Some people feel attached to their home country. They tend to invest more in domestic equities, even if foreign ones offer a better return. However good the quality of life abroad may be, they will always trust home-country doctors and teachers more .
Others look deeper into the real reason for migration: lack of opportunities. Changing residence is thus seen as a chance to overcome:
lack of opportunities for business
complicated bureaucratic procedures
monstrous tax rates
lack of political stability and security
low level of asset protection
low quality of healthcare and education
Let us see, step by step, how to choose the most attractive destination in terms of lifestyle – and avoid paying unnecessary taxes.
Countries with zero income tax
Countries with 0% tax are a double-edge d sword. The flip side is usually the cost of living.
Monaco does not tax its residents ’ income . Yet , it has the highest real estate costs worldwide that create real estate transfer tax. Furthermore, VAT comes from high living costs and touris m .
UAE residents pay no income tax , but the visa and license are subject to an annual fee . Also, property and services like notarisation are rather expensive.
Island states worldwide attract businessm e n through 0% corporate tax schemes, earn ing on corporate services and/or citizenship by investment schemes . However, they are difficult to reach and sometimes have a less developed legal environment.
Countries with beneficial taxation for resident s without domicile
T hese economically vibrant states tax only local -sourced income and/or remitted foreign income.
In Europe : Malta, Cyprus, Ireland, and the UK
In Asia : Singapore and Hong Kong
Countries with special temporary regimes
Portugal (NHR scheme, Golden Visa)
Spain ( Royal Decree 687/2005 , also known as th e “Beckham Law”)
Greece and Italy ( flat tax rate of 100.000 Euro on all foreign – source d income )
Countries with beneficial taxation and distribution of corporate income
Romania (1% tax rate for companies with revenue < 1 million euro per year employing at least 1 Romanian citizen)
Latvia ( the tax system taxes local corporate profits when they are distributed on a corporate level ; t here is tax exemption on dividends distributed from a white-listed foreign company)
Georgia (foreign- source income exempt ion from p ersonal income tax ; 0% corporate and dividend tax in case of a Virtual Zone Person )
💡 Y ou can first move to a zero-tax country , collect assets , and then move to another destination . In this case, you will have a capital to live from, while new profits will stay accumulated in a corporate structure.
Avoid costs when you leave the original country of residence
Depending on the jurisdiction, an exit tax can take the following forms:
taxation on a deemed dividend (delayed within EU)
valuation of intellectual property on the future value
Moreover, some local assets can remain subject to tax (for instance, real estate or income of local partnerships ). C itizens of countries such as the US need to pay the worldwide tax regardless of their residence.
Important note: article 4 of double taxation agreements defines residency criteria, which may overrule national regulations :
R eal estate back home may be seen as a permanent home. It is recommended to sell or rent it out to third parties.
M arried individuals with underage children have the ir residency where the ir core family is. Therefore, it is advised to move together with the family.
S pend ing much time in the original country may trigger the 183-day rule . A suggestion : stay in a bordering country where possible .
P rotect assets until it is too late
Think ahead. Private and corporate funds are exposed to claims from family members, governments, and potential creditors. Also, i nheritance laws often allow family member s to receive a mandatory share . It is better to have assets protected beforehand .
Separate ownership . Starting a trust or a foundation requires separat ing the assets from the original beneficial owner. Losing control may scare wealthy individuals away , but there are some ways to please everyone. For instance, a foundation is founded by a legal person, which is then taken over by this foundation, and this legal entity appoints the advisory board . The advisory board thus can appoint and discharge the board members, approve investments, and propose contributions. As long as the original persons do not receive any contribution, it will be difficult to claim beneficial ownership.
🤔 An ex-wife of a Russian billionaire has not managed to get billions of dollars in divorce settlement, because his assets were acquired by limited liability companies owned by trusts.
Open many bank accounts. B anks can be shut down by governments , defrauded, change terms of service , terminate a relationship, or block accounts. Therefore, it is indispensable to have bank accounts in different banks and countries.
Withdraw funds from corporate to private level smartly
Be prepared . In case someone plans to move to a high-tax country , it may be a good idea to jump in to a low – tax country , to withdraw assets from corporate to private level or to convert them into capital . Th i s capital can then be reinvested in a corporate structure as loans or hybrid instruments. In this way , the payback of capital will be tax – exempt in most new countr ies of residence (unlike income).
If there are no t sufficient liquid funds , you can sell some intellectual property that allows future revenues and receive in turn debit notes for a discount . You can then receive the payments for the debit notes in a new country of residence .
Us e a holding or an intermediary unit :
If there is a withholding tax on dividends, interests , or royalties , a holding in a nother country can ensure their t ax-free transfer to a company that can then distribute them tax-free to a shareholder .
Selling an entity requires a holding in a country where capital gains and outgoing dividends are tax-free .
D irectors’ fees or service income received outside the country require a careful check:
whether there are social charges and a withholding tax in the source country
whether there is an income tax in the country of residence
Us e a partnership :
If a partnership is established in a country with a residence – without – domicile scheme , it can opt to be taxed transparent ly (at the level of the partners in the country of the company). The partners can live in a tax-free country or in a country where they are residents without domicile. The partnership can create profits outside the country and have some activities in the country. Art. 7 of the double tax agreements allocates the right to tax to the country of the partnership , which applies the territorial principle. So, income that is earned outside the country of the partnership sometimes remains tax-free both on corporate and on private level s .
In some high – tax countries, shareholders can use participating loans to receive a profit share instead of a fixed interest. The company can deduct these variable interests , and the recipient may receive it tax – free outside his country of residence.
If a company is established in a low – tax country and the founder join s its profit centre as a silent partner, he will receiv e a profit share outside the country of residence. In many places, c ompanies can deduct such expenses, so that they are not shown as a profit in the final financial statement.
Us e other entities:
A foundation or a trust can help separate ownership from the person – for example , to avoid exit tax . Later, it can declare contribution s that are received by the person tax-free in or outside the new country of residence , depending on the constellation .
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