers a superior alternative to the standard non-domiciled resident tax framework is no longer th…
Tax residency and wealth structuring for new Hong Kong residents
Hong Kong’s territorial tax system has long been the primary reason high-net-worth individuals relocate to the city, but the interplay between immigration st…
Hong Kong unilateral tax credits for outbound HNW residents
The question of how Hong Kong’s territorial tax system interacts with foreign tax obligations has moved from a theoretical planning point to a live complianc…
Tax residency and wealth structuring for new Ireland residents
Ireland’s tax framework for new residents operates on a deceptively simple statutory test — 183 days in a calendar year, or 280 days across two consecutive y…
Inheritance and succession across jurisdictions: a planning matrix
For a family with assets spread across three or more jurisdictions, succession is rarely governed by a single law. It is governed by a collision of regimes —…
Tax residency and wealth structuring for new Italy residents
Tax residency and wealth structuring for new Italy residents
Italy non-resident heir inheritance tax: the planning gap to manage
The Italian inheritance tax regime for non-resident heirs is not a single rate but a cascade of thresholds, relationship tiers, and asset-location rules that…
Tax residency and wealth structuring for new Japan residents
Tax residency and wealth structuring for new Japan residents
Tax residency and wealth structuring for new Saint Kitts and Nevis residents
Saint Kitts and Nevis imposes no tax on worldwide income, capital gains, or inheritances for any resident who does not source income within the federation —…
Malta non-domiciled residency: remittance-basis taxation in practice
When a high-net-worth individual relocates to Malta and elects the non-domiciled (non-dom) status, the tax outcome is not a discount but a different set of r…
Tax residency and wealth structuring for new Malta residents
The question of how Malta taxes new residents has acquired a specific urgency in 2026, driven by a confluence of regulatory tightening across Europe and a ma…
Multi-family office regulatory landscape in 2026: jurisdiction-by-jurisdiction
The question of which jurisdiction offers the most stable regulatory environment for a multi-family office is no longer abstract for principals who manage co…
Tax residency and wealth structuring for new Mexico residents
The question of how Mexico taxes its new residents has become a 2026-specific concern because the Servicio de Administración Tributaria (SAT) has intensified…
Tax residency and wealth structuring for new Malaysia residents
The question of how Malaysia taxes new residents has never been more consequential for high-net-worth individuals than in the current regulatory environment…
Tax residency and wealth structuring for new Netherlands residents
The question of how the Netherlands taxes new residents has become materially more consequential in 2026, not because of a single legislative bomb but becaus…
Tax residency and wealth structuring for new New Zealand residents
For a high-net-worth individual contemplating relocation, New Zealand presents a tax framework that is simultaneously generous to newcomers and exacting in i…
Centre-of-vital-interests under OECD Model Tax Convention Article 4
The OECD Model Tax Convention’s Article 4 tie-breaker rule was designed for an era when a single individual had a single home. That era is ending. For the hi…
OECD Pillar 2: implications for single-family offices and holding structures
The question is no longer whether a single-family office will be caught by the OECD’s Pillar 2 rules, but how quickly the existing structure must be restruct…
Tax residency and wealth structuring for new Panama residents
Panama’s tax regime for new residents is defined by a territorial system that, in practice, taxes only income sourced within the republic, but the boundary b…
Pension portability across migration: a five-jurisdiction primer
The question of what happens to accumulated pension wealth when a high-net-worth individual changes tax residence has moved from a technical footnote to a ce…
Portugal NHR 2.0 (IFICI): scope, eligibility and the 10-year horizon
In the final quarter of 2025, Portugal’s Non-Habitual Tax Resident regime entered its second iteration — commonly referred to as NHR 2.0 or, by its statutory…
Pre-immigration tax planning: a 12-month roadmap before residency
The question of when pre-immigration tax planning should begin is usually answered with a single number: 12 months. This is not a rule of thumb but a functio…
Tax residency and wealth structuring for new Portugal residents
For most of the past decade, Portugal’s tax regime for new residents was defined by a single, generous offer: the Non-Habitual Resident (NHR) programme, whic…
Tax residency and wealth structuring for new Saudi Arabia residents
The question of how Saudi Arabia taxes new residents has shifted from an academic curiosity to a practical planning imperative since the Premium Residency pr…
Tax residency and wealth structuring for new Singapore residents
The question of how Singapore taxes a newly arrived resident is not answered by a single statute but by the interaction of three distinct rules: the physical…
Singapore territorial taxation and the foreign-sourced income relief
Singapore territorial taxation and the foreign-sourced income relief
Single-family office: Singapore vs Dubai vs Hong Kong vs Geneva compared
The decision to domicile a single-family office is, for most principals, a decision about regulatory architecture rather than lifestyle preference. Four juri…
Source vs residence tax conflict in dual-citizenship scenarios
The tax treatment of dual citizenship is rarely symmetrical, and the divergence between source-based and residence-based taxation creates a structural confli…
Substance requirements for offshore holding companies in 2026
The question of whether an offshore holding company possesses sufficient economic substance is no longer a niche compliance concern — it is a direct determin…
Switzerland lump-sum taxation: cantonal variation and 2026 floor
The question is no longer whether Switzerland’s lump-sum taxation regime will survive, but how advisors should navigate the widening gap between cantonal off…
Tax residency vs citizenship: a structural primer for migrating individuals
The distinction between tax residency and citizenship has become the single most consequential structural decision for internationally mobile high-net-worth…
Tax residency and wealth structuring for new Thailand residents
Thailand’s tax treatment of new residents underwent a material shift on 1 January 2024, when Revenue Department Notification No. 161/2566 took effect, alteri…
Tax residency and wealth structuring for new Türkiye residents
The 2025 revision to Türkiye’s Law on Income Tax (Gelir Vergisi Kanunu), enacted through Omnibus Law No. 7524 on 2 August 2024 and effective from 1 January 2…
Trust structures across jurisdictions: a comparison for migration planning
For a high-net-worth principal relocating cross-border, the choice of trust jurisdiction is not a tax afterthought — it is the structural foundation upon whi…
UAE 0% personal income tax: the substance requirements that bite
The UAE’s zero percent personal income tax regime is not a loophole; it is a statutory feature of Federal Decree-Law No. 47 of 2022 on the Taxation of Corpor…
UK non-dom abolition: the new four-year FIG regime explained
The repeal of the UK’s 226-year-old non-dom regime on 6 April 2025 was never going to be a clean cut, but the final architecture of its replacement — the fou…
Tax residency and wealth structuring for new United Kingdom residents
The abolition of the non-domiciled tax regime on 6 April 2025 represents the most consequential change to United Kingdom personal taxation for internationall…
UK Temporary Repatriation Facility (TRF): the three-year 12% window
The three-year, 12% rate on the UK’s Temporary Repatriation Facility (TRF) is the most consequential concession in the April 2025 non-domicile rule changes,…
US section 877A exit tax: covered-expatriate thresholds and gain calculation
The question of when a US citizen or long-term resident ceases to be a US person for tax purposes is rarely a matter of simple renunciation. Section 877A of…
Tax residency and wealth structuring for new United States residents
The United States is one of only two OECD countries — Eritrea being the other — that taxes its residents on worldwide income regardless of domicile, and it o…