Category: PPLI by Country

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 Left Brazil. The Receita Federal Did Not Entirely Let Go

Brazilian-source income, ITCMD on Brazilian-sited assets, and the planning most expatriates have not done. There is a recognisable Brazilian expatriate. The executive who built a São Paulo business and moved to Lisbon, Madrid, Miami, or Dubai. The entrepreneur who sold a Brazilian operating company and now lives, on the proceeds, between Switzerland and the United States. The next-generation heir who studied abroad, never went home, and inherited a Brazilian portfolio they have not yet had time to think about. The common feature is that the move out of Brazil was, for personal income tax purposes, complete: the Declaração de Saída Definitiva was filed; the Brazilian fiscal year closed; worldwide income is now taxed in the country of new residency, not

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Brazil Now Taxes Your Offshore Investments Every Year. The Question Your Adviser Should Be Asking Is Whether Your Insurance Policy Is Exempt

What Law 14,754/2023 changed, what the Supreme Court just confirmed about VGBL, and what it all means for offshore PPLI held by Brazilian residents. On 1 January 2024, the rule book that governs offshore wealth for Brazilian tax residents was rewritten. Law 14,754/2023, signed by President Lula in December 2023, ended decades of deferral. Financial investments abroad now attract a flat 15% Brazilian income tax. Profits of offshore companies controlled by Brazilian individuals are taxed annually, whether distributed or not. Foreign trusts are tax-transparent — assets treated as belonging to the settlor, income taxed as it arises. The structures that quietly worked for a generation of Brazilian families — Cayman holdings, BVI nominee companies, Bahamas trusts — are no longer

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You Left Singapore. Your Singapore Assets Did Not — And That Creates a Planning Problem

Singapore’s tax system stops following you the day you stop being resident. The tax systems of the places you go to — and the places your assets sit — do not. Consider another engagement. A Singapore-resident HNW client built and sold a business in Singapore over twelve years, then relocated his family to London in 2025. He kept a S$8 million Singapore brokerage account, his Singapore residential property (now leased), and a 12% interest in an Indonesian operating company that the original sale didn’t include. He thought, reasonably enough, that by ceasing to be Singapore tax resident he had cleared his international tax decks. He had not. Singapore does indeed stop taxing his foreign-sourced income on the day he ceases

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