Category: Jurisdiction Profiles

Structure Before You Land: PPLI and the Pre-Aliyah Planning Window

The most valuable planning window in Israel is the one before your client becomes a resident. Once they land, the best move is already behind them. Most planning for Aliyah begins after arrival. The family lands, settles, opens Israeli accounts, and — some months later — sits down with an adviser to think about the portfolio. By then, the single most powerful structuring opportunity has already closed. For an internationally mobile family moving to Israel, the decisive action is taken before Israeli tax residency attaches, not after. What Israel Taxes Before You Arrive — Almost Nothing Before Aliyah, your client is a non-resident of Israel. Israel taxes non-residents only on Israeli-source income and Israeli capital gains — principally Israeli real

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Your Ten-Year Tax Holiday Will End. What Happens to Your Portfolio at Year Eleven?

Section 14 gives new immigrants a decade of zero tax on foreign income and gains — so most Olim do nothing with their portfolio. That is precisely the mistake. There is a comfortable logic that settles over many new immigrants to Israel in their first year. Under Section 14 of the Income Tax Ordinance, a new immigrant (Oleh Chadash) or veteran returning resident pays no Israeli tax on foreign-source income or foreign capital gains for ten full years. No dividends tax. No interest tax. No capital gains tax on the offshore portfolio. And Israel has no estate, inheritance, or gift tax at all. On the surface, there is nothing to plan for — the portfolio is already tax-free. The logic

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Coming to Ireland with a Portfolio — or Leaving Assets Behind? Structure Before the Domicile Question Bites

Ireland is the last major Western European remittance-basis regime standing. For a non-resident with Irish assets, or a family planning a move, the decisive planning happens before residency attaches. Two kinds of client need to think about Irish tax before they think they do. The first holds assets in Ireland — property, a stake in an Irish company — while living elsewhere. The second is planning to move to Ireland, often from the United Kingdom, where the non-dom regime was abolished in April 2025. For both, the most valuable planning is done before Irish residency and before a succession event, not after. What Ireland Taxes When You Are Not Resident A non-resident is exposed to Irish tax on a defined,

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Ireland Taxes the Wrapper: Why PPLI Here Is About Non-Dom Status and Succession, Not a Tax Holiday

In most jurisdictions a life wrapper is a deferral tool. In Ireland it is taxed on the way out — and at 60% if you pick the assets. The real Irish story is somewhere else entirely. If you have read our guides to Italy, Cyprus, or Israel, you will recognise a familiar shape: a window of low or zero tax on foreign income, and a Private Placement Life Insurance policy that carries the efficiency beyond the window. It is tempting to assume Ireland works the same way. It does not, and an adviser who imports that logic into an Irish plan will get it wrong. Ireland taxes the growth inside a life wrapper deliberately. A foreign life policy held by

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You Don’t Live in Belgium. Belgium Still Taxes What You Own There

For a non-resident, Belgium reaches Belgian real estate — on its income and on death — but leaves a financial portfolio largely alone. That asymmetry is the whole plan. A great many families have a Belgian footprint without being Belgian residents: an apartment in Brussels, a house in the Ardennes, a legacy holding from a period spent working in the country, or a plan to move there for a role that has not yet started. For all of them, the first question is not how Belgium taxes residents — it is what Belgium taxes when you are not one. The answer is narrower than most people fear, and it points straight at how the assets should be held. What Belgium

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The Year Belgium Started Taxing Your Portfolio

For decades a Belgian private investor paid no tax on capital gains. In 2026 that changed — and a well-worn insurance structure suddenly looks a great deal more useful. Belgium has always been a high-tax country with one conspicuous exception. Income was taxed hard — a flat 30% withholding on every dividend and every euro of interest — but the growth in the value of a share portfolio, for a private investor managing personal wealth in the normal way, was not taxed at all. That single exception shaped how a generation of Belgian families invested. In 2026, it ended. Three federal measures arrived together, and their combined effect is the most significant change to the taxation of private wealth in

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You’re Not Moving to Greece Yet – But Your Money Might Want To

For non-residents with Greek assets, the tax picture is manageable. For those considering relocation, the opportunity is exceptional — and structuring decisions made now determine the outcome. You own a property in Crete. Or you hold shares in a Greek company your family started twenty years ago. Or you are watching the Golden Visa programme and calculating whether Athens, Thessaloniki, or one of the islands might eventually suit a relocation. You are not a Greek tax resident. Not yet. But you have Greek assets. And those assets create Greek tax exposure that most non-resident owners manage imperfectly — and that PPLI can help address, both now and in the context of any future move. This article is for non-residents with

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Greece Has a €100,000 Tax Cap on Everything Your Portfolio Earns. Here’s What That Means for PPLI

How Article 5A’s non-dom flat tax, combined with PPLI, creates the EU’s most efficient structure for inbound residents — and why Greece now outperforms Italy, Spain, and France for large portfolios. Imagine telling a client: no matter how much your investment portfolio earns this year — whether it is €200,000 or €2 million — your Greek income tax on those gains is the same fixed number. €100,000. Paid once. Done. That is not a hypothetical. It is Article 5A of the Greek Income Tax Code, introduced by Law 4646/2019, and it is currently the most powerful single provision in European tax law for high-net-worth individuals with offshore investment portfolios. When you combine it with Private Placement Life Insurance, the result

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PPLI for Non-Residents with Italian Assets: What It Can and Cannot Do

Advisers sometimes present offshore Private Placement Life Insurance to non-resident clients holding Italian assets as if the wrapper eliminates the Italian tax problem. It does not. Italian-source income and gains are taxable in Italy regardless of whether those assets sit inside a PPLI or outside it. The wrapper addresses the tax position in the client’s country of residence. It does not override Italian source-country taxation. That qualification matters a great deal, and it needs to be stated at the outset. What PPLI can do for non-residents with Italian assets is still significant — but advisers who start with an accurate picture of the limits will build better structures and avoid disappointed clients. The fundamental distinction Italy taxes non-residents only on

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