Category: Jurisdiction Profiles

Italy is not an obvious PPLI jurisdiction. It has a stamp duty on foreign financial assets, a mandatory foreign-asset declaration regime, and a tax authority that has spent the last decade tightening enforcement on offshore structures. For a standard Italian tax resident, the case for offshore Private Placement Life Insurance is real but qualified.  For a new Italian tax resident who has elected the flat tax regime under Article 24-bis of the Italian Tax Consolidated Act, the case is fundamentally different. Italy’s New Tax Resident regime — doubled from EUR 100,000 to EUR 200,000 per year by Law 143 of October 2024 — makes Italy one of the most structurally efficient jurisdictions in Europe for large PPLI portfolios. Understanding the difference between these two

What non-residents need to know about French tax on property, bank accounts, and cryptocurrency — and how offshore PPLI addresses each one. Updated for 2026. French tax law moved after this article was first published. The flat tax is now 31.4%, the nine-jurisdiction withholding rule has been confirmed in published guidance, and the proposed wealth tax on unproductive assets was dropped from the final Finance Act. The current position is set out in full in France Raised the Flat Tax to 31.4%. Assurance Vie Was Left Out. The assumption many internationally mobile clients make is a reasonable one: if I don’t live in France, France can’t tax me. For the most part, that is correct. But “for the most part”

How French residents are using offshore Private Placement Life Insurance to eliminate the annual 31.4% tax drag, plan their estates, and protect crypto wealth — legally and transparently. Updated for 2026. French tax law moved after this article was first published. The flat tax on directly held portfolios is now 31.4%, life insurance was expressly excluded from the increase, and a new minimum-rate contribution (the CDHR) can affect large policy surrenders. The current position is set out in full in France Raised the Flat Tax to 31.4%. Assurance Vie Was Left Out. If you live in France and hold a meaningful investment portfolio, the French tax system has a simple answer to most of your decisions: sell shares — 31.4%.

For non-residents who own property, investments, or other assets in Spain. Your client does not live in Spain, but maybe they lived there in the past, visit regularly, or own a property on the coast that they bought as an investment or a holiday home. They may have a brokerage account holding Spanish equities, or a Spanish-situs bond portfolio. Perhaps they moved on — to London, to Dubai, to Geneva — and Spain is somewhere in the background of their financial life rather than its centre. But Spain has not moved on from them and their assets. Spanish-situs assets — property, shares in Spanish companies, certain financial instruments with a Spanish connection — attract Spanish tax on capital gains, Spanish

For wealth advisers with Spanish-resident clients — and those with clients planning to relocate. Your client moved to Spain, or has lived there for years. They have built a portfolio – equities, funds, some cryptocurrency, perhaps a bond ladder. And every year, without fail, the Spanish tax authority takes its share. Dividends received: taxed. Capital gain on a fund switch: taxed. One cryptocurrency swapped for another: taxed. Each event is a separate charge, a separate calculation, a reduction in the capital that is supposed to be compounding. From 2026, Spain introduced a new 30% rate on savings income above EUR 300,000 per year. That is the headline number. But even before reaching EUR 300,000, the standard rates are 19%, 21%,

The previous two pieces in this series established the UK tax baseline for life insurance payouts and the mechanics of trust structures that remove a policy from the policyholder’s estate for Inheritance Tax purposes. This third piece addresses a question that arises directly from that analysis: when the life company itself authors the trust structure — as is standard practice across the offshore PPLI market — does that structure hold, and what are the UK IHT implications across the major PPLI jurisdictions beyond the Crown dependencies? THIS SERIESPart 1 – Are Life Insurance Payouts Tax-Free in the UK?Part 2 – Writing Life Insurance in Trust: How the Structure Works and What Changed in April 2025Part 3 – Offshore PPLI and