How wealth is lawfully organised

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%.

CY

Singapore holding company

A Singapore-resident company pays 17% corporate tax, but under the one-tier system its dividends are tax-free for shareholders, there is no withholding tax on dividends, and there is no general capital gains tax. Foreign dividends, branch profits and service income can be exempt when remitted if they were taxed abroad at a headline rate of at least 15%. Substance is now essential, especially since the 2024 rule taxing foreign disposal gains of entities without economic substance.

SG

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.

GB

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.

EE

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.

HK

Malta trading company with the 6/7 shareholder refund

A Malta company pays corporate tax at 35%, but when it distributes trading profits the shareholder can claim back 6/7 of the tax paid, leaving an effective rate of about 5%. Since 2025 a company can instead elect a final 15% tax with no refund. The refund system is legal and long-established, but it only works with real Maltese management and it is cash-flow heavy.

MT

UAE free zone company (Qualifying Free Zone Person)

A company licensed in a UAE free zone can pay 0% corporate tax on its qualifying income if it meets every condition to be a Qualifying Free Zone Person (QFZP). Everything else it earns is taxed at 9%, and if non-qualifying revenue breaches the de minimis limit the company loses the 0% rate for that year and the following four. It works for founders who genuinely live and run the business in the UAE, and it fails for anyone still running it from the UK.

AE

UAE mainland company

A company licensed by an emirate's economic department (the mainland) can trade anywhere in the UAE and pays corporate tax at 0% on the first AED 375,000 of taxable income and 9% above that. Small businesses with revenue of AED 3m or less can elect small business relief and pay no corporate tax, now extended to tax periods ending on or before 31 December 2029. It is simple and credible for a founder who lives in the UAE, and useless for one who does not.

AE

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.

GE

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.

IT

UK 4-year foreign income and gains (FIG) regime

From 6 April 2025 the UK replaced the non-dom remittance basis with a residence-based regime. A person who becomes UK resident after at least 10 consecutive tax years of non-UK residence can claim 100% relief from UK tax on foreign income and gains for their first 4 tax years of UK residence, and can bring the money into the UK freely. After 4 years they are taxed on worldwide income and gains like everyone else. For people who leave the UK, the same 10-year rule decides whether they can ever use it again.

GB

Offshore (non-UK resident) trust

A trust whose trustees are all outside the UK used to be the core tool of non-domiciled UK residents: foreign income and gains could build up tax-free and non-UK assets stayed outside inheritance tax. Since 6 April 2025 the non-dom regime is gone, the 'protected settlement' shelter is gone, and inheritance tax on trusts depends on the settlor's long-term UK residence. For a UK-resident settlor who can benefit, an offshore trust is now broadly tax-transparent: its income and gains are taxed on the settlor as they arise. It still has uses for asset protection, succession, and for people who are genuinely non-UK resident, but it is no longer a UK tax shelter.

JE · GG · IM · KY · BM · BS · SG · NZ

Private foundation (Liechtenstein, Panama, Malta, DIFC, ADGM)

A private foundation is a civil-law entity with its own legal personality that holds assets for beneficiaries or a purpose, run by a council under a charter and by-laws. It is the civil-law cousin of a trust and is popular for succession and asset protection. For UK tax the question is whether HMRC treats it as a company, a trust, or neither on the facts, and for a UK-resident founder who can benefit the Transfer of Assets Abroad and settlements rules usually remove any tax advantage.

LI · PA · MT · AE

UK family investment company (FIC)

A family investment company is an ordinary UK private company, funded by a founder and owned partly by the next generation, that invests for the long term. Its main advantages are that most dividends it receives are exempt from corporation tax, profits are taxed at corporation tax rates rather than personal rates while retained, and growth can be passed to children without an immediate inheritance tax charge. It remains UK resident wherever the founder goes, which is both its strength and its limit for people leaving the UK.

GB