Category: Taxation

The 2026 CSG increase took the French flat tax to 31.4% — and expressly left life insurance at 17.2%. The PPLI differential widened. But the CDHR now cuts the other way.

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. 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%,