Residency, Tax & Mobility Structuring
Strategic relocation, compliant integration, and fiscal clarity for global citizens.
Our Philosophy
At Noira Advisory, residency is not a change of address — it is a deliberate legal and fiscal repositioning within a secure, compliant framework.
We operate at the intersection of tax law, immigration, and wealth structuring, ensuring that each jurisdictional move strengthens regulatory clarity, fiscal control, and long-term mobility.
Our process combines private-client precision with institutional discipline. Every residency strategy is built around three non-negotiable pillars: legal compliance, tax efficiency, and strategic mobility.
1. Strategic Relocation Planning
Relocation begins long before any application is filed.
We analyse the client’s global footprint — assets, income flows, family structure, and existing tax exposure — to determine an optimal jurisdictional configuration.
Scope of work includes:
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Multi-jurisdictional tax assessment and pre-migration strategy
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Asset location review and pre-migration alignment
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Integration of corporate and personal structures under new residency
2. Residency Program Advisory
We advise on residency programmes across selected European jurisdictions where legal stability, tax integrity, and long-term defensibility are demonstrable.
Programmes are selected based on regulatory substance and sustainability — not speed, marketing appeal, or short-term incentives.
Core jurisdictions advised:
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Italy — Elective Residency & Lump-Sum Tax Regime
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Malta — Permanent Residency Programme (MPRP), Global Residence Programme (GRP)
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Switzerland — Lump-Sum Tax (Forfait Fiscal)
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United Kingdom — Business and returning-resident structuring
Our process:
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Preparation of financial and source-of-wealth documentation
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Liaison with immigration counsel and tax authorities
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Coordination of local counsel, fiduciaries, and required asset anchoring
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Integration with banking and reporting obligations
3. Tax Residency Structuring & Ongoing Compliance
Achieving residency is only the starting point.
The critical challenge lies in maintaining defensible tax residency while avoiding double taxation and preserving treaty protection.
We coordinate annual reviews with legal and tax partners in multiple jurisdictions to ensure continuous compliance and transparency.
Our expertise covers:
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Tax domicile determination and tie-breaker analysis under OECD standards
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Application of double-taxation treaties (DTT) and exit tax mitigation
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Cross-border income and capital-gain planning for corporate principals
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Banking, CRS and FATCA alignment
4. Integration with Wealth and Corporate Structures
Residency planning is effective only when synchronized with the client’s wider capital architecture.
Our team integrates residency solutions with existing trusts, holding companies, and funds — ensuring operational coherence and preventing structural inefficiencies and unintended tax exposure.
Typical integrations:
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Alignment of corporate ownership with new residency
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Succession and inheritance planning under civil-law systems
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Migration of fund management entities to EU or Swiss frameworks
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.
The result: a compliant European operating base, secure EU banking access, and a materially reduced effective global tax burden — achieved within a fully transparent and defensible framework.
Submit a Mandate Inquiry
Noira engages exclusively on a mandate basis.
Submissions are reviewed internally.
Advisory access is granted selectively.