Holdings and HNWI: holding structure, personal accounts, CFC rules, CRS and residency
Owners of several businesses, families with assets in different countries, founders after an exit. We build a holding that keeps shares and dividends free of double taxation, open personal accounts and private banking, and make sure CFC reporting and CRS do not bring letters from the tax office.
The tasks clients came to us with
A holding for three operating companies in different countries
The founder owned companies in Estonia, Poland and the UK directly and paid dividend tax three times. We set up a Cypriot holding, moved the shares with the exit-tax rules of each country in mind, and established substance in Cyprus. Dividends into the holding now flow free of withholding tax, and the founder files one CFC report instead of three.
Changing tax residency after an exit: from plan to certificate
After selling the business the founder planned to move to the UAE but kept a home, family and accounts in Ukraine. We drew up the plan: what to change in the Ukrainian ties, how many days to spend in the UAE, how to obtain the residence visa and the tax residency certificate. A year later UAE residency was confirmed, with the CFC notifications and CRS consequences closed.
Personal accounts and private banking for a family with assets on three continents
The family held assets at seven banks with no single picture, and two banks had requested source-of-wealth evidence. We prepared the source-of-wealth file, opened private banking accounts in Switzerland and Singapore, and consolidated the portfolio. The banks’ requests were closed and the CRS reporting now follows one logic.
What exactly we do for Holdings and HNWI
Structuring
A holding that keeps the shares, the property and the portfolio.
Residency
Where you are tax resident — and whether that is the status you want.
Accounts
Personal accounts, private banking, the holding’s accounts.
Deals
Buying, selling and passing on businesses and assets.
Contracts
Family and corporate agreements between owners.
Tax
CFC rules, CRS, dividends and capital gains in one calendar.
What we have written about Holdings and HNWI
Cyprus at 15%: What the 2026 Corporate Tax Change Means for Existing Structures
Cyprus corporate tax in 2026 is 15%, not 12.5%. The Second Schedule to the Income Tax Law now charges companies […]
Read articleChoosing a holding jurisdiction: what actually matters
Founders often pick a holding company location based on a single headline tax rate. In practice, the right jurisdiction depends […]
Read articleHolding assets in several countries and want one clear structure?
Tell us where the companies, the property and the accounts are, and where you live — we will say what the holding and the reporting would look like.
- A reply within one working day
- The first consultation is 30 minutes
- Confidential, no obligation