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Wealth Structuring & Cross-Border Strategy

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 legal and tax architectures that allow private and corporate wealth to operate globally while remaining transparent, protected, and efficient.

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Our focus is on sustainability: structures that perform under scrutiny, endure regulatory change, and align with the client’s long-term objectives — whether succession, liquidity, or relocation.

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.

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Scope of work includes:

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  • Holding and fund vehicles: UK LP, Luxembourg SCA/SICAV, Malta GP/LP, Liechtenstein trusts.

  • Treaty-based optimization and participation exemption planning.

  • Structuring for entrepreneurs, family offices, and digital asset holders.

  • Consolidation of multi-jurisdictional corporate ownership chains.

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Example: Re-domiciling a Cyprus holding company into Luxembourg to access EU directives and reduce withholding tax from 10 % to 0 % on intra-group dividends.

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.

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Key competencies:

  • Multi-jurisdictional CIT and withholding tax mapping.

  • Application of double-tax treaties and OECD tie-breaker rules.

  • Controlled Foreign Company (CFC) and exit-tax mitigation.

  • EU Substance and economic presence compliance.

 

Our advantage: We combine private-client thinking with fund-structuring precision — rare in the European advisory landscape.

3. Succession & Asset Protection

The structure must outlive its founder.
We design governance frameworks ensuring inter-generational control, privacy, and resilience to political or market shocks.

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Advisory areas:

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  • Private trusts and foundations (Liechtenstein, Malta, Luxembourg).

  • Family holding companies with tiered share classes.

  • Cross-border inheritance planning under civil-law regimes.

  • 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.

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We establish and manage:

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  • Fund platforms (UK LP, Lux RAIF, Malta NAIF).

  • SPV networks for real estate or venture participations.

  • Management entities and carry structures for fund principals.

  • 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 0 % CIT on retained profits and full institutional banking access.

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:

  • Relocate capital into EU banks with full AML clearance,

  • Obtain residency permits for all family members within 90 days,

  • Optimise taxation under Italy’s 100 000 € flat regime and Malta’s participation exemption.

 

The result: a compliant European presence, secure banking, and a 70 % reduction in effective global tax burden.

Why Noira Advisory

  • Cross-disciplinary approach: We merge immigration law, tax planning, and corporate structuring into one integrated advisory process.

  • Trusted network: Collaboration with Tier-1 law firms, private banks, and fiduciaries across the EU, UK, and Switzerland.

  • Absolute discretion: We operate under private-office confidentiality, serving individuals and families with complex cross-border profiles.

Begin Your Transition

Whether driven by opportunity, regulation, or lifestyle, your relocation deserves more than a visa — it requires a strategy.
Our team designs bespoke residency frameworks that protect your wealth, enable freedom, and ensure compliance at every step.

Book Private Advisory Session

We are committed to excellence and have a deep understanding of the law. Our aim is to provide you with real world solutions.

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