Insights
Notes from the practice
Commentary on cross-border structuring, banking, residence, tax and regulatory change. Articles more than 24 months old carry a note saying so.
Tax Strategy
149 articles, page 1 of 4
Tax Strategy
Cyprus non-dom extension: is the €250k fee worth it?
Cyprus's paid non-dom extension costs €250,000 per five years. Set against the new 5% dividend rate, it pays only for founders drawing over €1m a year.
Tax Strategy
FIG regime: the year-five cliff most arrival plans miss
FIG relief ends after four tax years with no taper, and worldwide IHT starts in year eleven. Both dates are fixed on arrival. Most plans model neither.
Tax Strategy
UK Non-Dom Reform 2025: What Really Changed
The UK non-dom reform 2025 abolished domicile-based taxation and moved to a residence test. Here is what actually changed and how to plan around it.
Tax Strategy
Split-Year Treatment: Leaving the UK Cleanly Mid-Year
How split-year treatment works when leaving the UK mid-year, the cases that apply, and the pitfalls that cost departing residents their relief.
Tax Strategy
UK Statutory Residence Test: Complete 2026 Guide
A practical 2026 guide to the UK statutory residence test: automatic overseas and UK tests, the sufficient ties test, day counting, and common traps.
Tax Strategy
Remittance Basis for Non-Domiciled UK Residents
A practical guide to the remittance basis for non-domiciled UK residents: how it works, what counts as a remittance, costs, and the reforms reshaping it.
Tax Strategy
UK Inheritance Tax and Offshore Assets in 2025
How UK inheritance tax now reaches offshore assets in 2025, the move to residence-based scope, excluded property, and planning for international families.
Tax Strategy
Business Asset Disposal Relief: A Founder's BADR Guide
A clear guide to Business Asset Disposal Relief (BADR): who qualifies, the lifetime limit, the rising rate, and how founders should plan an exit.
Tax Strategy
Germany Exit Tax (Wegzugsteuer): A Planning Guide
How Germany's exit tax (Wegzugsteuer) taxes unrealised gains on company shares when you leave, who it catches, and how to plan a departure properly.
Tax Strategy
UK Exit Tax? Capital Gains on Leaving the UK
Does the UK have an exit tax on capital gains when you leave? We explain the temporary non-residence rule, what is taxed on departure, and timing of disposals.
Tax Strategy
France Tax Residency: The Four Tests Explained
France decides tax residency using four alternative tests under Article 4B. Understand how home, main stay, economic activity and centre of interests apply.
Tax Strategy
Andorra Tax Residency: A Practical Relocation Guide
How to obtain Andorra tax residency: the active and passive routes, presence and investment requirements, the low-tax regime, and the pitfalls to avoid.
Tax Strategy
Scotland LBTT and Offshore Property Buyers: A Guide
How Scotland's Land and Buildings Transaction Tax applies to offshore and non-resident buyers, including the ADS surcharge, ownership structures and pitfalls.
Tax Strategy
Portugal's NHR Replacement in 2026: What Changed
Portugal's NHR regime closed to new entrants. Here is what replaced it, who the IFICI incentive suits in 2026, and how it compares for professionals.
Tax Strategy
UK Crypto Tax 2026: A Guide for Wealthy Individuals
How UK crypto tax works for individuals in 2026: capital gains versus income, disposals, DeFi and staking, record-keeping and HMRC's focus.
Tax Strategy
Italy's Flat Tax Regime for New Residents: A Guide
How Italy's flat tax regime for new residents works in 2026: the annual substitute charge on foreign income, who qualifies, and the key pitfalls.
Tax Strategy
Italy's Flat-Tax Regime for New Residents Explained
How Italy's flat-tax regime for new residents works in 2026: the annual substitute tax on foreign income, eligibility, family extension and duration.
Tax Strategy
Greece Flat Tax Regime: A Guide for Foreign Investors
How the Greece flat tax regime works for non-domiciled investors, pensioners and professionals relocating to Greece, with eligibility, costs and pitfalls.
Tax Strategy
Switzerland Lump-Sum Taxation: A Complete Guide
How Switzerland lump-sum taxation (forfait) works for wealthy foreigners: eligibility, how the base is calculated, cantonal differences and key pitfalls.
Tax Strategy
Double Taxation Agreements Explained for Global Investors
Double taxation agreements decide which country taxes your income and at what rate. We explain how DTAs allocate taxing rights, relieve double tax and where.
Tax Strategy
Tax Residency Certificate: A Practical Guide
A tax residency certificate proves where you are taxed and unlocks treaty relief. We explain what it is, how to obtain one, and the pitfalls that get claims.
Tax Strategy
GILTI High-Tax Exclusion: Planning for US Owners
The GILTI high-tax exclusion can switch off current US tax on foreign company profits. We explain how the election works, when it helps, and the traps.
Tax Strategy
Spain's Beckham Law: 2025 Guide for Expats
A clear 2025 guide to Spain's Beckham Law expatriate regime: who qualifies, the flat rate on Spanish employment income, exclusions and application windows.
Tax Strategy
Subpart F Income: A US CFC Guide for Owners
Subpart F income can tax US owners on a foreign company's profits before any distribution. We explain the CFC rules, the income categories, and how to plan.
Tax Strategy
US Expatriation Tax: The Covered Expatriate Rules
The US exit tax can apply when you renounce citizenship or give up a green card. We explain the covered expatriate tests and the mark-to-market charge.
Tax Strategy
NFT Taxation and Offshore Structuring Explained
NFT taxation is messier than most assume. We explain how creators, traders and collectors are taxed and where offshore structuring genuinely helps.
Tax Strategy
Staking and DeFi Taxation: A Practical Guide
Staking and DeFi taxation creates income and disposals where investors least expect them. Here is how rewards, lending and liquidity pools are taxed.
Tax Strategy
Monaco Tax Residency: A Complete 2026 Guide
Establishing genuine Monaco tax residency in 2026: no personal income tax for residents, the residency-card process, housing and banking requirements.
Tax Strategy
The 183-Day Tax Myth: Why Day Counting Alone Won't Protect You
The 183-day rule is widely misunderstood. Relying on day counting alone as your defence against tax-residency claims can result in unexpected six-figure tax bills: the rule is not a universal law but one threshold among many factors.
Tax Strategy
Wealth Tax in Europe: How Mobile Families Plan
How wealth tax in Europe works, which countries levy it, and how internationally mobile families plan around it legitimately.
Tax Strategy
Does Moving to Dubai Really Mean 0% Tax?
The reality behind Dubai's 0% tax reputation: UAE corporate tax, free-zone nuance, personal tax, and home-country tail risks.
Tax Strategy
Netherlands Box 3 Reform 2028: What Investors Face
The Netherlands Box 3 reform for 2028 moves savings and investment taxation toward actual returns. What international investors should plan for.
Tax Strategy
Netherlands Box 3 Unrealised Gains Tax: Act Before 2028
A Netherlands Box 3 unrealised gains tax would tax paper gains before any sale. What international investors should review before 2028.
Tax Strategy
Crypto Tax-Free Countries in 2026: The Reality
The crypto tax-free countries discussed in 2026, the real conditions and caveats, and why residence and substance decide the outcome.
Tax Strategy
Ireland Non-Dom Remittance Basis: A Practical Guide
How Ireland's non-domiciled remittance basis works for resident non-doms: the tax position on foreign income and gains, remittance traps, and who it suits.
Tax Strategy
Smart Tax Strategies for HNW Individuals: Planning Beyond Compliance
Filing tax returns is compliance. Planning is the year-round structuring of income, assets and succession within the reliefs and timing rules the law provides, with each position documented. For wealthy individuals, the difference can be material.
Tax Strategy
CFC Rules: The Hidden Force Shaping Offshore Structures
Controlled Foreign Corporation rules allow high-tax countries to tax residents on the undistributed income of foreign companies they control. Understanding how the UK, US, Germany and Netherlands apply these anti-deferral provisions is essential for anyone structuring international entities.
Tax Strategy
Excluded Property Trusts and UK Inheritance Tax in 2025
How excluded property trusts shield non-UK assets from UK inheritance tax in 2025, and why the move to a residence-based regime changes the calculus.
Tax Strategy
A Practical Guide to Leaving the UK Tax System Legally
Leaving the UK is not enough. The Statutory Residence Test, split year treatment, P85 submissions and the five-year temporary non-residence rule create a framework that binds you to HMRC long after you have physically departed.
Tax Strategy
Digital Nomad Tax Obligations: A Founder's Guide
A clear guide to digital nomad tax obligations: residency triggers, home-country ties, permanent establishment risk and how to stay compliant while mobile.
Tax Strategy
Greece Non-Dom Tax Regime: Flat Tax for New Residents
The Greece non-dom tax regime offers a flat annual charge on foreign income for new residents. We explain how it works, who qualifies, and the trade-offs.
Tax Strategy
Establishing Tax Residency in Dubai: A Practical Guide
How to establish genuine tax residency in Dubai: the residence visa, the 183-day rules, substance, banking, and the exit-side traps that catch the unprepared.
Tax Strategy
The Truth About UAE Taxes for Structured Entrepreneurs
The truth about UAE taxes: with corporate tax now live, properly structured entrepreneurs still enjoy a remarkably efficient and defensible position.
Tax Strategy
UAE Corporate Tax: 2025 Guidance and Compliance Update
A 2025 update on UAE corporate tax: rates, the free zone regime, registration and filing duties, transfer pricing, and practical compliance steps.
Tax Strategy
UK Corporation Tax Planning 2025: A Practical Guide
UK corporation tax planning in 2025: the rates and reliefs that matter, where genuine efficiency lives, and the structuring traps to avoid.
Tax Strategy
Annual Tax on Enveloped Dwellings (ATED) Explained
A clear guide to the Annual Tax on Enveloped Dwellings (ATED): who pays, the reliefs that matter, valuation dates, and the planning traps to avoid.
Tax Strategy
Capital Gains on Offshore Assets: A UK Tax Guide
How UK residents are taxed on capital gains from offshore assets: the worldwide charge, the remittance basis, temporary non-residence, and reporting traps.
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