Since the introduction of the Common Reporting Standard in 2017, the location of your tax residency — not the location of your assets — determines who sees your financial life. We help you choose that location deliberately.
Under CRS, more than 120 jurisdictions automatically exchange financial account information based on the tax residency you declare to your bank. For many high-net-worth families, this means a private account in Switzerland, Singapore or Dubai is reported in full to a tax authority they may have long since outgrown — often one with rising rates, exchange controls or political instability.
A second residence permit or citizenship gives you the legal right to declare a different tax residency. When properly structured — with genuine ties, valid documentation and appropriate physical presence — your future CRS reports flow to a jurisdiction you have chosen for its tax treatment, its discretion and its rule of law.
This is not avoidance. It is the lawful exercise of mobility rights that every multi-jurisdictional family is entitled to use.
A new permanent residence permit allows you to update the tax residency on file with every bank, broker and financial institution you use. Once your declared tax residency changes, your account information is reported to your new jurisdiction under CRS — not your country of origin.
We help clients open private banking relationships in jurisdictions that recognise their new residence or citizenship. The result: financial accounts that report to a tax-friendly home, fully within the CRS framework, with no irregular structures required.
Holding a second citizenship gives you the legal right to bank, hold assets and conduct business under that nationality. Many sovereign banks now accept account opening under your alternative identity documents, removing forced linkage to your birth country.
Several of the jurisdictions we advise on — Cyprus, Malta, Hong Kong, Paraguay, Vanuatu — operate territorial or non-domicile tax regimes. Worldwide income, foreign dividends and offshore capital gains can fall entirely outside the local tax net.
Reopened in March 2024, the New Capital Investment Entrant Scheme allows qualifying applicants to acquire Hong Kong residence in exchange for a HKD 30 million portfolio deployed into eligible Hong Kong assets — plus a HKD 3 million contribution to a dedicated I&T portfolio.
For families seeking to lawfully reduce global tax exposure and redirect CRS reporting away from a high-tax origin, the CIES is arguably the single most efficient tool currently available in Asia. It pairs genuine residence in a major financial centre with one of the cleanest territorial tax systems in the world.
Explore the Hong Kong program →Hong Kong taxes only income with a Hong Kong source. Foreign salary, foreign business profit, foreign dividends, foreign interest and foreign capital gains are not taxable in Hong Kong — even after you become a resident. The CIES is therefore one of the few investment-migration routes in the world where a major financial centre also offers genuine territoriality.
Once you hold a Hong Kong residence permit and a Hong Kong tax identification number, your accounts at Hong Kong and overseas institutions can be re-papered with Hong Kong as your tax residency. From that point forward, CRS reports flow to Hong Kong's Inland Revenue Department rather than to your country of origin.
Hong Kong imposes no exit tax, no inheritance tax (abolished in 2006) and no wealth tax. Bringing a family under the CIES therefore creates no new layer of inheritance or gift exposure, and assets restructured into Hong Kong-recognised vehicles are not exposed to additional reporting under the regime.
The HKD 30 million qualifying portfolio can be deployed into Hong Kong listed equities, debt securities, eligible funds, qualifying insurance products and a capped allocation to non-residential real estate. The structure is therefore not a sunk cost — it is a working private-banking portfolio that contributes to qualification.
The goal is not to make assets disappear; the goal is to make sure the right authority — the one whose legal system you have chosen to live under — is the one that sees them. A second passport allows an account to be opened under a different identity document. A new residence permit allows that account to be tax-reported to a different jurisdiction. The combination dramatically narrows the audience for your private financial information.
Where the CIES is involved, the receiving jurisdiction is Hong Kong — a financial centre with bank secrecy traditions, a strict territorial regime, no inheritance tax and no exchange controls. For families exiting high-tax or politically uncertain home countries, this is often the difference between feeling exposed and feeling settled.
Every structure we recommend is compliant with the disclosure obligations of the jurisdictions involved. The line between privacy and evasion is the quality of the structuring, the genuineness of the ties created, and the discipline with which the new residency is maintained.
Caribbean or Pacific citizenship gives you an alternative identity document for account opening. Hong Kong residence under the CIES gives you a tax-friendly home for those accounts to report to. Used together, the two restructure both who you are to a bank, and which authority sees the report.
Pairing a territorial jurisdiction (Hong Kong, Paraguay, Vanuatu) for active income with a non-dom jurisdiction (Cyprus, Malta, Ireland) for passive and investment income creates a layered structure in which no single regime sees the full picture of the family balance sheet.
Several residence permits — notably Greece, Portugal, Cyprus and Hong Kong — can be maintained without becoming tax-resident. This decouples the right to be somewhere from the obligation to be taxed there, giving the family genuine optionality.
Every strategy we recommend is built on full legal compliance with the jurisdictions involved. The objective is not to conceal — it is to choose, deliberately and lawfully, which government has visibility over your private financial affairs. The difference between privacy and evasion is the quality of the structuring.
Our team will assess your existing residency footprint, your banking relationships and your reporting exposure before recommending any change. Every engagement is conducted under strict confidentiality.
Request a Confidential Tax Review