The Cyprus reform in force from 1 January 2026: 15% corporate tax, a personal scale with a EUR 22,000 nil band, SDC of 5% on dividends and 17% on interest, 8% on crypto-assets, and the transition for pre-2026 profits.
Who files the GIR and where, the 15- and 18-month deadlines, the common understanding on central filing, exchange under the GIR MCAA and DAC9, and penalties.
Who pays the section 2801 tax: a U.S. recipient determined by domicile, 40% above the annual exclusion, TD 10027 effective January 14, 2025, Form 708 for 2025 due June 15, 2027, the section 2801 ratio and the electing foreign trust.
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.
Three reporting circuits for crypto-assets: the CARF perimeter and commitment waves as at 23 June 2026, DAC8 and the first exchange by 30 September 2027, the amended CRS, Form 1099-DA, UK SI 2025/744 and Spanish Modelos 172, 173 and 721.
TRF designation after Finance Act 2026: rates by designation year, eligibility, the double designation requirement, mixed funds and correcting errors.
How Singapore sells certainty in advance: the s.108 IRAS advance ruling, GST rulings, stamp duty adjudication, APAs, MAS 13O/13U approvals and EDB awards — with the published ruling corpus and the limits set by s.33.
When a foreign company becomes taxable at source: how a permanent establishment is decided under domestic law and the tax treaty, fixed-place and agent PE, exceptions, and how profits are attributed.
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.
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.
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.
A map of the migration domain: three independent variables, the eight-step route model, seven entry types on shared axes, and a detailed guide to each branch.
Three independent layers of any Swiss decision: the canton and the lump-sum regime, the federal residence permit, the bank and its booking centre. A cluster map.
The UK after non-dom abolition: 4-year FIG regime, TRF to 2028, residence-based IHT after 10 of 20 years, SRT, banks from Coutts to fintechs, visa routes.
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.
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.
Two-tier 8.25%/16.5% against 17% with PTE, SUTE and the YA 2026 rebate: effective rates at six profit levels, FSIE both sides, Pillar Two threshold.
A map of the investor cluster: choosing the model of entry, the full price of a route, due diligence, the tax trail of a status, three regional maps and reform risk.
Jersey trust with an Italian-resident family: where to place the holding, how CFC rules (art. 167 TUIR) and trust interposition read the stack, and why effective management must stay out of Italy.
An esports player has no federation to endorse them: § 22 Nr. 5 BeschV with the ESBD, the French employer approval, no UK route, Article 17 against Articles 7 and 15.
Share deal or asset deal, SSE and §8b KStG, Sperrfrist and 150-0 B ter, BADR at 18% from 6 April 2026, earn-outs, W&I and what happens to the team's options.
Twelve jurisdictions from both sides: when the old residence breaks, what the exit costs, what trails behind and how the new one arises. Pair: country A's exit column plus country B's entry column.
Mutual agreement procedure under OECD Model Article 25, MLI Part VI arbitration, EU Directive 2017/1852 and Russian Chapter 20.3: deadlines, odds and pitfalls.
Hong Kong's CDTA network as at August 2026: 51 in force, 8 signed, 17 in negotiation. Withholding rates, Certificate of Resident Status in 21 working days, MLI reservations, CARF and Pillar Two.
Singapore CPF in 2026: 37% for those 55 and below, the S$8,000 OW ceiling, graduated PR rates, retirement sums, CPF LIFE, SRS and closing the account on exit.
Singapore GST in 2026: the 9% rate, the S$1m registration tests, reverse charge and OVR for holdings and funds, zero-rated against exempt, filing and penalties.
The UK earned settlement reform: a 10-year baseline, reductions at £50,270 and £125,140, talent routes, and the rules that actually apply in August 2026.
House v. NCAA: a $20.5m cap per school in 2025/26 and $21.3m in 2026/27, deal clearing from $600, self-employment tax and the F-1 deadlock for foreign athletes.
How the authorities rebuild a touring year: CRS, DAC7 and the PStTG, the Shakira ruling, BFH case law on § 8 AO, and the residence certificate procedure in Spain, Germany, the UAE and Andorra.
No income tax on salary, 15% VAT, Premium Residency at SAR 800,000 or 100,000 a year, RHQ at 0% for 30 years, and the temporary non-residence trap at home.