Cross-Border Structuring for Private Capital
Preserving capital, creating control, and ensuring compliance across jurisdictions.
Our Philosophy
Wealth structuring is not an exercise in avoidance — it is the discipline of control.
At Noira Advisory, we design and coordinate cross-border legal and tax architectures for private capital operating across multiple jurisdictions.
This service is designed for entrepreneurs, family offices, and investment principals with active cross-border exposure.
1. Strategic Architecture Design
Each client begins with a detailed audit of their current capital structure: shareholdings, trusts, corporate entities, and personal residency status.
We then create a jurisdictional blueprint balancing tax exposure, reporting obligations, and asset protection.
Scope of work includes:
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Holding and fund vehicles across the UK, Luxembourg, Malta, and Liechtenstein (LPs, funds, and fiduciary structures).
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Treaty-based optimization and participation exemption planning.
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Structuring for entrepreneurs, family offices, and digital asset holders.
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Consolidation of multi-jurisdictional corporate ownership chains.
Example: Re-domiciling a Cyprus holding company into Luxembourg to eliminate intra-group withholding tax under EU directives.
2. Cross-Border Tax Planning
True efficiency is achieved not by minimising tax in one country, but by optimising the entire chain of value creation.
We coordinate with tax specialists in key jurisdictions to ensure full alignment between personal, corporate, and investment structures.
Key competencies:
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Multi-jurisdictional CIT and withholding tax mapping.
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Application of double-tax treaties and OECD tie-breaker rules.
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Controlled Foreign Company (CFC) and exit-tax mitigation.
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EU Substance and economic presence compliance.
Our advantage: We combine private-client thinking with fund-structuring precision — rare in the European advisory landscape.
All tax planning is conducted within applicable domestic law, treaty frameworks, and OECD standards.
3. Succession & Asset Protection
The structure must outlive its founder.
We design governance and succession frameworks that ensure inter-generational control, privacy, and resilience to regulatory and market shocks
Advisory areas:
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Private trusts and foundations (Liechtenstein, Malta, Luxembourg).
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Family holding companies with tiered share classes.
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Cross-border inheritance planning under civil-law regimes.
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Integration with residency and citizenship planning for heirs.
4. Corporate & Investment Structures
For clients active in trading, technology, or investment management, Noira Advisory provides end-to-end coordination between regulatory, banking, and operational layers.
We establish and manage:
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Fund platforms (UK LP, Lux RAIF, Malta NAIF).
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SPV networks for real estate or venture participations.
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Management entities and carry structures for fund principals.
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White-label digital infrastructure for crypto and tokenized assets.
Case highlight: A $25 million digital-asset fund re-structured under a UK LP with Estonian operational entity, achieving tax-neutral profit retention and full institutional banking access.
This layer applies to clients with active investment or asset management operations.
Case Example
A family from Eastern Europe held real-estate and investment assets in multiple jurisdictions but lacked EU access and faced growing compliance risk.
Noira Advisory developed a dual-residency strategy between Italy and Malta, enabling the family to:
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Relocate capital into EU banks with full AML clearance,
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Obtain residency permits for all family members within 90 days,
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Optimise taxation under Italy’s 100 000 € flat regime and Malta’s participation exemption.
Result: a compliant EU presence, consolidated banking access, and a materially improved global tax position.
Engagement Model
We act as lead advisor and coordinator, working alongside local legal counsel, tax advisors, and banks. Noira Advisory does not provide legal representation or audit services.
Submit a Mandate Inquiry
Noira engages exclusively on a mandate basis.
Submissions are reviewed internally.
Advisory access is granted selectively.