# Maria Plotnikova

Role: Lawyer, Family Office
Location: Barnaul, Russia
Email: maria@private.law
LinkedIn: https://www.linkedin.com/in/maria-plotnikova-b34460234
Canonical: https://wiki.private.law/en/authors/plotnikova

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## Experience

- private.law (2022 – present)

## Education

**University education**

- Altai State University (ASU) — Specialist in Law, “Judicial and Prosecutorial Activity”, honours (2023)

**Additional courses**

- Web Application Developer, Altai State University (2023)
- Professional Mediation, Altai State University (2022)
- Legal Foundations of Digital Technologies and Digitalisation of the Electoral Process in the Russian Federation, Altai State University (2022)

## Wiki articles

- Trust Jurisdictions: A Map for Choosing Where to Settle
  URL: https://wiki.private.law/en/trust-jurisdictions-map
  Summary: Fifteen trust jurisdictions on one map: firewall and reserved powers, perpetuity, purpose trusts and PTCs, trust tax, regulators and published tariffs, the creditor test and digital-asset custody.
  Last modified: 2026-09-20T14:01:00.000Z

- Crypto Banks and Custodians: Where a Private Holder Keeps Coins and Receives Fiat
  URL: https://wiki.private.law/en/crypto-banks-custodians-map
  Summary: Eighteen crypto banks and qualified custodians compared on licence, bankruptcy treatment of client coins, entry thresholds, fiat rails and published fees.
  Last modified: 2026-09-20T13:57:00.000Z

- Redomiciliation Routes: Moving a Company or a Fund to Another Register
  URL: https://wiki.private.law/en/redomiciliation-routes
  Summary: Nineteen continuation regimes compared: which registers admit a company and let it leave, exit tax, substance, licences, fees, funds and the alternatives.
  Last modified: 2026-09-20T13:51:00.000Z

- TRF Designation Mechanics
  URL: https://wiki.private.law/en/uk-trf-designation-mechanics
  Summary: TRF designation after Finance Act 2026: rates by designation year, eligibility, the double designation requirement, mixed funds and correcting errors.
  Last modified: 2026-09-14T19:07:00.000Z

- The EU Tax Omnibus and the DAC Recast: The 24 June 2026 Proposals
  URL: https://wiki.private.law/en/tax-omnibus-dac-recast-2026
  Summary: Two Commission proposals of 24 June 2026: a narrow carve-out for Pillar Two groups, Category A hallmarks deleted, 90 days instead of 30, imported hybrid mismatches removed, a single 30% of EBITDA and a mandatory EUR 3 million. Status: proposal; application from 1 January 2029.
  Last modified: 2026-09-14T18:27:00.000Z

- EU Public Country-by-Country Reporting: The EUR 750 Million Threshold and the Aggregated Line
  URL: https://wiki.private.law/en/public-cbcr
  Summary: The EUR 750 million threshold, who publishes when the parent sits outside the EU, named versus aggregated jurisdictions, the shorter Spanish and Hungarian deadlines, the safeguard clause and first-wave evidence.
  Last modified: 2026-09-14T18:22:00.000Z

- Corporate Tax Residence: Incorporation, Management and Control, and Dual Residence
  URL: https://wiki.private.law/en/corporate-tax-residence
  Summary: How corporate tax residence works: incorporation-based vs central management and control tests, board minutes vs substance of decision, dual residence and the post-2017 treaty rule, with an evidence matrix.
  Last modified: 2026-09-20T20:20:00.000Z

- Transfer Pricing: Arm's Length Principle, Methods and Disputes
  URL: https://wiki.private.law/en/transfer-pricing
  Summary: How the arm's length principle prices controlled transactions between associated enterprises — delineation, the five OECD methods, loans, IP/DEMPE, services, and the APA/MAP route when two states disagree.
  Last modified: 2026-09-14T19:18:00.000Z

- Entity Classification: Persons, Instruments and Income Across Borders
  URL: https://wiki.private.law/en/entity-classification
  Summary: How each country decides whether an entity is a taxpayer or a look-through, an instrument debt or equity, and how ATAD 2 neutralises hybrid mismatches.
  Last modified: 2026-09-14T19:16:00.000Z

- Companies and Holdings: Jurisdiction, Form and Place of Management
  URL: https://wiki.private.law/en/companies-hub
  Summary: Map of the corporate domain: legal form and company residence, substance and anti-abuse tests, holding jurisdictions compared, and the sanctions filter that comes first.
  Last modified: 2026-09-20T17:08:00.000Z

- Health Insurance for a Spanish Residence Permit
  URL: https://wiki.private.law/en/spain-health-insurance-residency
  Summary: Which medical policy clears a Spanish immigration file: the DGSFP register, sin copago and sin carencia wording, the closed list of UGE exclusions and the Seguridad Social fork.
  Last modified: 2026-09-11T15:31:00.000Z

- United States: Tax, Structures and Banking for Private Capital
  URL: https://wiki.private.law/en/usa-hub
  Summary: US hub: US person status and substantial presence, pre-immigration planning, LLCs and trusts, the $15m estate exemption, 877A exit tax, EB-5 and banking.
  Last modified: 2026-09-20T20:15:00.000Z

- Singapore Holding Companies with EU Founders: Management, CFC and Substance
  URL: https://wiki.private.law/en/singapore-holding-eu-founders
  Summary: Singapore holding company with founders in Europe: where the operating company goes, why effective management decides residence (ITA s.2) and how EU CFC rules under ATAD treat the holding.
  Last modified: 2026-09-14T18:40:00.000Z

- Singapore IP Companies with UK-Resident Owners: IDI and CFC Rules
  URL: https://wiki.private.law/en/singapore-ip-uk-resident-owner
  Summary: IP in a Singapore company under the IP Development Incentive (5%/10%, ITA s.43X, nexus) with the family in the UK: UK CFC rules (TIOPA 2010 Part 9A), central management and control, substance.
  Last modified: 2026-09-11T19:08:00.000Z

- UAE Holding Company for an EU Operating Business: Anti-Abuse, Beneficial Ownership, Substance
  URL: https://wiki.private.law/en/uae-holding-eu-operating-company
  Summary: UAE holding over an EU operating business: 0%/9% corporate tax, participation exemption (Art. 23 FDL 47/2022), no Parent-Subsidiary shelter, GAAR and beneficial-ownership tests and real substance.
  Last modified: 2026-09-11T15:24:00.000Z

- Investor Routes in the Americas and Oceania: A Map
  URL: https://wiki.private.law/en/investor-routes-americas-oceania
  Summary: Thresholds, timelines and presence: EB-5 and the Gold Card, New Zealand, Panama, Paraguay, Uruguay, Chile. The 2026 investor map of the Americas and Oceania.
  Last modified: 2026-09-20T13:39:00.000Z

- Family Wealth: Matrimonial Property, Inheritance and Governance
  URL: https://wiki.private.law/en/family-hub
  Summary: A map of the family perimeter: the matrimonial regime first, then the instrument, then the event. Regulations 2016/1103 and 650/2012, waiver of the reserved share, governance and the family office.
  Last modified: 2026-09-14T19:09:00.000Z

- Cross-Border Divorce Jurisdiction: Where to File and How to Get the Decree Recognised
  URL: https://wiki.private.law/en/divorce-jurisdiction
  Summary: Jurisdiction under Regulation (EU) 2019/1111, the race of fora and lis pendens, English rules under s. 5(2) DMPA 1973, recognition of foreign divorces, and why money does not follow the divorce.
  Last modified: 2026-09-14T18:33:00.000Z

- Japan and Korea: payment and crypto licences
  URL: https://wiki.private.law/en/japan-korea-fintech-licenses
  Summary: Licensing in Japan and South Korea: funds transfer tiers, prepaid issuers, JPYC and JPYSC stablecoins, crypto moving into FIEA, Korea's VAUPA and EFTA, real-name accounts and 2024–2026 enforcement.
  Last modified: 2026-09-13T10:24:00.000Z

- Money Transmitter Licenses in the US: Fifty Licenses Instead of One
  URL: https://wiki.private.law/en/money-transmitter-license-usa
  Summary: No federal money transmission license exists in the US: MTMA implementation, state exemptions, bond and capital rules, crypto regimes and 18 U.S.C. 1960.
  Last modified: 2026-09-20T21:06:00.000Z

- The Russian Applicant in Investment Migration: The Ban, the Refusal and the Banking Constraint
  URL: https://wiki.private.law/en/russian-applicants-investment-migration
  Summary: All five Caribbean programmes have been closed to Russian applicants since 31 March 2023, the EU wants CBI gone by 1 June 2028, and Article 5b caps EU bank deposits.
  Last modified: 2026-09-20T20:58:00.000Z

- Caribbean CBI Under Ultimatum: the EU's 2028 Deadline and US Entry Restrictions
  URL: https://wiki.private.law/en/caribbean-cbi-2028
  Summary: The EU wants Caribbean CBI programmes wound down by 1 June 2028 or Schengen goes; the US already restricts Antigua and Dominica. What issued passports face.
  Last modified: 2026-09-20T20:57:00.000Z

- Compliance Stack for a Licensed Operator: Roles, Policies, Systems and Audit
  URL: https://wiki.private.law/en/compliance-stack
  Summary: Four AML programme skeletons instead of the "five pillars", BWRA as the load-bearing element, NYDFS Part 504 certification, MLRO pay of £140–300k and the 2024–2026 fines.
  Last modified: 2026-09-16T13:35:00.000Z

- Athlete Visas and Residence Permits: A Map of the Routes
  URL: https://wiki.private.law/en/athlete-visas
  Summary: P-1A and O-1A in the US, premium processing at $2,965 from 1 March 2026, the FA's June 2026 GBE changes, carte talent, § 22 BeschV and the UAE Golden Visa.
  Last modified: 2026-09-14T19:07:00.000Z

- Sanctions Screening at a Financial Operator: The Discipline That Holds Payments Together
  URL: https://wiki.private.law/en/sanctions-screening
  Summary: The EU's 21st package of 23 July 2026, OFAC's sham-transactions guidance and a USD 275m penalty: how sanctions screening works and why payments stall.
  Last modified: 2026-09-14T19:00:00.000Z

- Creator Holdco: Turning Reach into Capital
  URL: https://wiki.private.law/en/creator-holdco
  Summary: § 1221(a)(3) IRC turns the sale of a channel into ordinary income: why a creator needs a holdco, a C-corp and QSBS with a $15m cap, and how the Beast round works.
  Last modified: 2026-09-14T18:09:00.000Z

- Image Rights: The Persona as a Tax Structure
  URL: https://wiki.private.law/en/image-rights
  Summary: Article 92 LIRPF and the 85/15 rule, the Ancelotti conviction of 09.07.2025, HMRC after Hull City, the Guernsey register at £500 and the 65/35 split in Garcia.
  Last modified: 2026-09-12T07:42:00.000Z

- Retroactive Reform: What Happens to Your Status When a Programme Closes
  URL: https://wiki.private.law/en/investment-migration-status-risk
  Summary: Ireland 2023, the UK 2022, Spain 2025, Malta after C-181/23, Portugal 2026 and EB-5 to 30.09.2026: how reforms hit status and the road to a passport.
  Last modified: 2026-09-07T04:34:00.000Z

- Getting Paid After You Move: Ohtani, Bonuses and RCAs
  URL: https://wiki.private.law/en/deferred-comp-relocation
  Summary: 4 U.S.C. § 114 and Ohtani's $680m: how a deferred payout escapes state tax, where § 409A and § 457A bite, and what the Tavares dispute with the CRA turns on.
  Last modified: 2026-09-06T07:32:00.000Z

- The EU AML Package: AMLR, AMLD6 and AMLA — What Actually Changes in 2027–2028
  URL: https://wiki.private.law/en/eu-aml-package
  Summary: A single rulebook from 10 July 2027, AMLA supervision from 2028, a €10,000 cash cap, a 25% beneficial-ownership threshold and EDD for €50m+ clients — the map.
  Last modified: 2026-09-14T11:57:00.000Z

- PSD3 and PSR: EU Payment Services Reform
  URL: https://wiki.private.law/en/psd3-psr
  Summary: One PI licence replaces the EMI regime: re-authorisation within 27 months, verification of payee, TARGET access and new capital floors — the EU payments reform calendar to 2029.
  Last modified: 2026-09-11T18:56:00.000Z

- SG-FORGE: Société Générale's MiCA Stablecoins
  URL: https://wiki.private.law/en/sg-forge
  Summary: The only global systemically important bank issuing MiCA stablecoins on public chains: how EURCV and USDCV work and why Euroclear is testing them for settlement.
  Last modified: 2026-09-11T15:02:00.000Z

- Slash: Business Banking for Specialised Industries
  URL: https://wiki.private.law/en/slash
  Summary: Slash is a US financial platform for specialised and higher-risk industries. Business accounts, corporate and virtual cards, Global USD Account, stablecoins, partner banks, pricing and onboarding.
  Last modified: 2026-09-20T20:11:00.000Z

- Alpian: Licensed Digital Bank in Switzerland
  URL: https://wiki.private.law/en/alpian
  Summary: Alpian is a FINMA-licensed Swiss digital bank for mass-affluent residents: multi-currency accounts, debit cards, managed and advisory portfolios, Pillar 3a, pricing, esisuisse protection and limits.
  Last modified: 2026-09-16T13:50:00.000Z

- BVNK: Stablecoin Payment Infrastructure for Businesses
  URL: https://wiki.private.law/en/bvnk
  Summary: BVNK provides infrastructure for cross-border payments through stablecoins and bank rails. Products, licences, onboarding, pricing model and the acquisition by Mastercard.
  Last modified: 2026-09-16T13:46:00.000Z

- Ramp: Corporate Cards, Spend Management and Treasury
  URL: https://wiki.private.law/en/ramp
  Summary: Ramp is a financial platform for US companies: corporate cards, spend management, bill pay, procurement and treasury via partner banks. Pricing, FDIC sweep, money-market funds, AI tools, onboarding.
  Last modified: 2026-09-11T07:53:00.000Z

- Flex (flex.one): Business Accounts, Cards and Payments Through Partner Banks
  URL: https://wiki.private.law/en/flex
  Summary: Flex is a fintech platform for US businesses, not a bank. Business accounts, cards, international payments, partner banks, FDIC sweep coverage, pricing, stablecoin features and onboarding limits.
  Last modified: 2026-09-05T18:33:00.000Z

- Capital Gains Tax: Basis, Realisation and Buy-Borrow-Die
  URL: https://wiki.private.law/en/capital-gains-tax
  Summary: How capital gains tax works and why realisation is the operative word: rates by country, step-up basis, buy-borrow-die mechanics, exchange funds and exit taxes.
  Last modified: 2026-09-20T19:23:00.000Z

- Private Museum and Charitable Foundation: Collection Ownership and the FMV Deduction
  URL: https://wiki.private.law/en/private-museum-foundation
  Summary: Private operating foundation §4942(j)(3): full fair market value deduction, 30% AGI ceiling, related use, self-dealing under §4941 and the 0.5% floor from 2026.
  Last modified: 2026-09-14T19:07:00.000Z

- Private Aircraft Tax: Bonus Depreciation, VAT and Personal Use
  URL: https://wiki.private.law/en/aircraft-tax-planning
  Summary: 100% bonus depreciation after OBBBA, the §280F, §274 and §469 tests, 2026 SIFL rates, EU input VAT recovery and the capital goods scheme, benefit in kind across four jurisdictions.
  Last modified: 2026-09-14T18:12:00.000Z

- Capital Gains on Art and Collectibles by Country
  URL: https://wiki.private.law/en/collectibles-capital-gains
  Summary: US 28% plus NIIT, Germany nil after a year and a day, France 6.5% of price, UK wasting assets, Switzerland and Italy judged on the seller's conduct.
  Last modified: 2026-09-13T09:41:00.000Z

- Taxes for private wealth: residence, special regimes and ownership structures
  URL: https://wiki.private.law/en/taxes
  Summary: Hub for the tax section: three variables of the calculation, residence tests and exit tax, new-resident regimes, CFC rules, CRS, DAC8 and UBO registers.
  Last modified: 2026-09-20T13:11:00.000Z

- Yacht Ownership: Flag, VAT, Charter and Crew
  URL: https://wiki.private.law/en/yacht-ownership
  Summary: Flag map from the Red Ensign Group to Malta, charter rules country by country, VAT and temporary admission, crew and MLC, radio and MMSI, 2025–2026 trends and Q/A.
  Last modified: 2026-09-14T19:02:00.000Z

- Charitable Deduction: Appreciated Stock, CRT/CLT and DAFs
  URL: https://wiki.private.law/en/charitable-deduction
  Summary: The charitable deduction after the 2026 rewrite: the 0.5% AGI floor, the 35% cap, the $1,000 non-itemizer deduction, appreciated stock, DAF bunching, CRTs and CLTs — what works now.
  Last modified: 2026-09-13T18:00:00.000Z

- Private Aircraft: Registration, Ownership, VAT and Operations
  URL: https://wiki.private.law/en/private-jet
  Summary: Map of private aircraft registries from M- to N-trust, temporary admission and EU import points, Cape Town and IDERA, economics by class, 2025–2026 regulatory trends and Q/A.
  Last modified: 2026-09-13T10:41:00.000Z

- Family Philanthropy: Foundations, DAFs and Cross-Border Giving
  URL: https://wiki.private.law/en/philanthropy-family-office
  Summary: How family charitable capital is structured: private, operating and conduit foundations, DAFs, supporting organisations and CRTs, Gift Aid, the 10% IHT threshold and cross-border giving.
  Last modified: 2026-09-14T20:21:00.000Z

- Fund LPA: Clawback, LPAC and GP Removal
  URL: https://wiki.private.law/en/lpa-mechanics
  Summary: How an LPA protects LPs: clawback and escrow, recycling limits, LPAC powers, for-cause and no-fault removal, key person events and ILPA standards.
  Last modified: 2026-09-11T15:23:00.000Z

- Family Office Economics: Budget, Team and Infrastructure
  URL: https://wiki.private.law/en/family-office-economics
  Summary: What an SFO costs in basis points, headcount and pay, what to outsource, and how consolidated reporting, the tech stack and the risk contour actually work.
  Last modified: 2026-09-06T08:06:00.000Z

- Russia to the UAE vs Russia to Singapore: The Tax Mechanics of Two Relocation Routes
  URL: https://wiki.private.law/en/russia-to-uae-vs-singapore
  Summary: Russia to the UAE vs Singapore in 2026: 0% vs 24% personal tax, the QFZP de minimis trap, Golden Visa vs Employment Pass, bank onboarding and CFC lock-in.
  Last modified: 2026-09-20T19:25:00.000Z

- Spanish Wealth Tax: IP and the Solidarity Tax ITSGF
  URL: https://wiki.private.law/en/spain-wealth-tax
  Summary: Spain's IP at 0.2–3.5% and the ITSGF up to 3.5%: the €700,000 allowance, the 2026 regional map, the foreign-structure trap, and the 60% cap for non-residents.
  Last modified: 2026-09-20T20:55:00.000Z

- Exiting Spain's Beckham Regime: Timing, Renuncia, Exit Tax
  URL: https://wiki.private.law/en/beckham-law-exit
  Summary: Six tax periods, renuncia in November–December and exclusión within a month: the tax cliff after the regime, and the exit-tax window under art. 95 bis.8 LIRPF.
  Last modified: 2026-09-12T21:29:00.000Z

- Modelo 720: Spain's Foreign Asset Declaration
  URL: https://wiki.private.law/en/modelo-720
  Summary: Spain's Modelo 720: the €50,000 threshold per asset block, the 1 January–31 March window, LGT arts 198–199 penalties after C-788/19, and Modelo 721 for crypto.
  Last modified: 2026-09-12T21:29:00.000Z

- Company in Kazakhstan for Non-Residents: LLP, Sole Trader and 2026 Taxes
  URL: https://wiki.private.law/en/kazakhstan-company
  Summary: Setting up an LLP in Kazakhstan as a non-resident in 2026: C5 visa, one-day eGov registration, 4% simplified regime, 20% CIT, 16% VAT, 15% dividend WHT.
  Last modified: 2026-09-12T04:38:00.000Z

- Taxes in Serbia
  URL: https://wiki.private.law/en/serbia-tax
  Summary: Serbia taxes 2026: 10% salary tax, 35% contributions, 15% dividends and capital gains, annual surtax 10-15%, pausal regime, 50% crypto relief, Russia treaty.
  Last modified: 2026-09-10T20:45:00.000Z

- Foreign Real Estate Purchase for Non-Residents: Rules, Taxes, Structures
  URL: https://wiki.private.law/en/foreign-real-estate-purchase
  Summary: London, Italy, France, Portugal, Spain, Singapore, Bulgaria, Austria, UAE, Greece, Cyprus: what non-residents need, entry tax from 2% to 60%, residency by purchase and ownership structuring.
  Last modified: 2026-09-20T20:57:00.000Z

- Spain: visas, Beckham Law and taxes — cluster map
  URL: https://wiki.private.law/en/spain-hub
  Summary: Spanish tax residency, the Beckham regime at 24% for six years, IP and ITSGF by region, Modelo 720, 2026 visa routes, property taxes and regional ISD rules.
  Last modified: 2026-09-20T20:22:00.000Z

- Securities Custody: Euroclear, Clearstream, Pershing
  URL: https://wiki.private.law/en/securities-custody
  Summary: How securities custody works: the custody chain, CSD and ICSD depositories (Euroclear, Clearstream), global custodians and Pershing, asset segregation and sanctions risk.
  Last modified: 2026-09-14T20:10:00.000Z

- Buying Property in Bulgaria as a Non-Resident: Apartments Without Land, EOOD, and Residence Permit for €307,000
  URL: https://wiki.private.law/en/bulgaria-property-purchase
  Summary: Apartments in Bulgaria are available to any nationality, land only through Bulgarian EOOD. Euro from 2026, Schengen from 2025, residence permit for purchases from 600,000 BGN.
  Last modified: 2026-09-13T09:17:00.000Z

- Buying Property in Austria as a Non-Resident: Grundverkehr, Regional Permits, and Vienna
  URL: https://wiki.private.law/en/austria-property-purchase
  Summary: For non-EU buyers, each Austrian state requires Grundverkehr approval: Vienna is feasible, Tyrol nearly closed. 3.5% GrESt, 2025 share-deal reform, 30% ImmoESt, zero inheritance tax.
  Last modified: 2026-09-20T21:11:00.000Z

- Buying Property in Spain as a Non-Resident: NIE, Regional ITP, and the End of Golden Visa
  URL: https://wiki.private.law/en/spain-property-purchase
  Summary: NIE requirements, military zones for non-EU buyers, ITP from 6% in Madrid to 13% in Catalonia, the fate of the "100% tax" and golden visa, ownership and sale taxes—a guide for non-residents.
  Last modified: 2026-09-13T10:58:00.000Z

- Buying Property in Portugal as a Non-Resident: NIF, 7.5% IMT and What's Left of the Golden Visa
  URL: https://wiki.private.law/en/portugal-property-purchase
  Summary: From 25 May 2026, Portugal charges a flat 7.5% IMT on non-residents. NIF and fiscal representative, CPCV and escritura, AIMI, golden visa fate and D7/D8 routes—explained.
  Last modified: 2026-09-13T10:40:00.000Z

- Buying Property in France as a Non-Resident: Notaire, SCI and IFI
  URL: https://wiki.private.law/en/france-property-purchase
  Summary: France imposes no restrictions on foreign buyers: transactions through notaire with costs ~7–8%, IFI on property over €1.3m, SCI for inheritance, réserve héréditaire and exit taxes.
  Last modified: 2026-09-20T21:11:00.000Z

- Pillar Two: Global Minimum Tax 15%
  URL: https://wiki.private.law/en/pillar-two
  Summary: How the OECD global minimum tax works: €750m threshold, QDMTT/IIR/UTPR, safe harbours, side-by-side for the US, and what it means for private structures.
  Last modified: 2026-09-14T19:13:00.000Z

- Purchasing London Property as a Non-Resident: SDLT, ROE and Inheritance Tax
  URL: https://wiki.private.law/en/london-property-purchase
  Summary: No restrictions for foreigners, but SDLT with 5% + 2% surcharges reaches ~17%, companies pay ATED and disclose in ROE, and UK property always faces 40% IHT. Transaction breakdown.
  Last modified: 2026-09-20T21:11:00.000Z

- Buying Property in Italy as a Non-Resident: reciprocità, codice fiscale, and Taxes
  URL: https://wiki.private.law/en/italy-property-purchase
  Summary: How non-residents buy property in Italy: reciprocità check (confirmed for Russian citizens), codice fiscale, 9% registration tax on cadastral value, IMU, rental, and inheritance.
  Last modified: 2026-09-20T21:11:00.000Z

- Intestate Succession in the UK: Intestacy, Freedom of Testation and Planning
  URL: https://wiki.private.law/en/uk-intestate-succession
  Summary: How estates are divided without a will in England and Wales: £322,000 statutory legacy for spouse, freedom of testation, the 1975 Act, 40% inheritance tax and residence-based regime from April 2025.
  Last modified: 2026-09-13T11:11:00.000Z

- Intestate Succession in Spain: legítima, foral law and planning
  URL: https://wiki.private.law/en/spain-intestate-succession
  Summary: Forced share in Spain: two-thirds to children under common law, usufruct to spouse, symbolic legítima in Catalonia and Navarre, choice of law under Brussels IV and regional inheritance tax ISD.
  Last modified: 2026-09-20T19:24:00.000Z

- Intestate Succession in Italy: legittima, patto di famiglia, and Planning
  URL: https://wiki.private.law/en/italy-intestate-succession
  Summary: Forced heirship (legittima) in Italy for spouses and children, patto di famiglia for business transfer, foreign trust recognition under Hague Convention, 4–8% inheritance tax.
  Last modified: 2026-09-20T19:24:00.000Z

- Intestate Succession in France: réserve héréditaire and Planning
  URL: https://wiki.private.law/en/france-intestate-succession
  Summary: Mandatory share for children in France (half, two-thirds, three-quarters), surviving spouse rights, Brussels IV choice of law, droit de prélèvement 2021, assurance-vie.
  Last modified: 2026-09-13T10:03:00.000Z

- Intestate Succession in the USA: Intestacy, Elective Share, and Planning
  URL: https://wiki.private.law/en/us-intestate-succession
  Summary: Inheritance without a will in the USA: probate and state formulas, no forced share for children, spousal elective share, federal estate tax ($15M / 40%) and the $60K trap for non-residents.
  Last modified: 2026-09-13T11:14:00.000Z

- EB-5: the Investor Green Card From $800,000
  URL: https://wiki.private.law/en/eb-5-investor-visa
  Summary: How EB-5 works after the 2022 reform: $800,000 into a TEA project or $1.05m, 10 jobs, regional centers, the queue-free rural set-aside, concurrent filing and the two real risks — project and tax.
  Last modified: 2026-09-20T20:22:00.000Z

- Residence by Investment: Golden Visa Program Map
  URL: https://wiki.private.law/en/golden-visas
  Summary: Active residence-by-investment programs: thresholds, formats (real estate, funds, business), what has closed and what replaces it. How to choose a program for the task.
  Last modified: 2026-09-20T21:04:00.000Z

- IP Box: Preferential Tax on Intellectual Property and the European Meta
  URL: https://wiki.private.law/en/ip-box
  Summary: How IP box regimes work: modified nexus under BEPS Action 5, effective rate map (Ireland KDB, Cyprus, Netherlands, Luxembourg), and regulatory passporting in the EEA.
  Last modified: 2026-09-20T20:57:00.000Z

- Russia: Relocation, Accounts, and Capital – What to Consider in 2026
  URL: https://wiki.private.law/en/russia-hub
  Summary: Russia hub for private capital: the 183-day test and 13–22% scale, currency reporting, CFC rules, suspended tax treaties, personal foundations, payment routes.
  Last modified: 2026-09-12T05:00:00.000Z

- France Titre Talent: One 4-Year Status for Experts, Founders and Investors
  URL: https://wiki.private.law/en/france-titre-talent
  Summary: The French titre talent after the 2024 reform: tracks for employees, French Tech founders, investors from €300k and researchers; family with work rights and the impatrié regime up to eight years.
  Last modified: 2026-09-20T21:07:00.000Z

- Inheritance in the UAE: Sharia defaults, DIFC Wills and ADJD
  URL: https://wiki.private.law/en/uae-inheritance-difc-wills
  Summary: What happens to UAE assets on death: frozen accounts, Sharia and Decree-Law 41/2022 defaults, DIFC Wills (AED 10,000) vs ADJD (AED 950), probate and guardianship of minors.
  Last modified: 2026-09-14T20:29:00.000Z

- UK Innovator Founder: the Founder Visa With No Minimum Capital
  URL: https://wiki.private.law/en/uk-innovator-founder
  Summary: The UK Innovator Founder visa: endorsement of an innovative business plan with no £50k minimum, checkpoint meetings, the 3-year ILR criteria and how the route compares with Global Talent.
  Last modified: 2026-09-14T18:50:00.000Z

- UK Global Talent: the British Talent Visa Without an Employer
  URL: https://wiki.private.law/en/uk-global-talent
  Summary: How the UK Global Talent visa works: endorsement by Tech Nation, Royal Society or Arts Council, or a listed prize; work freedom with no sponsor, ILR after 3 or 5 years and the 4-year FIG window.
  Last modified: 2026-09-03T19:29:00.000Z

- Crypto for Private Wealth: Custody, Tax, Structures
  URL: https://wiki.private.law/en/crypto-private-wealth
  Summary: How wealthy families hold crypto: multisig and MPC, qualified custodians, banking for crypto-origin funds, CARF exchanges from 2027, key succession.
  Last modified: 2026-09-20T21:07:00.000Z

- Tax Residency: 183-Day Rule, Centre of Vital Interests and Tax Treaties
  URL: https://wiki.private.law/en/tax-residency-basics
  Summary: Why 183 days don't guarantee status, how OECD Article 4 tie-breaker works, why the "nowhere resident" myth is dangerous, and how residency connects to CRS.
  Last modified: 2026-09-20T17:08:00.000Z

- Holding Structures: Netherlands, Luxembourg, Cyprus, Singapore, UAE
  URL: https://wiki.private.law/en/holding-structures
  Summary: Holding structures end to end: the investor→holdco→opco path, eight independent tax tests (residence, PE, beneficial ownership, PPT, CFC, TP, substance), NL vs Cyprus flow economics, Pillar Two.
  Last modified: 2026-09-20T13:38:00.000Z

- EB-1A: the Extraordinary-Ability Green Card Without an Employer
  URL: https://wiki.private.law/en/eb-1a-green-card
  Summary: EB-1A is the only green card needing no employer or investment: 3 of 10 criteria, the Kazarian two-step, 15-business-day premium processing, family included, India/China backlogs and the tax price.
  Last modified: 2026-09-03T19:37:00.000Z

- O-1A Visa: Extraordinary Ability as the US Entry Ticket
  URL: https://wiki.private.law/en/o-1-visa
  Summary: How the O-1A visa works: 3 of 8 extraordinary-ability criteria, an employer or US agent as petitioner, premium processing in 15 days, a 3-year status with unlimited extensions and the EB-1A path.
  Last modified: 2026-09-20T21:11:00.000Z

- CIM Banque: Swiss bank for international capital
  URL: https://wiki.private.law/en/cim-banque
  Summary: CIM Banque — a Geneva-based Swiss commercial and private hybrid offering multi-currency accounts. Remote onboarding and fit for cross-border capital.
  Last modified: 2026-09-16T14:51:00.000Z

- UK tax residence and worldwide taxation
  URL: https://wiki.private.law/en/uk-tax-residence-worldwide-taxation
  Summary: UK tax residence, the FIG regime, worldwide income, offshore companies, trusts and funds, the TRF, CRS data and leaving the UK — the post-6 April 2025 frame.
  Last modified: 2026-09-19T12:37:00.000Z

- Cross-Border Prenups: Notarial Contracts, Radmacher and Choice of Law
  URL: https://wiki.private.law/en/prenup-cross-border
  Summary: Marriage contracts for an international couple: notarial contracts in Germany, France and Switzerland, English prenups after Radmacher, US UPAA rules and choice of law under Regulation 2016/1103.
  Last modified: 2026-09-20T21:12:00.000Z

- Property Division in a Cross-Border Divorce: Regimes, Assets, Protection
  URL: https://wiki.private.law/en/divorce-property-division
  Summary: How property is divided in a cross-border divorce: five matrimonial regimes, real estate by situs, business valuation and buy-outs, crypto forensics, attacks on trusts and pension splitting.
  Last modified: 2026-09-14T18:48:00.000Z

- CFC (Controlled Foreign Company): Master Guide to Regimes and Residency Strategies
  URL: https://wiki.private.law/en/cfc-master-guide
  Summary: Comprehensive master guide to CFC (Controlled Foreign Company) rules: core regimes (Russia, US GILTI, UK TIOPA, EU ATAD) and mitigation strategies through tax residency planning.
  Last modified: 2026-09-20T20:59:00.000Z

- Solicitor — English Lawyer for Private Capital
  URL: https://wiki.private.law/en/solicitor
  Summary: Solicitor in the English tradition: reserved activities, legal professional privilege, client account, undertakings, trust practice, and recognition of status outside England.
  Last modified: 2026-09-16T15:25:00.000Z

- Remote Notarisation: Russia, England, USA – One Touch
  URL: https://wiki.private.law/en/remote-notary
  Summary: How remote notarisation works: Art. 44.3 and two-notary transactions in Russia, remote notarisation and e-Apostille in England, RON in the USA – and how Private.law makes it one touch.
  Last modified: 2026-09-16T15:21:00.000Z

- Harbin Bank — account for China corridor trade
  URL: https://wiki.private.law/en/harbin-bank
  Summary: Harbin Bank opens HK-company accounts for China corridor trade with multi-currency settlements, documented funds, eligibility and fees.
  Last modified: 2026-09-16T14:59:00.000Z

- Digital Nomad Visa for Spain: regime for remote workers
  URL: https://wiki.private.law/en/digital-nomad
  Summary: Spain Digital Nomad Visa for remote workers: eligibility, documents, 2026 SMI income test, Social Security, Beckham Law as a separate tax election and PE/CFC risks.
  Last modified: 2026-09-14T18:53:00.000Z

- Nasdaq Private Market: Company-Sponsored Liquidity
  URL: https://wiki.private.law/en/nasdaq-private-market
  Summary: Tender buybacks and company-sponsored liquidity programs: how NPM organizes transactions for employees and early investors in late-stage private companies.
  Last modified: 2026-09-16T15:19:00.000Z

- Forge Global: Private Share Trading, Custody and Market Data
  URL: https://wiki.private.law/en/forge-global
  Summary: Full-stack private equity secondary market—brokerage, custody, Forge Price data; the Charles Schwab acquisition and what it changes for accredited investors.
  Last modified: 2026-09-20T20:11:00.000Z

- Hiive: Order Book for Private Company Shares
  URL: https://wiki.private.law/en/hiive
  Summary: Order book for pre-IPO: direct matching of buyers and sellers of private company shares, transparent quotes, and investor access.
  Last modified: 2026-09-16T15:00:00.000Z

- Erste Bank Austria: personal account in a Viennese bank
  URL: https://wiki.private.law/en/erste-bank
  Summary: Erste Group — the largest banking group in Central and Eastern Europe: personal account, private banking access and EU residency angle for UHNW clients.
  Last modified: 2026-09-11T15:08:00.000Z

- Voluntary Disclosure and Capital Amnesties
  URL: https://wiki.private.law/en/voluntary-disclosure
  Summary: How voluntary disclosure works: willful vs. non-willful violations, US VDP and Streamlined procedures, the role of CRS and FATCA, penalty reduction and criminal risk mitigation.
  Last modified: 2026-09-20T20:55:00.000Z

- Stablecoins: Types and Regulation
  URL: https://wiki.private.law/en/stablecoins
  Summary: Stablecoin regimes in 2026: MiCA in the EU, the GENIUS Act in the US, HKMA licences in Hong Kong, final FCA rules, plus risks and tax for private holders.
  Last modified: 2026-09-20T16:53:00.000Z

- Panama Private Foundation (Law 25): Structure, Taxes, Succession
  URL: https://wiki.private.law/en/panama-foundation
  Summary: Panama Fundación de Interés Privado under Law 25 of 1995: founder, council, protector, beneficiaries in private regulations, $10,000 contribution, territorial tax, FATF and EU status.
  Last modified: 2026-09-14T20:40:00.000Z

- Holding Company in Switzerland: Rates, Participation Relief, Pillar Two
  URL: https://wiki.private.law/en/company-switzerland
  Summary: Swiss holding company: cantonal rates 12–15%, participation relief, TRAF 2020 reform, global minimum tax Pillar Two (QDMTT/IIR), and substance requirements.
  Last modified: 2026-09-20T20:19:00.000Z

- Liechtenstein Foundation (Stiftung): Family Foundation and 12.5% Tax
  URL: https://wiki.private.law/en/liechtenstein-foundation
  Summary: Liechtenstein Stiftung under PGR (Art. 552): family foundation without members, privacy through deposit, beneficiary types, 12.5% tax and PVS status, Pillar Two impact.
  Last modified: 2026-09-11T15:30:00.000Z

- Multi-Currency Management and FX Hedging of Capital
  URL: https://wiki.private.law/en/multicurrency-fx
  Summary: Managing capital currencies: choosing a base currency, currency risk, natural hedging, forwards and options, FX market context and typical costs.
  Last modified: 2026-08-31T12:59:00.000Z

- GAAR and Principal Purpose Test: Tax Anti-Abuse Rules
  URL: https://wiki.private.law/en/gaar-ppt
  Summary: How GAAR and principal purpose test work after BEPS: ATAD Art.6, MLI Action 6, substance over form principle and real substance requirements.
  Last modified: 2026-09-14T20:48:00.000Z

- Swiss lump-sum taxation: expenditure basis, control calculation and permit limits
  URL: https://wiki.private.law/en/switzerland-flat-tax
  Summary: Swiss expenditure-based taxation: how the lump-sum regime is calculated, control thresholds and permit limits for wealthy foreigners relocating private capital.
  Last modified: 2026-09-20T19:25:00.000Z

- Purpose Trust: Cayman STAR and the Enforcer Role
  URL: https://wiki.private.law/en/purpose-trust
  Summary: Cayman STAR trust (1997 law): purpose trust without human beneficiaries, enforcer role, perpetual duration, orphan ownership of PTC, and BVI VISTA analogue.
  Last modified: 2026-09-13T10:45:00.000Z

- Jersey and Guernsey Trusts: Reserved Powers and Firewall
  URL: https://wiki.private.law/en/jersey-guernsey-trust
  Summary: Channel Islands trusts: Trusts (Jersey) Law 1984 and Guernsey 2007, settlor's reserved powers, firewall protection from forced heirship and creditors, tax neutrality.
  Last modified: 2026-09-04T09:54:00.000Z

- Structured Products and Notes: How They Work and What the Risks Are
  URL: https://wiki.private.law/en/structured-products
  Summary: How structured products and notes work: capital protection, autocall and reverse convertible, issuer credit risk, liquidity and PRIIPs KID / MiFID II regime.
  Last modified: 2026-09-14T20:34:00.000Z

- Crypto Taxation by Country
  URL: https://wiki.private.law/en/crypto-tax-by-country
  Summary: Four patterns of crypto taxation across 16 jurisdictions: zero capital gains, holding-period exemption, a dedicated low rate, full taxation. Wealth tax, exit tax, CARF waves.
  Last modified: 2026-09-20T20:11:00.000Z

- Delaware LP for Funds: GP/LP, Carry, and Blocker Structures
  URL: https://wiki.private.law/en/delaware-lp-fund
  Summary: Fund structured as Delaware limited partnership: GP and LP roles, pass-through taxation and Schedule K-1, carried interest and §1061 rule, blocker corporations for foreign and tax-exempt investors.
  Last modified: 2026-09-13T09:54:00.000Z

- Luxembourg Funds: UCITS, SIF and RAIF
  URL: https://wiki.private.law/en/luxembourg-sif-raif
  Summary: Funds in Luxembourg: retail UCITS and alternative SIF/RAIF — structures, subscription tax (taxe d'abonnement), AIFM and the EU passport, CSSF supervision.
  Last modified: 2026-09-20T20:58:00.000Z

- International Brokerage Account: IBKR and Alternatives
  URL: https://wiki.private.law/en/international-brokerage
  Summary: International brokerage accounts (IBKR and alternatives): access to global markets, multi-currency functionality, margin, SIPC and FSCS protection, CRS/FATCA reporting, and tax considerations.
  Last modified: 2026-09-20T20:17:00.000Z

- Split-year treatment: tax year of relocation to the UK
  URL: https://wiki.private.law/en/split-year-treatment
  Summary: How UK split-year treatment divides the tax year of relocation into UK and overseas parts: eight SRT cases, automatic application, and common pitfalls.
  Last modified: 2026-09-02T10:00:00.000Z

- Holding Ladder and Dividend Flows
  URL: https://wiki.private.law/en/holding-dividend-flows
  Summary: How dividends climb the holding ladder: withholding tax, Parent-Subsidiary and Interest & Royalties Directives, beneficial ownership, PPT, and CJEU Danish cases.
  Last modified: 2026-09-20T16:51:00.000Z

- Cayman Fund: Exempted Company, ELP and SPC under CIMA Supervision
  URL: https://wiki.private.law/en/cayman-fund
  Summary: Cayman investment funds: Mutual Funds Act and Private Funds Act, exempted company, ELP and SPC structures, tax neutrality, economic substance and EU/FATF status.
  Last modified: 2026-09-14T19:02:00.000Z

- UK LLP for International Partnerships
  URL: https://wiki.private.law/en/uk-llp
  Summary: Limited Liability Partnership in the UK: limited liability, tax transparency, salaried member rules, and application for international partnerships and funds.
  Last modified: 2026-09-11T15:25:00.000Z

- Tie-breaker: Dual Tax Residency and Its Resolution
  URL: https://wiki.private.law/en/tax-residency-tiebreaker
  Summary: How dual tax residency is resolved: tie-breaker sequence under OECD Model Convention Article 4—permanent home, centre of vital interests, habitual abode, nationality, MAP.
  Last modified: 2026-09-14T21:21:00.000Z

- MiCA: EU Single Regime for Crypto-Assets
  URL: https://wiki.private.law/en/mica-eu
  Summary: How MiCA works: ART and EMT token categories, CASP license and passporting, rollout stages and transitional period until 1 July 2026.
  Last modified: 2026-09-14T20:44:00.000Z

- Malta Holding: 6/7 Refund System and Effective 5% Rate
  URL: https://wiki.private.law/en/company-malta
  Summary: How Malta's full imputation system and 6/7 tax refund work, participation exemption for holdings, substance requirements, and the impact of Pillar Two.
  Last modified: 2026-09-13T09:46:00.000Z

- Bermuda: Residence and Zero Taxes
  URL: https://wiki.private.law/en/bermuda-residence
  Summary: Bermuda residence through Economic Investment Residential Certificate: investment from $2.5 million, 90 days per year, and a regime with no income, inheritance, or wealth tax.
  Last modified: 2026-09-02T09:41:00.000Z

- Channel Islands and Isle of Man: Residence and Tax Caps
  URL: https://wiki.private.law/en/channel-islands-residence
  Summary: Jersey, Guernsey and Isle of Man for high-net-worth residents: 20% income tax, tax caps, high value residency regime, and no capital gains or inheritance tax.
  Last modified: 2026-09-14T12:05:00.000Z

- Liechtenstein: Residence and Taxes
  URL: https://wiki.private.law/en/liechtenstein-residence
  Summary: How Liechtenstein residence works: quotas and lottery for residence permits, income and wealth tax, lump-sum regime for ultra-high-net-worth individuals, and no capital gains tax.
  Last modified: 2026-09-20T20:54:00.000Z

- Andorra: Tax System and Residency
  URL: https://wiki.private.law/en/andorra-tax
  Summary: Andorra's tax system: income tax up to 10%, VAT 4.5%, no wealth or inheritance tax, passive residency conditions, and CRS compliance explained.
  Last modified: 2026-09-20T16:58:00.000Z

- Monaco: Tax Regime for Residents
  URL: https://wiki.private.law/en/monaco-tax
  Summary: How Monaco's tax regime works: zero personal income tax, French citizens exception under the 1963 convention, inheritance tax, and residency requirements.
  Last modified: 2026-09-14T20:41:00.000Z

- EU Citizenship Routes: Naturalization, Investment, Descent
  URL: https://wiki.private.law/en/eu-citizenship-routes
  Summary: Compare pathways to an EU passport: naturalization by residence period, investment visas, and descent. Germany's 2025 and Portugal's 2026 reforms.
  Last modified: 2026-09-20T19:26:00.000Z

- Renunciation of Citizenship and the Risk of Statelessness
  URL: https://wiki.private.law/en/renunciation-statelessness
  Summary: How citizenship renunciation works, why becoming stateless is prohibited, what a covered expatriate is, and the US exit tax when renouncing a US passport.
  Last modified: 2026-09-11T15:02:00.000Z

- Wyoming DAO LLC and DUNA: Legal Wrappers for Decentralized Organizations
  URL: https://wiki.private.law/en/wyoming-dao-llc
  Summary: Wyoming pioneered DAO legal status: DAO LLC since 2021 and Decentralized Unincorporated Nonprofit Association (DUNA) since July 2024—structure, taxes, and limitations.
  Last modified: 2026-09-11T15:25:00.000Z

- DAC6: Mandatory Disclosure of Cross-Border Arrangements in the EU and Hallmarks
  URL: https://wiki.private.law/en/dac6-hallmarks
  Summary: EU Directive 2018/822 (DAC6): who discloses cross-border tax arrangements and when, five categories of hallmarks, and the role of the main benefit test.
  Last modified: 2026-09-20T19:23:00.000Z

- Passport Index and Mobility: Henley, Arton and Nomad
  URL: https://wiki.private.law/en/passport-index
  Summary: How Henley, Arton and Nomad passport rankings work, what visa-free score shows, and why mobility is only part of a second passport's value.
  Last modified: 2026-09-11T15:35:00.000Z

- Real-World Asset Tokenization (RWA): Structure and Regulation
  URL: https://wiki.private.law/en/tokenization-rwa
  Summary: What legal right an RWA token contains: five models from direct statutory rights (TVTG, Swiss DLT Act) to SPV shares (BUIDL), issuer claims (xStocks), beneficial interests (PAXG) and synthetic exposure — with a rights matrix and failure scenarios.
  Last modified: 2026-09-14T20:10:00.000Z

- Precious Metals Vaults and Freeports: Allocated Storage, LBMA, and Free Ports
  URL: https://wiki.private.law/en/precious-metals-vaults
  Summary: How to store precious metals: allocated vs unallocated storage, LBMA Good Delivery standard, freeport storage in Switzerland, Singapore, and Luxembourg, tax benefits and costs.
  Last modified: 2026-09-12T04:37:00.000Z

- Lombard Lending: Liquidity Against Portfolio Collateral
  URL: https://wiki.private.law/en/lombard-lending
  Summary: How lombard lending works: pledging portfolios without selling, loan-to-value (LTV) by asset class, floating rates, margin call risk, pledge versus title transfer and interest deductibility.
  Last modified: 2026-09-07T22:16:00.000Z

- Holding in Ireland: 12.5%, participation exemption and Pillar Two
  URL: https://wiki.private.law/en/company-ireland
  Summary: Ireland as a holding jurisdiction: 12.5% on trading profits, participation exemption for foreign dividends from 2025 and for capital gains, 75 tax treaties in force and Pillar Two rules.
  Last modified: 2026-09-13T09:46:00.000Z

- New Zealand Foreign Trusts: Foreign Income Taxation and IRD Registration
  URL: https://wiki.private.law/en/nz-foreign-trust
  Summary: How a New Zealand foreign trust works: resident trustee, foreign exemption trust, IRD registration, annual return, financial statements, CRS/FATCA and tax red flags.
  Last modified: 2026-09-13T10:32:00.000Z

- Private Trust Company (PTC): Family Trust Company and Control
  URL: https://wiki.private.law/en/ptc
  Summary: What is a PTC, why families create their own trust company, how shares are held by purpose trust, and exemption conditions in Singapore, Cayman Islands, and BVI.
  Last modified: 2026-09-16T15:20:00.000Z

- PPLI: Private Placement Life Insurance as a Portfolio Wrapper
  URL: https://wiki.private.law/en/ppli
  Summary: How PPLI works: tax treatment, §817(h) diversification test, investor control doctrine, qualified purchaser, jurisdictions (Luxembourg, Bermuda), and CRS transparency.
  Last modified: 2026-09-11T15:19:00.000Z

- Foreign Real Estate Succession
  URL: https://wiki.private.law/en/foreign-real-estate-succession
  Summary: Why foreign real estate is inherited under the law of the country where it is located (lex rei sitae), how this creates forced heirship and double taxation issues.
  Last modified: 2026-09-13T10:02:00.000Z

- Succession to Foreign Accounts and Brokerage Portfolios
  URL: https://wiki.private.law/en/foreign-accounts-succession
  Summary: How foreign bank accounts and brokerage portfolios are inherited: account freezing, bank requirements for heirs, US-situs for American stocks, and the role of designated beneficiaries.
  Last modified: 2026-09-14T20:40:00.000Z

- Family Charter: Values, Governance and Succession Planning
  URL: https://wiki.private.law/en/family-charter
  Summary: What is a family charter: a set of rules for ownership, management, and succession of family capital. Why it's needed, what it includes, and how it relates to legal documents.
  Last modified: 2026-09-13T09:56:00.000Z

- Business Succession: Transferring a Company to Heirs
  URL: https://wiki.private.law/en/business-succession
  Summary: How to transfer a family business to the next generation without collapse: separating ownership and management, shareholder agreements, foundation or holding at the top.
  Last modified: 2026-09-14T20:34:00.000Z

- Trusts and CFC Rules: When a Foreign Trust Is a Controlled Foreign Company
  URL: https://wiki.private.law/en/trust-taxation-russia-cfc
  Summary: When a foreign trust or foundation becomes a CFC for a Russian tax resident: controlling person, notifications, undistributed profits, PIT and distributions.
  Last modified: 2026-09-20T19:23:00.000Z

- Trustee and Protector
  URL: https://wiki.private.law/en/trustee-protector
  Summary: A role map for trustee and protector: fiduciary duties, protector powers, reserved powers, conflicts of control, and when a trust risks being treated as a sham.
  Last modified: 2026-09-14T20:01:00.000Z

- Types of Trusts: Discretionary, Fixed, Revocable, Life Interest
  URL: https://wiki.private.law/en/trust-types
  Summary: Discretionary, fixed, revocable and irrevocable, life interest and purpose trusts—how trust types differ and which to choose for inheritance, asset protection and charity.
  Last modified: 2026-09-14T11:57:00.000Z

- How a Trust Works: Settlor, Trustee, Beneficiary, Protector
  URL: https://wiki.private.law/en/trust-basics
  Summary: A trust basics map: settlor, trustee, beneficiaries, protector, legal and beneficial ownership, fiduciary duties, reserved powers and sham risk.
  Last modified: 2026-09-20T20:15:00.000Z

- Family Holding for Succession and Inheritance
  URL: https://wiki.private.law/en/family-holding-succession
  Summary: Why consolidate family assets into a holding company before inheritance: single control point, shares instead of scattered assets, and linking the holding with a foundation or trust.
  Last modified: 2026-09-13T09:56:00.000Z

- Life Insurance as a Succession Tool
  URL: https://wiki.private.law/en/life-insurance-succession
  Summary: Unit-linked policies from Luxembourg and Ireland as a capital wrapper: liquidity for inheritance tax, tax deferral, direct transfer to beneficiaries, and asset protection.
  Last modified: 2026-09-02T10:00:00.000Z

- US Estate Tax: The US-Situs Trap for Non-Residents
  URL: https://wiki.private.law/en/us-estate-tax
  Summary: Non-residents face only a $60,000 estate tax exemption on US-situs assets (US stocks, real estate), with rates up to 40%. How the trap works and treaty relief.
  Last modified: 2026-09-13T11:13:00.000Z

- Forced Heirship and Statutory Share: Who Inherits Despite the Will
  URL: https://wiki.private.law/en/forced-heirship
  Summary: Who inherits despite a will: statutory share in Russia (Art. 1149 Civil Code), réserve in France, legítima in Spain, Sharia in UAE—and testamentary freedom in common law.
  Last modified: 2026-09-20T19:24:00.000Z

- Personal and Hereditary Foundations in Russia: Structure and Taxation
  URL: https://wiki.private.law/en/russian-personal-fund
  Summary: Personal foundation (since 2022) and hereditary foundation under Art. 123.20-8 of the Civil Code: 15% profit tax benefit, beneficiary income tax, ₽100M threshold, business succession.
  Last modified: 2026-09-11T19:07:00.000Z

- Exit Tax: Tax on Departure When Changing Tax Residency
  URL: https://wiki.private.law/en/exit-taxes-overview
  Summary: Exit tax across eleven jurisdictions: trigger, residence test, threshold, rate, deferral and the tail after departure in Germany, France, Spain, the US and more.
  Last modified: 2026-09-20T21:02:00.000Z

- CRS: Automatic Exchange of Tax Information — How It Works
  URL: https://wiki.private.law/en/crs-overview
  Summary: How the Common Reporting Standard works: which accounts and data are exchanged between countries, how CRS differs from FATCA, and what CRS 2.0 and CARF change from 2026.
  Last modified: 2026-09-14T20:44:00.000Z

- Foreign residence or citizenship notification rules
  URL: https://wiki.private.law/en/mvd
  Summary: When citizens must notify domestic authorities after foreign residence or citizenship, with deadlines, consular filing and penalty risk.
  Last modified: 2026-09-16T15:17:00.000Z

- Luxembourg SOPARFI: Classic Holding with Participation Exemption
  URL: https://wiki.private.law/en/company-luxembourg
  Summary: How a Luxembourg SOPARFI holding works: dividend and capital gains exemption under Art. 166, combined rate of 23.87% from 2025, and requirements for stake and substance.
  Last modified: 2026-09-13T09:46:00.000Z

- Netherlands Holding Company (BV): Participation Exemption and Tax Treaty Network
  URL: https://wiki.private.law/en/company-netherlands
  Summary: Why Dutch BV remains a classic holding structure: dividend and capital gains exemption via participation exemption, corporate tax rates, and extensive tax treaty network.
  Last modified: 2026-09-03T15:54:00.000Z

- Portugal IFICI (NHR 2.0): New Tax Regime Replacing Non-Habitual Resident
  URL: https://wiki.private.law/en/portugal-ifici
  Summary: How IFICI works—the successor to NHR in Portugal: 20% on professional income, foreign income exemption, who qualifies, and how it differs from the old regime.
  Last modified: 2026-09-14T20:49:00.000Z

- US LLC (Wyoming and Delaware) for Non-Residents: Disregarded Entity, ECI and Form 5472
  URL: https://wiki.private.law/en/us-llc-non-resident
  Summary: When a US LLC pays no federal tax, what ECI and ETBUS mean, why Form 5472 is required with a $25,000 penalty, and how Wyoming differs from Delaware for non-residents.
  Last modified: 2026-09-12T04:53:00.000Z

- Cayman and Bahamas: Residence in Zero-Tax Jurisdictions
  URL: https://wiki.private.law/en/cayman-residence
  Summary: Residence by investment in the Cayman Islands and Bahamas: KYD and USD thresholds, zero income tax, and why a certificate from a zero-tax jurisdiction doesn't always sever prior residency.
  Last modified: 2026-09-20T21:04:00.000Z

- Family Office: SFO/MFO Structure, Jurisdictions, Governance and Succession
  URL: https://wiki.private.law/en/family-office
  Summary: How SFO differs from MFO, which jurisdictions family offices choose (Singapore 13O/13U and VCC, UAE, Switzerland), why family charter matters and succession planning.
  Last modified: 2026-09-20T20:56:00.000Z

- Succession Planning: Wills, Multi-Jurisdiction & Forced Heirship
  URL: https://wiki.private.law/en/succession-planning
  Summary: Cross-border succession planning: situs wills, trusts and foundations, choice of law under Regulation 650/2012, forced heirship, probate and estate taxes.
  Last modified: 2026-09-20T19:21:00.000Z

- Asset Protection Trusts: Cook Islands and Nevis
  URL: https://wiki.private.law/en/asset-protection-trusts
  Summary: How APTs work in Cook Islands (1984/1989) and Nevis (NIETO 1994): non-recognition of foreign judgments, beyond reasonable doubt standard, statutes of limitation, and fraudulent conveyance.
  Last modified: 2026-09-20T14:55:00.000Z

- Private Foundations (Foundations / Stiftung): Liechtenstein, Panama, Jersey
  URL: https://wiki.private.law/en/private-foundations
  Summary: What is a private foundation, how it differs from a trust, and how Liechtenstein Stiftung, Panama Private Interest Foundation, and Jersey Foundations work.
  Last modified: 2026-09-20T19:21:00.000Z

- Second Passport as an Asset: Passport Portfolio and Plan B
  URL: https://wiki.private.law/en/second-passport-plan-b
  Summary: Why build a citizenship portfolio: mobility via the Henley Passport Index, record capital migration, and why a second passport is insurance, not a tax trick.
  Last modified: 2026-09-20T20:59:00.000Z

- The Five Flags Theory: A Map of Global Private-Wealth Diversification
  URL: https://wiki.private.law/en/five-flags
  Summary: Citizenship, tax residency, assets, business and where you live across jurisdictions: how the Five Flags Theory works today — adjusted for CRS, FATCA and Pillar Two.
  Last modified: 2026-09-20T20:58:00.000Z

- Remittance basis after 6 April 2025
  URL: https://wiki.private.law/en/uk-remittance-basis-after-2025
  Summary: Legal guide to the abolition of the UK remittance basis, pre-6 April 2025 pools, TRF, mixed funds and transitional rules.
  Last modified: 2026-09-20T16:58:00.000Z

- Planning before UK residence
  URL: https://wiki.private.law/en/uk-planning-before-residence
  Summary: Legal guide to pre-arrival UK tax planning for FIG, OWR, foreign companies, offshore funds, trusts, IHT and residence evidence.
  Last modified: 2026-09-14T20:41:00.000Z

- UK Overseas Workday Relief (OWR): Tax Relief for New Residents
  URL: https://wiki.private.law/en/uk-overseas-workday-relief
  Summary: Legal guide to UK Overseas Workday Relief after 6 April 2025, foreign workdays, employment income, RSUs, bonuses and evidence.
  Last modified: 2026-09-13T11:11:00.000Z

- Offshore Funds and UK Tax
  URL: https://wiki.private.law/en/uk-offshore-funds
  Summary: Legal guide to UK reporting fund status, non-reporting funds, offshore income gains, foreign ETFs and investment portfolios.
  Last modified: 2026-09-08T04:45:00.000Z

- Leaving the UK: Tax on Departure
  URL: https://wiki.private.law/en/uk-leaving
  Summary: Legal guide to leaving UK tax residence, P85, SA109, split year, temporary non-residence, UK property and IHT tail risk.
  Last modified: 2026-09-14T20:46:00.000Z

- Foreign tax credit and treaties
  URL: https://wiki.private.law/en/uk-foreign-tax-credit-treaties
  Summary: Legal guide to UK foreign tax credit relief, double tax treaties, treaty residence, withholding tax and Self Assessment reporting.
  Last modified: 2026-09-13T11:11:00.000Z

- HMRC enquiries and cleanup
  URL: https://wiki.private.law/en/uk-hmrc-enquiries-cleanup
  Summary: Legal guide to HMRC offshore enquiries, CRS data, Worldwide Disclosure Facility, penalties, amended returns and evidence repair.
  Last modified: 2026-09-08T04:44:00.000Z

- UK Family Office Records and Tax Evidence
  URL: https://wiki.private.law/en/uk-family-office-records
  Summary: Legal guide to UK residence files, ownership maps, source-of-funds records, CRS self-certifications and evidence architecture.
  Last modified: 2026-09-16T17:22:00.000Z

- UK tax residence
  URL: https://wiki.private.law/en/uk-tax-residence
  Summary: Legal guide to the UK Statutory Residence Test, day counting, ties, split years, temporary non-residence and treaty residence.
  Last modified: 2026-09-20T19:21:00.000Z

- UK Tax on Worldwide Income and Gains
  URL: https://wiki.private.law/en/uk-worldwide-income-gains
  Summary: Legal guide to UK taxation of foreign income, gains, cryptoassets, Self Assessment, SA106, SA108 and SA109.
  Last modified: 2026-09-20T14:56:00.000Z

- UK Tax Information Exchange: CRS, FATCA and HMRC Data
  URL: https://wiki.private.law/en/uk-crs-fatca-hmrc-data
  Summary: Legal guide to CRS, FATCA-style reporting, HMRC offshore data, Self Assessment consistency and family office evidence.
  Last modified: 2026-09-16T17:22:00.000Z

- Greece: non-dom €100k and benefits for pensioners and workers
  URL: https://wiki.private.law/en/greece-non-dom
  Summary: Greek non-dom (Art. 5A): €100k/year on foreign income, 15 years, €500k investment; 7% for pensioners (5B); 50% relief for relocating workers (5C).
  Last modified: 2026-09-14T20:42:00.000Z

- Thailand: Foreign Income Tax (2024) and LTR/DTV Visas
  URL: https://wiki.private.law/en/thailand-foreign-income-tax
  Summary: Thailand taxes remitted foreign income from 2024 (Por 161/162); proposed 2026 exemption; LTR visas (10 years, tax relief) and DTV visas (5 years) for remote workers.
  Last modified: 2026-09-02T10:02:00.000Z

- Georgia: Territorial Tax, HNWI Status and 1% for Sole Proprietors
  URL: https://wiki.private.law/en/georgia-territorial-tax
  Summary: Georgia does not tax foreign-source income of individuals (territorial principle); residency via 183 days or HNWI status; 1% tax for sole proprietors; residence permits.
  Last modified: 2026-09-13T10:04:00.000Z

- Italy: Flat Tax for New Residents (€300k from 2026)
  URL: https://wiki.private.law/en/italy-flat-tax
  Summary: Italy's neo-residenti regime (Art. 24-bis TUIR): fixed tax on foreign income €100k→€200k→€300k from 2026, 15 years, 9/10 year condition, investor and elective visa options.
  Last modified: 2026-09-14T20:43:00.000Z

- Cyprus: Non-Dom and the 60-Day Rule
  URL: https://wiki.private.law/en/cyprus-non-dom
  Summary: Cyprus non-dom status: 0% tax on dividends and interest for up to 17 years (SDC exemption), 60-day tax residency rule, GeSY contribution, residence permits and permanent residency.
  Last modified: 2026-09-14T21:17:00.000Z

- UK FIG Regime: Foreign Income and Gains
  URL: https://wiki.private.law/en/uk-fig-regime
  Summary: The UK Foreign Income and Gains (FIG) regime from 6 April 2025: relief from UK tax on foreign income and gains for the first 4 years of residence; 10-year non-residence condition; replaced remittance.
  Last modified: 2026-09-20T20:20:00.000Z

- Turkey: 20 Years Tax-Free on Foreign Income for New Residents
  URL: https://wiki.private.law/en/turkey-tax-holiday
  Summary: Turkey's new non-dom regime: 20 years tax-free on foreign income for new residents, 3-year non-residency requirement, 1% inheritance tax, and compliance risks.
  Last modified: 2026-09-06T08:01:00.000Z

- Turkish Asset Amnesty 2026: How Varlık Barışı Works
  URL: https://wiki.private.law/en/turkey-asset-amnesty-2026
  Summary: Varlık Barışı 2026: which foreign and undeclared assets can be declared by July 31, 2027, rates 0-5%, deadlines and AML risks under Turkish law № 7582.
  Last modified: 2026-09-02T18:47:00.000Z

- Turkey Residence Permit and Citizenship 2026: How to Become a Resident
  URL: https://wiki.private.law/en/turkey-residence-permit
  Summary: Turkish residence permit (ikamet) types, property-based residence from USD 200,000, digital nomad visa, citizenship from USD 400,000, and how immigration status relates to tax residency.
  Last modified: 2026-09-02T18:47:00.000Z

- Greece Golden Visa: €250k–800k Tiered Thresholds and Path to EU Residency
  URL: https://wiki.private.law/en/greece-golden-visa
  Summary: Greece Golden Visa offers EU residency by investment: €250k–800k tiered thresholds, 5-year renewable permit, Schengen mobility, and path to Greek citizenship.
  Last modified: 2026-09-20T21:05:00.000Z

- Portugal Golden Visa: Investment Funds, Residence and Citizenship
  URL: https://wiki.private.law/en/portugal-golden-visa
  Summary: Portugal Golden Visa (ARI): residency through €500k fund investment, IFICI tax regime and path to citizenship (10 years from 19 May 2026, 7 for EU/CPLP). Conditions for private capital.
  Last modified: 2026-09-20T20:13:00.000Z

- CFC in the United Kingdom: TIOPA 2010 Part 9A, TOAA and the FIG Regime
  URL: https://wiki.private.law/en/uk-cfc
  Summary: British CFC rules: TIOPA 2010 Part 9A, gateway tests, charge calculation and interaction with Transfer of Assets Abroad and the FIG regime.
  Last modified: 2026-09-14T20:48:00.000Z

- UAE Tax Residency: Cabinet Decision 85/2022, Golden Visa and 0% Personal Income Tax
  URL: https://wiki.private.law/en/uae-tax-residency
  Summary: UAE tax residency (Cabinet Decision 85/2022): 183/90-day tests, 0% personal income tax, Golden Visa, TRC, DMTT 15% for large groups from 2025.
  Last modified: 2026-09-20T20:13:00.000Z

- EU ATAD I CFC: Articles 7-8 and Member State Implementation
  URL: https://wiki.private.law/en/eu-atad-cfc
  Summary: CFC rules under EU ATAD I (Articles 7–8): two approaches to income attribution and implementation across EU Member States for holding structures.
  Last modified: 2026-09-17T11:23:00.000Z

- Source of Funds and Source of Wealth: Documents and Compliance for Banks
  URL: https://wiki.private.law/en/source-of-funds
  Summary: Source of Funds vs Source of Wealth in bank onboarding and EDD: documents private clients need for large transactions and compliance.
  Last modified: 2026-09-07T08:29:00.000Z

- Spain Entry Declaration
  URL: https://wiki.private.law/en/spain-entry-declaration
  Summary: Declaración de entrada is an entry declaration for arrivals to Spain from Schengen without a border stamp. When required, deadlines, and what matters for residents.
  Last modified: 2026-09-13T10:57:00.000Z

- Swiss residence, lump-sum taxation and business admission: legal boundary
  URL: https://wiki.private.law/en/switzerland-residence-permit
  Summary: Switzerland has no federal golden visa: residence rests on lump-sum taxation and business admission, not a property buy. Where the legal boundary sits for UHNW.
  Last modified: 2026-09-20T20:53:00.000Z

- Malta GRP: special tax status, residence card and remittance basis
  URL: https://wiki.private.law/en/global-residence-program
  Summary: Malta's Global Residence Programme: special tax status, residence card and the remittance basis of taxation. Who qualifies and fit for UHNW relocation.
  Last modified: 2026-09-14T21:15:00.000Z

- Gibraltar Category 2 and HEPSS: tax certificates, residence and substance
  URL: https://wiki.private.law/en/gibraltar-residence-permit
  Summary: Gibraltar Category 2 and HEPSS tax certificates explained: residence, substance and capped tax for HNW — and why this is not a residence-by-investment programme.
  Last modified: 2026-09-13T10:04:00.000Z

- Strategy: Beckham Law + Hong Kong
  URL: https://wiki.private.law/en/beckham-hong-kong
  Summary: Tax planning strategy combining Spanish Beckham Law residency with a Hong Kong company: offshore income, PE risks, dividends, expenses, and compliance controls.
  Last modified: 2026-09-20T20:55:00.000Z

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