PPLI Technical Guides

How the 12-year holding period eliminates income tax on PPLI returns under §20 EStG. Covers InvStG black fund risk, VVG compliance, BaFin PRIIPs disclosure, and inheritance tax exposure for non-residents with German assets.

How PPLI defers the 30% PFU flat tax on investment returns for French residents, and how the 8-year threshold unlocks additional advantages. Covers Loi Sapin II compliance, Form 3916-bis declaration, IFI wealth tax, and succession planning under French forced heirship rules.

Structuring PPLI in a zero-tax jurisdiction. Covers Sharia succession and forced heirship risk for non-Muslim expats, DIFC and ADGM foundation alternatives, and how offshore PPLI functions as a succession bypass mechanism for internationally mobile clients based in the Gulf.

How PPLI functions in Portugal after the end of NHR and introduction of the IFICI framework in 2024. Covers IFICI tax interaction with offshore insurance wrappers, investment fund taxation, stamp duty on life policies, and structuring for new arrivals, long-term residents, and non-residents with Portuguese property.

How to use PPLI alongside the Beckham Law six-year IRPF exemption — and how to structure for when the window closes. Covers Modelo 720 reporting, the 30% investment income cap under standard IRPF, the solidarity wealth tax, and succession planning under Spanish forced heirship rules.

How Greece's Article 5A flat-tax regime caps all foreign-source income at €100,000 per year — and how PPLI interacts with this. Covers foreign-asset reporting obligations, non-resident exposure on Greek property, and structuring for clients considering or already holding Greek tax residency.

How PPLI functions within Switzerland's favourable tax environment: no capital gains tax for private investors, lump-sum taxation for qualifying foreign nationals, and no federal estate tax. Covers cantonal wealth tax interaction, FINMA regulation of foreign PPLI issuers, and Swiss banking integration within an insurance wrapper.

How offshore PPLI interacts with Italy's foreign asset reporting framework. Covers Quadro RW declaration, IVAFE (0.2% annual wealth tax on foreign financial assets), the substitute tax exemption under Art. 26-ter, Italian forced heirship (legittima), and pre-immigration structuring windows.

How PPLI serves Singapore-based HNW clients outside or below the S13O/S13U family office framework. Covers MAS tightening of family office conditions (2023), VCC as a competing structure, Singapore's territorial tax system, the abolition of estate duty, and PPLI for mobile Asia-Pacific clients.

How Brazil's 2024 offshore investment tax reform changes PPLI structuring for Brazilian residents. Covers annual 15% accruals taxation on offshore financial investments under Law 14,754/2023, the ITCMD inheritance tax reform, VGBL comparison, BACEN exchange controls, and whether offshore PPLI qualifies for the life insurance exemption.

Estate tax planning for non-US persons with US-sited assets. Covers IRC §2042 estate tax (40% on US assets above $60,000 for non-resident aliens with no treaty exemption), §817(h) diversification requirements, withholding tax rates by carrier jurisdiction, and the §871(h) portfolio interest exemption.

An honest assessment of PPLI for Australian clients. Covers Foreign Investment Fund rules (Division 394), the Part IVA general anti-avoidance rule, CGT treatment under s section 118-300, and where PPLI genuinely delivers value in the Australian context — primarily succession and estate planning in the absence of federal estate duty.

An honest assessment of where offshore PPLI works for Canadian-connected clients — and where it does not. Covers ITA s.94.1 (why PPLI generally does not work for Canadian residents), departure tax planning, and how Canadian non-residents can use PPLI effectively under the rules of their new country of residence.

How the abolition of the UK non-dom regime (April 2025) reshapes PPLI structuring for UK-connected clients. Covers the new long-term resident IHT test, ITTOIA 2005 chargeable event rules for offshore policies, the Temporary Repatriation Facility window, ATED on UK property, and the post-Brexit carrier access question.

How Cyprus's 17-year SDC exemption for non-domiciled residents creates one of Europe's longest tax-deferred compounding windows — and how the 2026 reform changes the planning. Covers the liberalised 60-day residency rule, the new 8% cryptocurrency disposal charge, partial surrender rules for structured withdrawals, and the post-17-year extension option.