Where wealth pays less tax. Lawfully.

holding company

Cyprus holding company with a non-dom shareholder

A Cyprus-resident company can receive dividends and sell shares largely free of Cyprus tax, and pay dividends out with no Cyprus withholding tax to most shareholders. Paired with an individual who is Cyprus tax resident but non-domiciled, those dividends also escape Cyprus Special Defence Contribution for up to 17 years, extendable since 2026 for a lump sum. Since 1 January 2026 the corporate rate on trading profits is 15%.

residency planning

Dual residency and the treaty tie-breaker

A person can be tax resident in the UK under the Statutory Residence Test and in another country under its law at the same time. Where a double tax treaty applies, its tie-breaker article decides which country is the residence state for treaty purposes, and the other country's taxing rights are then limited by the treaty. It can protect someone who cannot avoid UK residence, but it is fact-heavy, only as good as the specific treaty, and leaves UK domestic residence in place for many purposes.

operating company

Estonian company (tax only on distributed profit)

An Estonian company pays no corporate income tax on profit it keeps or reinvests; tax is charged only when profit is distributed (as dividends, hidden distributions or non-business expenses), at 22/78 of the net amount, equal to 22% of the gross. It is often opened by non-residents through e-Residency, which is exactly why UK residents get it wrong: an Estonian company run from the UK is UK resident and taxed in the UK.

personal regime

Georgia individual entrepreneur with small business status

A Georgian tax-resident individual registered as an individual entrepreneur can apply for small business status and pay 1% tax on turnover up to GEL 500,000 a year. It is not a company, it is a personal status that covers only the individual's own business activity, and it requires genuine Georgian tax residence to be of any use to someone leaving the UK.

operating company

Hong Kong company with an offshore profits claim

Hong Kong taxes only profits arising in or derived from Hong Kong, so a Hong Kong company whose profit-generating operations happen entirely outside Hong Kong can claim its profits are offshore and not taxable. The claim is examined closely by the Inland Revenue Department, and since 2023 the foreign-sourced income exemption (FSIE) regime taxes certain passive foreign income received in Hong Kong by group companies unless substance or participation conditions are met. It suits genuine offshore trading, but it is a common trap for UK residents.

personal regime

Italy flat tax for new residents (Article 24-bis TUIR)

A new Italian tax resident can elect to pay a fixed annual substitute tax on all foreign-source income instead of ordinary Italian tax. For people transferring residence from 1 January 2026 the charge is EUR 300,000 a year, plus EUR 50,000 for each family member included, for up to 15 years. Italian-source income is taxed normally. It is a personal regime, not a structure, and makes sense only for people with very large foreign income or gains.