Every article in our library is written by a named HPT director, distilled from active client engagements. We publish on the topics our clients ask us about most often: structuring, banking, mobility, tax and regulatory change. Articles older than 24 months are marked accordingly.
583 articles — page 1 of 13. Use the filters above to browse by topic, or page through the whole archive below.
The UK non-dom reform 2025 abolished domicile-based taxation and moved to a residence test. Here is what actually changed and how to plan around it.
Trust vs foundation for succession: control, beneficiary rights, legal personality, tax neutrality and cross-border recognition, and which suits which family.
How split-year treatment works when leaving the UK mid-year, the cases that apply, and the pitfalls that cost departing residents their relief.
A practical 2026 guide to the UK statutory residence test: automatic overseas and UK tests, the sufficient ties test, day counting, and common traps.
How HMRC Connect and global data exchange let the UK tax authority track offshore assets, and what compliant taxpayers should understand about disclosure.
A practical guide to the remittance basis for non-domiciled UK residents: how it works, what counts as a remittance, costs, and the reforms reshaping it.
How UK inheritance tax now reaches offshore assets in 2025, the move to residence-based scope, excluded property, and planning for international families.
A clear guide to Business Asset Disposal Relief (BADR): who qualifies, the lifetime limit, the rising rate, and how founders should plan an exit.
How Germany's exit tax (Wegzugsteuer) taxes unrealised gains on company shares when you leave, who it catches, and how to plan a departure properly.
Does the UK have an exit tax on capital gains when you leave? We explain the temporary non-residence rule, what is taxed on departure, and timing of disposals.
France decides tax residency using four alternative tests under Article 4B. Understand how home, main stay, economic activity and centre of interests apply.
How to compare citizenship-by-investment programmes in 2026 on visa-free access, true all-in cost, family inclusion, due diligence and tax position.
How to obtain Andorra tax residency: the active and passive routes, presence and investment requirements, the low-tax regime, and the pitfalls to avoid.
How Scotland's Land and Buildings Transaction Tax applies to offshore and non-resident buyers, including the ADS surcharge, ownership structures and pitfalls.
Portugal's NHR regime closed to new entrants. Here is what replaced it, who the IFICI incentive suits in 2026, and how it compares for professionals.
How UK crypto tax works for individuals in 2026: capital gains versus income, disposals, DeFi and staking, record-keeping and HMRC's focus.
How Italy's flat tax regime for new residents works in 2026: the annual substitute charge on foreign income, who qualifies, and the key pitfalls.
How Italy's flat-tax regime for new residents works in 2026: the annual substitute tax on foreign income, eligibility, family extension and duration.
How the Greece flat tax regime works for non-domiciled investors, pensioners and professionals relocating to Greece, with eligibility, costs and pitfalls.
How Switzerland lump-sum taxation (forfait) works for wealthy foreigners: eligibility, how the base is calculated, cantonal differences and key pitfalls.
A decision framework for choosing between EMI, PSP, VASP and MSB licences: what each permits, capital and substance, jurisdictions, timelines and banking.
A clear guide to BEPS Pillar Two and the 15% global minimum tax: who is in scope, how the GloBE rules work, and what it means for offshore structures.
An honest look at the cheapest citizenship by investment routes in 2026 and what the lower-cost Caribbean programmes really cost once fees are added.
OECD Pillar One reallocates taxing rights over the largest multinationals to market jurisdictions. Here is what it means and who it affects.
Pillar Two compliance in its first year is a data and process challenge. Here is a practical guide to GloBE calculations, safe harbours, and filings.
FATCA for individuals means US persons must report foreign financial assets on Form 8938. Here is who is affected and how it differs from the FBAR.
FBAR reporting requirements catch many US persons with foreign accounts. Here is who must file FinCEN Form 114, what counts, and the penalties.
Transfer pricing essentials for multinationals: the arm's length principle, documentation, methods, and how to manage audit risk across borders.
Which routes deliver the fastest second passport in 2026, what really drives processing times, and how to set realistic expectations.
Transfer pricing basics for entrepreneurs: when the rules apply to your group, the arm's length principle, simple documentation, and pitfalls to avoid.
Permanent establishment risk from remote work: how home-based employees and roaming founders can create a taxable presence abroad, and how to manage it.
How founders should structure holding entities, residency, reliefs and trusts in the 12-24 months before a liquidity event, and the costly mistakes to avoid.
A complete guide to permanent establishment risk: the types of PE, treaty rules, profit attribution, common triggers, and how to manage exposure.
Tax treaty shopping is far harder after BEPS. We explain the principal purpose test, the limitation on benefits clause, and how to claim treaty relief.
Double taxation agreements decide which country taxes your income and at what rate. We explain how DTAs allocate taxing rights, relieve double tax and where.
A clear-eyed guide to St Kitts & Nevis citizenship by investment: routes, due diligence, passport strength and who the original CBI programme suits.
A tax residency certificate proves where you are taxed and unlocks treaty relief. We explain what it is, how to obtain one, and the pitfalls that get claims.
Economic substance requirements determine whether your offshore entity is respected. We explain the rules, how they vary by jurisdiction, and how to build.
The GILTI high-tax exclusion can switch off current US tax on foreign company profits. We explain how the election works, when it helps, and the traps.
A clear 2025 guide to Spain's Beckham Law expatriate regime: who qualifies, the flat rate on Spanish employment income, exclusions and application windows.
Subpart F income can tax US owners on a foreign company's profits before any distribution. We explain the CFC rules, the income categories, and how to plan.
A balanced 2026 view of private banking: how major banks and boutiques differ on minimums, onboarding, source of wealth, booking centres and service.
The US exit tax can apply when you renounce citizenship or give up a green card. We explain the covered expatriate tests and the mark-to-market charge.
Grenada citizenship by investment explained: the rare US E-2 treaty route, China travel access, the investment options, the process and who it suits.
Renouncing citizenship carries tax consequences that vary widely by country. We explain exit taxes, ongoing obligations, and how to plan a clean departure.
Renouncing citizenship carries real tax consequences, from US exit tax to ongoing reporting. Here is what to weigh before you hand back a passport.
NFT taxation is messier than most assume. We explain how creators, traders and collectors are taxed and where offshore structuring genuinely helps.
Long-form practical guides on jurisdictions, structures and pathways.
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Explore →Plain-English definitions of offshore terms — from ATED to VASP.
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