Category: Taxation

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

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

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

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. 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” is doing a lot of work in that sentence. France has a long reach when it comes to assets with a French connection, and the gaps in that assumption — inheritance tax on French property, withholding tax on French income, wealth tax on French real estate above the threshold — can be expensive for clients who have not planned around them. France imposes succession tax

How French residents are using offshore Private Placement Life Insurance to eliminate the annual 30% tax drag, plan their estates, and protect crypto wealth — legally and transparently. If you live in France and hold a meaningful investment portfolio, the French tax system has a simple answer to every decision you make: 30%. Sell shares — 30%. Receive dividends — 30%. Swap one cryptocurrency for another — 30%. Every year, without exception, the prélèvement forfaitaire unique takes its share of everything your money earns. Add 17.2% social charges to that picture, and the cost of holding wealth in France directly is not incidental — it is structural. For a €3 million portfolio generating 5% a year, the annual PFU alone

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