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 2 of 4
Tax Strategy
Salary vs Dividends for the Offshore Company Director
How offshore company directors should weigh salary against dividends: residence, substance, withholding, social security, and getting the mix right.
Tax Strategy
Offshore Dividend Planning With a Holding Company
How a holding company supports offshore dividend planning: participation exemptions, withholding tax, treaty access, substance, and the pitfalls to avoid.
Tax Strategy
Pension Planning for the Internationally Mobile
Pension planning for internationally mobile individuals: cross-border tax, treaty relief, transfers, currency risk, and the traps that catch mobile savers.
Tax Strategy
Can You Legally Pay No Tax? What Is Real, What Is Not
Whether paying no tax legally is possible: the genuine routes, why residence and substance matter, and the schemes that promise zero tax but deliver liability and risk.
Tax Strategy
Capital Gains Tax-Free Countries: A 2026 Guide
Capital gains tax-free countries in 2026: where gains genuinely escape tax, how residence and exit taxes work, and the conditions that make or break a move.
Tax Strategy
Countries With No Income Tax: A 2026 Guide
A clear, current look at countries with no income tax, how residency actually works there, and the planning pitfalls that catch unprepared movers.
Tax Strategy
Territorial Tax Countries: A Practical 2026 Guide
A practical guide to territorial tax countries, how foreign-income exemptions really work, the remittance traps, and who benefits most in 2026.
Tax Strategy
How to Reduce Taxes as an Entrepreneur: 2026 Guide
How to reduce taxes as an entrepreneur, legally: entity choice, residency, holding structures, remuneration and the pitfalls that undo good planning.
Tax Strategy
Exit Tax Guide by Country: What to Know in 2026
An exit tax guide by country: how departure taxes work, which jurisdictions impose them, common triggers, and how to plan a clean, compliant exit.
Tax Strategy
Non-Dom Tax Regimes Worldwide: A 2026 Comparison
A 2026 guide to non-dom tax regimes worldwide, comparing how Italy, Greece, Malta, Cyprus, Ireland and others tax foreign income for new residents.
Tax Strategy
Flat-Tax Countries for Expats: A 2026 Guide
A 2026 guide to flat-tax countries for expats, comparing fixed-charge and flat-rate regimes in Italy, Greece, Switzerland and beyond, with the pitfalls.
Tax Strategy
How to Leave the German Tax System: A 2026 Guide
How to leave the German tax system in 2026: ending unlimited tax liability, the Wegzugsteuer exit tax, extended limited liability, and the common traps.
Tax Strategy
How to Leave the Australian Tax System: A 2026 Guide
How to leave the Australian tax system in 2026: ceasing tax residency, the CGT deemed-disposal exit tax, the residency tests, and the common pitfalls.
Tax Strategy
How to Leave the Canadian Tax System: A Practical Guide
How to leave the Canadian tax system cleanly: severing residency, the departure tax on deemed disposition, RRSP and TFSA treatment, and common pitfalls.
Tax Strategy
How to Leave the French Tax System: A Practical Guide
How to leave the French tax system: severing residency under the four tests, the exit tax on substantial shareholdings, social charges, and key pitfalls.
Tax Strategy
How to Leave the South African Tax System: A Practical Guide
How to leave the South African tax system: ceasing residence, the deemed-disposition exit charge, retirement funds, and exchange control.
Tax Strategy
How to Leave the Swedish Tax System: A Practical Guide
How to leave the Swedish tax system: severing residence, the five-year essential-connection rule, the ten-year capital gains rule, and key pitfalls.
Tax Strategy
The Worst Countries for Tax Residency in 2026
The worst countries for tax residency share the same traps: worldwide taxation, exit taxes, and sticky rules. Here is what to watch before you move.
Tax Strategy
International Tax Structures for Freelancers and Solo Founders
A clear guide to international tax structures for freelancers: residency, company use, permanent establishment risk, and where simple beats clever.
Tax Strategy
British Virgin Islands Tax Residency: A Practical Guide
A practical guide to British Virgin Islands tax residency: what residence means in a no-tax jurisdiction, substance, and the common pitfalls to avoid.
Tax Strategy
Cayman Islands Tax Residency: A Practical Guide
A practical guide to Cayman Islands tax residency: residence certificates, the no-tax position, substance, and the pitfalls international movers must avoid.
Tax Strategy
Nevis Tax Residency: A Practical Guide
How Nevis tax residency actually works: who qualifies, the local tax position, substance, and the pitfalls that derail an otherwise clean exit.
Tax Strategy
Bahamas Tax Residency: A Practical Guide
How Bahamas tax residency works in practice: qualifying, the no-income-tax position, substance, banking, and the exit pitfalls that catch people out.
Tax Strategy
Bermuda Tax Residency: A Practical Guide
How Bermuda tax residency works: the no-income-tax position, residential certificates, substance, the high cost of living, and exit pitfalls to plan around.
Tax Strategy
Anguilla Tax Residency: A Practical Guide
How Anguilla tax residency works: the zero-income-tax position, the tax residency programme, substance requirements, banking, and the exit pitfalls to avoid.
Tax Strategy
St. Vincent & the Grenadines Tax Residency Guide
How to establish genuine St. Vincent and the Grenadines tax residency: the rules, the resident tax position, substance, and the pitfalls to avoid.
Tax Strategy
United Kingdom Tax Residency: A Practical Guide
A practical guide to UK tax residency: the Statutory Residence Test, split-year treatment, the post-non-dom regime, and the pitfalls that catch people out.
Tax Strategy
Ireland Tax Residency: A Practical Guide
A practical guide to Irish tax residency: the day-count rules, ordinary residence and domicile, the remittance basis for non-doms, and key pitfalls.
Tax Strategy
Luxembourg Tax Residency: A Practical Guide
A practical guide to Luxembourg tax residency: how residence is determined, the tax position for residents, substance, treaties, and common pitfalls.
Tax Strategy
Switzerland Tax Residency: A Practical Guide
How to establish genuine Switzerland tax residency: the day-count and centre-of-life tests, lump-sum taxation, cantonal differences, and the pitfalls.
Tax Strategy
Malta Tax Residency: A Practical Guide
A practical guide to Malta tax residency: ordinary residence, the non-dom remittance basis, the residence programmes, substance, and the pitfalls.
Tax Strategy
Cyprus Tax Residency: A Practical Guide
A practical guide to Cyprus tax residency: the 183-day and 60-day rules, the non-dom regime, what residents pay, substance, and common pitfalls.
Tax Strategy
Netherlands Tax Residency: A Practical Guide
A practical guide to Netherlands tax residency: how residence is decided, the box system, the 30 percent ruling, substance, and the key pitfalls.
Tax Strategy
Germany Tax Residency: A Practical Guide for HNWIs
How Germany tax residency is established, what worldwide taxation means in practice, and the substance and exit-tax pitfalls to plan around.
Tax Strategy
France Tax Residency: A Practical Guide for HNWIs
How France tax residency is determined by four alternative tests, what worldwide taxation involves, and the wealth and exit-tax pitfalls to anticipate.
Tax Strategy
Spain Tax Residency: A Practical Guide for HNWIs
How Spain tax residency is triggered, what worldwide taxation and regional wealth tax involve, and how the Beckham regime and exit tax fit in.
Tax Strategy
Portugal Tax Residency: A Practical Guide for HNWIs
How Portugal tax residency is established after NHR, what worldwide taxation involves, and the substance and planning pitfalls to anticipate.
Tax Strategy
Italy Tax Residency: A Practical Guide for 2026
How Italy tax residency is determined, what residents are taxed on, the flat-tax option for new arrivals, and the pitfalls that catch mobile families.
Tax Strategy
Belgium Tax Residency: A Practical Guide for 2026
How Belgium tax residency is determined, what residents are taxed on, the rules on foreign income, and the pitfalls that catch mobile individuals.
Tax Strategy
Austria Tax Residency: A Practical Guide for 2026
How Austria tax residency is determined, what residents are taxed on, the special regimes available, and the pitfalls that catch mobile families.
Tax Strategy
Denmark Tax Residency: A Practical Guide for 2026
How Denmark tax residency is determined, what residents are taxed on, the inbound expert regime, and the pitfalls that catch mobile individuals.
Tax Strategy
Sweden Tax Residency: A Practical Guide
How Sweden tax residency works in practice: the residence and connection tests, the five-year rule on leaving, exit charges and common pitfalls.
Tax Strategy
Norway Tax Residency: A Practical Guide
Norway tax residency explained: the day-count tests, the slow three-year exit rule, exit taxation on unrealised gains, and the pitfalls of leaving.
Tax Strategy
Finland Tax Residency: A Practical Guide
Finland tax residency explained: the six-month rule, the three-year tail for departing nationals, worldwide taxation, and the pitfalls of leaving cleanly.
Tax Strategy
Poland Tax Residency: A Practical Guide
Poland tax residency explained: the 183-day and centre-of-interests tests, the lump-sum regime for new arrivals, exit tax on gains, and key pitfalls.
Tax Strategy
Estonia Tax Residency: A Practical Guide
How to establish Estonia tax residency: the residency tests, the resident tax position, substance, and the pitfalls that catch the unprepared.
Tax Strategy
Liechtenstein Tax Residency: A Practical Guide
How to establish Liechtenstein tax residency: the strict permit system, the resident tax position, substance, and the pitfalls to watch.
Tax Strategy
Gibraltar Tax Residency: A Practical Guide
How to establish Gibraltar tax residency: the ordinary route, Category 2 status, the resident tax position, substance, and common pitfalls.
Also in Insights
Reference
Guides and comparisons
Longer guides on jurisdictions, structures and routes to residence.
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Example scenarios
Illustrative scenarios showing how a matter is approached.
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Glossary
Plain-English definitions of cross-border terms, from ATED to VASP.
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How the firm works, what it charges and where it operates.
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Much of the firm's thinking sits in client memoranda rather than published articles. The note covers the parts that apply more widely: changes in jurisdictions, banking practice and regulatory deadlines.
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