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The first question is not tax but stability. Before comparing the tax rates of different jurisdictions, assess political and legal stability: a low rate means nothing if the rules change unpredictably within a few years.
Currency control on both sides. You need to consider not only the requirements of the new jurisdiction but also the currency control legislation of your place of tax residence: a mismatch between them creates a real risk.
Do not leave structuring until later. It is simpler and cheaper to build the ownership structure before the move than to untangle assets already transferred after the fact, when some decisions have already been made in haste.
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Who needs asset structuring when relocating
The situations clients most often bring to us before a move or in the first months after it.
How to hold assets: personal ownership, holding company, trust
Personal ownership is not always suitable. Direct ownership of assets by an individual is simpler to set up, but it does not protect against risks arising from inheritance under the law of the new country, division on divorce or personal liability, especially if the assets include an operating business.
A holding company changes the tax picture. Transferring assets to an intermediate holding structure removes some inheritance and corporate control issues, but adds controlled foreign company reporting and requires deciding in advance in which country the place of management of that structure will be recognised.
A trust or private foundation is not a universal solution. Such structures limit personal liability and simplify the transfer of assets between generations, but they are not recognised equally in all jurisdictions, and automatic exchange of tax information will still disclose the beneficiary to the country of their tax residence.
How structuring works when you relocate
The timeframes below are indicative and depend on the number of jurisdictions and the complexity of the asset structure.
Audit of assets and residence
We compile a complete map of the client’s assets, accounts and corporate structures and record the current tax status and the planned date of its change. Timeframe: 1-2 weeks.
Choice of jurisdiction and form of ownership
We compare jurisdictions by tax treaties, beneficial owner disclosure requirements and currency restrictions, and select the form of ownership for the particular set of assets. Timeframe: 2-4 weeks.
Re-registration and transfer of assets
We carry out the redomiciliation of companies and the transfer of corporate rights, accounts and real estate to the agreed ownership structure. Timeframe: from 1 to 3 months.
Compliance after the move
We set up a calendar for controlled foreign company reporting, automatic exchange and local disclosure requirements, so that the structure does not become outdated within a year. Timeframe: ongoing, on a calendar basis.
Our practice in numbers
Experience specifically in structuring assets on relocation, not in international practice in general.
Costly mistakes when relocating
Residence changes, CFC reporting does not. A change of an individual’s tax residence does not in itself remove the duty to report on controlled foreign companies to the former jurisdiction if the formal status of controlling person remains, and the discrepancy usually comes to light at the first automatic data exchange.
Automatic exchange discloses the structure before it can be rebuilt. CRS transmits data on accounts and beneficiaries every year, and if the ownership structure has not been put in order before the move, the new country’s tax authority receives information about the old assets faster than the client can legalise them or declare them under the new rules.
The place of management of a business does not move with the director. A formal change of the owner’s tax residence does not automatically transfer the place of effective management of the operating company. If key decisions and board meetings still take place in Russia, the structure risks inadvertently acquiring tax residence somewhere other than planned.
What you get at the end of the work
A map of assets and ownership structure. A complete diagram of what belongs to the client now and through which structure, and how it will be arranged after the move, stating the jurisdiction of each element.
An opinion on the tax consequences of the move. A written analysis of how the change of residence will affect taxation of personal income, dividends and the profits of controlled companies.
A compliance calendar. A schedule of mandatory reporting after the move, covering CFC rules, automatic exchange and local beneficial owner disclosure requirements, with dates and the jurisdictions responsible.
A document package for the new structure. The constitutional and corporate documents needed to register or redomicile the ownership structure in the chosen jurisdiction.
Frequently asked questions
Do I need to change tax residence when moving capital to another jurisdiction?+
Not necessarily. The asset structure and an individual’s tax residence can be considered separately, and we review this case by case.
How long does asset structuring on relocation take?+
From a few weeks for a simple structure to several months if several jurisdictions are involved at once.
Planning to move capital abroad?+
Leave a request and a partner from our international practice will contact you within one working day.