Jurisdiction: Other

According to New World Wealth who compiled the data for the Henley Global Citizens Report, a projected 88,000 of the world’s millionaires will move to a new country by the end of the year.

High-net-worth individuals (HNWIs) with a net worth of over US$1 million are extremely mobile following the Covid-19 pandemic, as well as the current war in Ukraine which is having global repercussions. Due to the lockdown and travel restrictions from Covid-19, there are no specific reports for 2020 and 2021 but as restrictions have now eased, momentum is gaining as relocation has become front of mind for many of the ultra-rich.

It will come as no surprise that Russia and Ukraine are projected to see some of the biggest emigration numbers, by the end of 2022. Andrew Amoils, the head of research at New World Wealth stated in the report that “Russia [is] haemorrhaging millionaires […] Affluent individuals have been emigrating from Russia in steadily rising numbers every year over the past decade, an early warning sign of the current problems the country is facing”. Russia is projected to see 15% of their HNWIs moving (projected 15,000).

However, it is Ukraine that is expected to suffer the greatest loss of HNWIs as a proportion of its population – a huge 42% of its HNWIs, could leave by the end of 2022; a predicted net loss of 2,800 millionaires.

China and India are also predicted to see their millionaire populations relocate. General wealth growth in China has been slowly declining in the past few years, which could lead to China seeing its most damaging year yet.

India on the other hand is not so concerning. Predicted figures are suggesting that India will see approximately 8,000 HNWIs migrate during 2022, however there is also a suggestion that those who have relocated in the past, are returning. In the next few years, we would not be surprised if the HNWI population in India rises substantially, which will then make it one of the biggest growing wealth markets at that time.

The UAE

During 2022, the UAE is expected to draw in the largest inflow of HNWIs, with approximately 4,000 millionaires from; Russia, India, Africa, and the Middle East moving to the country. The UAE has been known as a ‘millionaire magnet’ for many years; it has a robust international business hub, sits at the top amongst the world’s most competitive tax systems, and offers a luxury lifestyle from education, leisure activities, shopping, and hospitality, to its top-end real estate sector. With the UAE predicted to surpass the US this year, the US is rapidly losing its appeal as a haven for the world’s wealthiest.

Australia

In second place sits Australia – approximately 3,500 HNWIs will move to Oz before the end of 2022 (and according to the New World Wealth, 80,000 millionaires have already relocated in the last two decades). It is one of the largest countries in the world, rich in natural resources and fertile land, and has a thriving economy.

Singapore

Singapore is a favoured location, mainly for the rest of Asia. Emerging as Asia’s top wealth management centre, this makes sense. A net inflow of approximately 2,800 HNWIs is expected to find a home in this prosperous country.

Israel

Israel sits closely behind, with large numbers of HNWIs from the UK, France and Russia set to move there; approximately 2,500 during the year.

Switzerland

But it is Switzerland we are keeping our eye on. Even though Switzerland is not part of the EU, it is within the Schengen area, and has always been an elite jurisdiction in which to settle down. Switzerland is projected to attract a net inflow of around 2,200 in 2022.

It has always featured amongst the top most attractive countries for high-net-worth individuals to live, being one of the world’s wealthiest countries and known for its impartiality and neutrality. In 2021 Geneva was listed as one of the wealthiest cities in the world with the total wealth held in the city amounting to US$875 billion.

Portugal

A consistent favourite, fuelled by the ‘Golden visa’ of Golden visas. Over the last decade, Portugal has seen HNWIs, wealthy entrepreneurs and ultra-rich investors from around the globe, predominantly from Turkey, South Africa, and South America, but also most recently from the US, relocate to its sunny shores. With the current hype around digital nomadism and the D7 visa, the younger generation of HNW families are setting up shop in Lisbon. An expected inflow of 1,300 HNWIs is expected in Portugal in 2022.

Greece

More and more HNWIs are relocating to Greece and applying for its Golden visa programme, with millionaires from Turkey, Russia, Ukraine, and China all favouriting the country. Greece is expected to see around 1,200 HNWIs apply in 2022. Dixcart has already seen interest, especially around the opportunities that are presented by obtaining a Greek residence permit but becoming tax resident in Cyprus and benefiting from the Cypriot non-dom tax regime.

Malta

Whilst just outside the top 10 list of countries gaining millionaires in 2022, Malta still has an important spot. Approximately 300 millionaires are expected to move to Malta in 2022, joining at least 2 billionaires already registered on the island.

In terms of wealth growth, the island currently has one of the fastest growing markets, with its strong economic performance in recent years being driven by its shift towards fast-growing services such as; finance, e-gaming and tourism, and its citizenship by naturalisation programme which has brought substantial new wealth to the island.

Summary

“Countries that draw wealthy individuals and families to migrate to their shores tend to be robust, with low crime rates, competitive tax rates, and attractive business opportunities,” Amoils has stated.

Dixcart Domiciles offers specialist advice regarding various residence programmes around the world. 

We can help you discover the different countries around the world that offer attractive residence and/or citizenship programmes and those that might suit you and your family best, and provide advice on a number of tax efficient solutions that might be available.

Get in touch

If you are considering relocating and would like to speak to an adviser to find out which programme and/or country best suits you and your family’s needs, please contact us: advice@dixcart-domiciles.com.

A move of residence can provide opportunities to review your affairs and holding structures. There may well be potential to implement wealth preservation and inheritance provisions, and advantageous strategic investment structures.

Every jurisdiction is different. There will always be some specific items to consider before relocating and taking bespoke professional advice at an early stage will always be the right thing to do. Carefully considered pre-exit and pre-arrival planning is essential to ensure a smooth and efficient move.

Please see below a comprehensive checklist that every individual and their family need to consider before relocating.

PRIOR TO ARRIVAL IN NEW COUNTRY

Consider Practical Issues	Travel documents (visas) Formal enrolment in country/jurisdiction of ‘arrival’, including communication with tax authorities, healthcare, schooling, etc.
Succession and Inheritance	Confirm which laws govern succession and whether a choice of different jurisdiction law is available. Confirm whether marital/family laws are affected and whether a choice of different jurisdiction law is available. Review estate planning documents (wills, succession, and prenuptial documents) and consider the interaction of wills, appropriate for different jurisdictions.
Implications of Transferring Physical Wealth	Family heirlooms, jewellery and works of art (possible ban on export or right of first refusal, etc.). Are import duties applicable?
Before Exit	Confirm arrangements that affect heirs and family that remain behind. Optimal timing of loss of tax residence and exit charges. Consider establishing new banking arrangements to segregate income and gains, if this is relevant to the new residence regime.
Before Arrival	Seek early tax advice from a professional advisor. Take advantage of any special tax regimes that are available. Review if there are any changes to controlled foreign company rules and what the effects may be. Ensure that previously established companies, trusts, life insurance policies, etc. are compliant.
Gifts and Donations	Confirm whether gifts or donations should be executed in advance of acquiring a new residency.
ONGOING	Annual review of estate planning documents (wills, succession, and prenuptial documents). Annual review of trusts arrangements, structures, and bank accounts. Annual review of any changes to tax laws and implications in relation to existing agreements and structures.

Residency versus Citizenship

Residency and citizenship are not the same things. Individuals may seek alternative residency in another country and may still remain a citizen of their country of origin. Citizenship is the status of being a ‘citizen’ of a country. This will include the privilege of holding a passport for that country. Dual citizenship (nationality) may be an interesting option, but it is not always feasible, depending on an individual’s country of origin.

Residence Programmes

Residence programmes vary in what they offer and the criteria that need to be met. Depending on the country, there are differences regarding the time period that residence is valid for, how to apply, what the benefits are, tax obligations, and how to move on to apply for citizenship (and a passport), if the individual wishes to follow this route and it is permitted by the particular residence programme.

There are many reasons why individuals and their families choose to take up residence in another country. They may wish to start a new life elsewhere, in a more attractive and relaxing environment, or they may find the greater political and economic stability that another country offers, of appeal.

For individuals considering an alternative country of residence, the most important decision is where you and your family would like to live. It is critical that clients consider the long-term objectives for themselves and their family before applying for a particular residence (and/or citizenship programme), to help make sure that the decision is right for now and in the future.

Citizenship – A Passport

The benefit of gaining citizenship is the right to obtain a passport from a particular country. This may also make travel much easier, into and out of a considerable number of countries.

A number of residence schemes can lead to citizenship and a passport. Countries where this is possible include: the Isle of Man, Malta, Portugal, St Kitts & Nevis, and the UK. If ease of travel and a relatively quick solution is required whilst plans are in progress to live elsewhere, a St Kitts & Nevis passport can offer a good interim solution.

What else can Dixcart Domiciles help you achieve?

Experts at Dixcart Domiciles will not only help you achieve your family goals but can assist further, by explaining the tax regimes that exist in different countries (a number of which are particularly attractive for new residents) and assist you to ensure that your affairs are structured in a tax efficient manner. The exit strategy from the country that you are moving from also needs to be planned for. We can also help on a practical level by organising visits to the country and helping you complete application forms and supply the right documentation. You may also need advice regarding the purchase of real estate – and even help with the move itself.

If you would like to talk to one of our experts, please contact: advice.domiciles@dixcart.com. Alternatively, please contact your usual Dixcart contact.

‘Digital nomadism’ has never been so topical.

Over recent years the concept of remote working has become an every day reality. Technology has improved and the way the workplace is structured is changing; a new culture of working from home is being adopted by a lot of companies, especially as a result of the Covid-19 pandemic and stay-at-home requirements enforced by many countries around the world. 

There are numerous countries around the world offering Digital Nomad visas. Three of the most popular countries are; Cyprus, Malta, and Portugal – here is why.

CYPRUS

From January 2022, Cyprus is launching a Digital Nomad Visa for non-EU nationals wishing to work remotely for employers/clients based outside of Cyprus. Individuals who are self-employed, salaried, or on a freelance basis, can apply for the right to live and work in Cyprus.

Individuals who apply for the Cyprus Digital Nomad visa will have the right to stay in Cyprus for a period of up to 1 year. They can renew the visa for another 2 years, if required.

Cyprus is an attractive destination for individuals; it is a member of the EU, located in the eastern Mediterranean Sea and enjoys over 320 days of sunshine per year, it offers the warmest climate in Europe, has a good infrastructure and a convenient geographic location for internationally mobile individuals – it is easily accessible from in Europe, Asia, and Africa.

The population of Cyprus is approximately 1.2 million, with 180,000 foreign nationals living in Cyprus. It offers an excellent private healthcare sector, a low cost of living, and a friendly expat community.

As an incentive to attract and retain highly-skilled and highly-paid expats to Cyprus, foreign workers (for example, non-dom tax residents), do not need to pay taxes on international dividends, ‘passive’ interest income, or profit from the sale of securities.

In addition, individuals who were not previously resident in Cyprus, but who take up residence in Cyprus for work purposes, and earn over €100,000 per annum, are entitled to the following tax benefit:

• 50% of employment income earned in Cyprus is exempt from income tax for a period of 10 years.

However, the proposal for 2022 (the relevant legislation has not yet been implemented) is to allow an income tax exemption of 50% to new resident employees with income of €55.000.

MALTA

Malta has introduced a Nomad Residence Permit which enables individuals to maintain their current job in another country whilst they legally reside in Malta. The permit is targeted at non-EU remote workers and entitles them to reside in Malta for 1 year. After this, the visa can be renewed.

Malta offers the climate, the relaxed lifestyle and rich history to make living in Malta a real pleasure. Located in the Mediterranean, just south of Sicily, Malta offers all of the advantage of being a full member of the EU and Schengen Member States, has English as one of its two official languages, and a climate many chase all year round. Malta is also very well connected with most of the international airlines, which makes travel to and from Malta easy.

Since joining the EU and due to the forward-thinking Government actively encourages new business sectors and technologies, Malta’s economy has enjoyed large growth in recent years.

With a population of about 475,000 over an area of 316 square kilometres, Malta is already home to many expats and EU digital nomads. This community of ‘nomads’, enjoys Malta’s climate and lifestyle, and have already begun to interact with people with similar ideas, to add value to the community.

The Nomad Residence Permit in Malta opens up this opportunity to third country citizens, who would usually need a visa to travel to Malta. This permit lasts for 1 year and can be renewed at the discretion of Residency Malta, as long as the individual still meets the criteria.

Applicants for the Nomad Residence Permit must prove they can:

• Work remotely using telecommunication technologies, or
• Work for an employer registered in a foreign country and have a contract for this work, or
• Perform business activities for a company registered in a foreign country (and be a partner/shareholder of that company), or
• Offer freelance or consulting services, mainly to customers whose permanent establishment is in a foreign country, or
• Earn a monthly income of €2,700 gross of tax.

One of the biggest advantages of relocating to Malta is the remittance basis of taxation. Malta non-domiciled individuals are taxed on Malta source income and certain gains arising in Malta but are not taxed on non-Malta source income not remitted to Malta. In addition, they are not taxed on capital gains, even if this income is remitted to Malta.

PORTUGAL

Portugal’s temporary residence visa is particularly popular with freelancers and entrepreneurs; it is an independent workers and entrepreneurs visa available to individuals for 1 year. After this it can be renewed for up to 5 years. After 5 years, individuals have the option to apply for permanent residency in Portugal if they wish.

Portugal is located in the southwest of mainland Europe and is easily accessible in terms of travel to and from the rest of the world, which makes it very popular with international mobile individuals. The two islands of the Azores and Madeira are also autonomous regions of Portugal and, like the mainland, offers fantastic weather, a relaxed lifestyle, cosmopolitan cities, and stunning coastlines.

The Portuguese government is very aware of Portugal’s reputation as an international hub for digital nomads and, in response, launched a ‘Madeira Digital Nomads’ project, to attract foreign professionals to the island. Those taking advantage of this initiative can live in the Digital Nomad village in Ponta do Sol which boasts both villa or hotel accommodation, free wi-fi, coworking stations and regular social events.

For individuals who wish to live and work in Portugal, for example in Lisbon, Porto, or along the coast of the Algarve, there is also a large and established community to interact with. Lisbon is teeming with digital nomads, and Porto is the second most popular spot.

Portugal is an attractive and popular location – not only for digital nomads to move to – but for a large variety of individuals, in many different circumstances. Not only is it a beautiful country, offering an attractive lifestyle, but it also offers the popular Non-Habitual Residents programme (NHR), which allows individuals moving to Portugal to enjoy tax advantages once they re-locate here.

This has proven to be a major motivator for both EU and non-EU citizens. Provided they have not been resident in Portugal for the previous 5 years, they can enjoy non-habitual status for 10 years, whereby income derived from employment or independent personal services (from a domestic source) is taxed at a special flat rate of 20% provided the income is from high value-added activities or a scientific, artistic, or technical nature. In addition, a tax exemption might also apply to income derived from a foreign source.

Summary

Digital nomad visas and temporary residence permits have made travelling the world and working, easy and enjoyable. They provide new opportunities to individuals who can work remotely and independently of their location but continue to remain legally employed by their current employer. If you would like more information on applying for a Digital Nomad visa, please contact:

• Katrien de Poorter in our Cyprus office: advice.cyprus@dixcart.com
• Henno Kotze in our Malta office: advice.malta@dixcart.com
• Catarina Sardinha in our Portugal offices (Lisbon and Madeira): advice.portugal@dixcart.com

Alternatively, please contact your usual Dixcart contact.

Dixcart Management Malta Limited Licence Number: AKM-DIXC-21

What is Changing?

India is tightening its residency provisions specifically to push ‘stateless’ persons (Indian nationals), who are not liable to tax in any other country, within the Indian tax net.

In addition, in order to become non-resident in India you will have to stay outside of India for at least 240 days per tax year and as detailed above, Indian citizens will also need to be liable to pay tax in another country, by virtue of domicile or residence.

Who Will this Affect – What Can be Done?

Non-Resident Indians (NRIs) who are “Citizens of the World,” often find they do not stay anywhere long enough to trigger tax residence. Other NRIs are resident in countries that do not impose taxation on individuals. For both of these groups of NRIs, the changes will have a major impact.

Such NRIs will now have to accept Indian tax residency or ensure that they either cease to be Indian citizens or find a tax residence that is not too punishing in respect of their global income.

UK Tax Residence

NRIs in the above position could do far worse than to consider becoming tax resident in the UK.

UK tax residence can be triggered by a combination of connecting factors and days spent in the UK. By having a regular pattern of visits, having accommodation available, a spouse with you on your visits to the UK, and by doing some work in the UK, residence could be triggered by as little as a 46 day presence.  Many NRIs spend some time in London and therefore a slight adjustment could trigger UK tax residence.

Whilst the UK is a ‘high’ tax jurisdiction, NRIs who are tax resident in the UK can enjoy a very favourable tax position thanks to the UK’s remittance basis of taxation. With proper planning, before becoming UK resident, it is possible to pay very little tax.

Giving Up Existing Citizenship

For those wanting to give up their existing citizenship and take up new citizenship, key problems can be; the amount of time that this can take and the commitment in terms of the time to be spent in the host country. To be eligible to apply for UK citizenship, for example, you would need to spend nine months a year in the UK for six years.

There are however some faster alternatives. With a significant donation, you can gain citizenship in Malta after 12 months. With a €2,000,000 investment into Cyprus real estate, you could secure Cyprus citizenship in 180 days. 

St Kitts & Nevis Citizenship

A potentially faster and cheaper option is the St Kitts & Nevis Citizenship Programme, which can be fast tracked. This would enable you to secure citizenship, costing from US$186,000 (required donation and professional fees), within two months.  

A St Kitts & Nevis passport enables the holder to travel visa free or visa on arrival to all Schengen countries, Commonwealth countries, the UK and Russia.

St Kitts & Nevis Citizenship AND UK Tax Residence

A viable and attractive solution could be to gain St Kitts & Nevis citizenship while   becoming UK tax resident. The advantageous UK remittance basis of taxation can be enjoyed by NIRs for up to 15 years.

Additional Information

If you require further information on any of the issues raised in this Information Note please speak to Peter Robertson at the Dixcart office in the UK: advice.uk@dixcart.com or to your normal Dixcart contact.