Developing a tax strategy to minimise risk and protect assets
A Ukrainian citizen who was a tax resident of Ireland planned to move to Portugal to obtain NHR status in 2025. There were risks of double taxation between Ukraine and the country of residence, of retaining Ukrainian tax residency, and of the consequences of automatic exchange of information (CRS). The client was looking for a jurisdiction for a holding company or trust to protect assets and minimise tax.
We developed a tax strategy that included:
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Confirming NHR status in Portugal.
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Ending tax residency in Ireland after the move.
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Setting up a holding company in Cyprus (0% tax on dividends, support for interim dividends, compatibility with NHR).
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Managing time spent in Romania and other countries to avoid unwanted tax residency.
Alternatives (Malta, Andorra, Luxembourg) were considered but found less suitable.
The client received a strategy that eliminates double taxation, minimises CRS risk and provides legal income structuring through a Cyprus holding company with an optimised tax burden.
The challenge
The solution
The result
