Launch Your Dreams in Europe: Portugal’s Start-Up Visa Program

Are you an aspiring entrepreneur with a groundbreaking idea and the drive to see it flourish? Look no further than Portugal’s Start-Up Visa Program! This initiative welcomes foreign innovators like yourself, offering a streamlined path to residency or citizenship, and the chance to establish your business in a thriving European hub.

Why Portugal?

Portugal has rapidly become a magnet for entrepreneurs and is lauded for its:

  • Supportive Ecosystem: A network of business incubators, co-working spaces, and government agencies provide guidance, resources, and funding opportunities to help your start-up take root.
  • Favourable Tax Environment: Portugal offers competitive tax rates for both companies and individuals:
    • Individuals: under certain conditions, individuals may benefit for the favourable tax regime called the NHR – see here for more details. Other advantages may still exist for those not eligible for NHR.
    • Corporate: Taxes from 12.5% apply to start-ups in Portugal mainland – however, making use of the Madeira International Business Centre is an alternative option which provides an attractive tax rate of 5%. Read here for more details.
      • Further, government support programs are available in Portugal to support start-ups.
  • High Quality of Life: Portugal boasts a stunning coastline, rich culture, and a welcoming population, making it an ideal place to live, work, and raise a family.
  • Doorway into Europe: a gateway into the world’s largest trading bloc with access to a favourable business with clients, suppliers, grants and beneficial tax regimes

Furthermore, Portugal is rapidly emerging as a significant player in the global start-up landscape, with several companies achieving unicorn status and attracting significant investment. This thriving ecosystem presents a compelling opportunity for ambitious entrepreneurs seeking to establish their businesses in Europe.

The Start-Up Visa: Your Gateway to Success

The Start-Up Visa Program streamlines the visa application process for foreign entrepreneurs, allowing you to:

  • Gain residency in Portugal: This visa allows you to live and work in Portugal, granting access to the European Union market.
  • Bring your family: You can extend your visa to include your spouse and dependent children.
  • Focus on your business: With residency secured, you can devote your energy to building your dream company.
  • Obtaining Portuguese citizenship. After having lived in Portugal for five years, you and your family can apply for citizenship or permanent residency.

Eligibility and Requirements

To qualify for the Start-Up Visa, your business must meet the following criteria:

  • Innovation: Your business idea must be deemed innovative by IAPMEI, the Portuguese public agency responsible for innovation in the economy and who evaluates applications. This typically involves presenting a unique product or service, deemed innovative, with high growth potential. Eligible criteria includes:
    • Opening or relocating a company in Portugal;
    • Focus on technology and knowledge;
    • Have the potential to attain, after five years after the incubation period, a turnover over 325.000€ per year, and/or assets value over 325.000€ per year.
  • Job creation: Your business plan should demonstrate the potential to create qualified jobs in Portugal.

Portugal has many incubators to mentor and support new businesses. Explore a certified incubator and ask for a quotation of services. A signed contract with an incubator will be required when submitting for this type of visa option. A complete list of eligible incubators for the purposes of the start-up visa may be found here (IAPMEI – Página Inicial).

Minimum Stay Requirements:

  • You must be present in Portugal, within a 24 months period, for 18 months in a row or 16 intermittent months to maintain your residency status.

Minimum Payments:

  • There is no minimum investment required for the Start-Up Visa, unlike other residency programs in Portugal. However, you must demonstrate sufficient funds to support yourself and your dependents for the first year (as referred above).

Evaluation of the Visa

IAPMEI reviews and approves applications for the start-up visa. The evaluation of the visa is based on the degree of innovation, the scalability of the business, the market potential, the capacity of the management team, the potential for creating qualified employment in Portugal and the relevance of the applicant in the team.

The processing time is at least 6 months to a year.

Taking the Next Step

At Dixcart Portugal, we are passionate about helping aspiring entrepreneurs like you navigate the complexities of international business ventures. We offer comprehensive guidance and to ensure a smooth and efficient journey.

Contact us today to schedule a consultation and learn how we can help you turn your vision into reality in Portugal (advice.portugal@dixcart.com). Together, let’s launch your success story in Europe!

Additional Notes:

It is important to remember that this information is for general informational purposes only and does not constitute advice. It is highly recommended to consult with a qualified professional on your specific situation.

Key Employee Initiative – Fast-track Work Permit in Malta for Non-EU Highly-Skilled Workers

What is the Key Employee Initiative?

The Key Employee Initiative (KEI) provides a fast-track work permit for highly specialised Third-Country Nationals (TCNs), who are employed in Malta.

The scheme enables work permits to be issued to key prospective employees, no longer than 5 working days from the date of application, under normal circumstances.

Third-Country Nationals

Third-Country Nationals require a single work permit to be able to obtain residence and be employed in Malta. This is because TCNs are not members of the EU or EFTA, and are therefore not able to move across borders, in the EU, without the proper documentation. 

However, TCNs who are high-skilled workers, are provided with a fast-track work permit service by the Key Employee Initiative. Under normal circumstances, the scheme will issue work permits in not more than 5 days, as detailed above. In contrast non highly specialised TCNs must wait for at least a couple of months.

Who is Defined as a Highly Skilled Worker?

Highly-skilled workers include individuals who possess advanced technical, academic and interpersonal skills. They usually flourish in the areas of; problem-solving, leadership, system improvement and creativity. Examples of highly-skilled workers include; university professors, engineers, biotech scientists, business directors, and IT experts. 

Criteria

Malta’s Key Employee Initiative (KEI), is available to highly technical or managerial professionals with the relevant qualifications and experience for the job they are applying for.

Eligible highly-skilled workers are required to meet the following requirements: 

  • Have valid travel documents.
  • Receive an annual gross salary of at least €35,000.
  • Be in possession of certified copies of qualifications and necessary work experience.
  • The employer must declare that the individual has the necessary credentials for the assigned role. Should the applicant wish to be employed by a Maltese company of which s/he is a shareholder or ultimate beneficial owner, s/he must have a fully paid up share capital of at least €500,000 OR must have made a capital expenditure of at least €500,000 to be used by the company (fixed assets only, rental contracts do not qualify).

Benefits:

The following benefits are available through Malta’s Key Employee Initiative:

  • The KEI is a fast-track version of the standard single work permit application, with applications being approved in just 5 days.
  • Applications can be submitted online, without the applicant needing to be present in Malta.
  • Approved applicants are issued with a residence permit valid for 1 year. This  can be renewed, subject to the presentation of a valid definite or indefinite contract, and an original ‘annual tax declaration form’, stamped by the Maltese Inland Revenue Department.
  • Visa-free travel within the 26 Schengen Area Countries, by virtue of the Maltese residence card. This is limited to a maximum of 90 days every 180 days.

Family Members of Work Permit Holders

Non-EU nationals who have been legally residing in Malta for over a year (in specific circumstances this may be reduced), are eligible to apply for the ‘reunification’ of family members. This includes spouses over the age of 21 and children under the age of 18.

Long-term Residents

Long-term residence status may be granted to persons legally residing in Malta for a continuous 5 year period.

A successful application requires; proof of continuous residence prior to the application date, and the ability to show stable and regular income of a stipulated amount. Dixcart can provide details of the other requirements, which include the need to have health insurance and attendance of a language and culture course.

Tax Treatment

  • Tax is charged at progressive rates (capped at a maximum of 35%), on Malta sourced income and capital gains, and on foreign source income (excluding foreign source capital gains), that is remitted to Malta.
  • No tax is chargeable on foreign sourced income that is not remitted to Malta.
  • Capital gains are tax-exempt in Malta, even if they are remitted to Malta.
  • Bank interest earned in Malta can be liable to withholding tax at 15%.
  • Long term residence permit holders are not entitled to benefit from the remittance basis of taxation and will be taxed on their worldwide income in Malta.

Case Study

Dixcart Malta provided advice to a UK citizen who was still living in the UK. An important benefit of the Key Employee Initiative is that it is possible to start the  process before the relevant individual has even arrived in Malta.

This highly-skilled professional, in the ICT industry, secured his position at a Maltese employer and decided to relocate to the island once he received the ‘Approval in Principal Letter’, confirming that his application met all of the requirements and had been successful.

After being provided with all of the essential documents, Dixcart Malta made the application, on behalf of the Employee and Employer and submitted all of the forms and evidence of experience, qualifications, and health insurance, to the Authorities. In addition, we even helped to find an apartment for the newcomer.

After receiving a final decision, the KEI had 90 days to relocate to Malta.

Another Set of Circumstances

Dixcart Malta can also provide support services, relating to the Key Employee Initiative, for TCN Employees and local Employers. There may be situations where positions cannot be filled by the local labour market and where suitable TCNs can fulfil the job in the EU with a fast-track Malta work permit, rather than the company remain with vacant positions.

Additional Information

For further information on the Key Employee Initiative, please do not hesitate to contact Henno Kotze: advice.malta@dixcart.com at the Dixcart office, in Malta or your usual Dixcart contact.

Dixcart Management Malta Limited Licence Number: AKM-DIXC-24

New More Accessible Fast-Track Work Permit in Malta

The Specialist Employee Initiative

A new Fast-track work permit has been introduced in Malta called the Specialist Employee Initiative (SEI). This route is applicable to specialised employees that are not eligible for the Key Employee Initiative (KEI), but still hold the relevant academic, vocational or technical skills in line with their employment offer in Malta. Applications for SEIs are filed in accordance with the Single Permit Regulations.

The introduction of the SEI demonstrates Malta’s commitment to attracting global talent, recognising the importance of simplifying application procedures for qualified foreign workers.

Third-Country Nationals

Third-Country Nationals (TCNs) require a single work permit to obtain residence and to be employed in Malta. This is because TCNs are not members of the EU or EFTA, and are therefore not able to move across borders, in the EU, without the proper documentation.

However, highly skilled TCNs benefit from a fast-track work permit service under this Specialist Employee Initiative.

Application Process

The processing time for this type of application typically takes around 15 days, after submission of the complete list of required documents.

The employer is required to email a completed application along with all necessary attachments in accordance with the relevant checklist. ‘Identitá’, the Government Agency overseeing this programme, will ask the applicant’s permission before submitting the application and supporting materials.

Upon receiving approval, the application will be processed in accordance with set protocols. Both the company and the candidate will receive an informational email and an acknowledgement, along with additional instructions on how to pay the application fee during the biometrics stage.

Any missing documents can result in delays or application rejection. It is important to ensure that all mandatory documents are submitted as per the checklist.

Once a decision is made on the application, both the applicant and the employer are informed of the outcome via email.

Eligibility and Requirements

In order to be eligible to apply for the SEI application an individual must:

  • Have a signed contract with a Maltese company;
  • Have an annual gross salary of at least €25,000;
  • Be in possession of either
    • (i) an MQF level 6 or higher in an area directly related to the job offer or
    • (ii) skill qualifications together with a minimum of 3 years’ experience in a position which is directly related to the job offer.
  • Present previous employment contracts (signed by both employer and employee).
  • Provide their employment history, issued and officially certified (stamped or legalised) by the official employment authority in the country where the employment took place.
  • Reference letters by former employer/s. Reference letters must show the start and end dates and details of the work carried out. The letters should contain clear contact details of the referee including a valid email address, postal address and contact number.

Typical documents needed with the application are:

  • Full copy of passport
  • CV
  • Declaration of Suitability
  • Lease Agreement & Housing Approval
  • Health Screening
  • Health Insurance

Visa duration and conditions

A residence permit will be granted to successful applicants for a period of one year. If the employee remains in compliance with the eligibility criteria and his/her employment contract applies to all periods of validity, this authorisation may be renewed for an additional period of up to three years.

Tax Treatment

  • Tax is charged at progressive rates (capped at a maximum of 35%), on Malta sourced income and capital gains, and on foreign source income (excluding foreign source capital gains), that is remitted to Malta.
  • No tax is chargeable on foreign sourced income that is not remitted to Malta.
  • Capital gains are tax-exempt in Malta, even if they are remitted to Malta.
  • Bank interest earned in Malta can be liable to withholding tax at 15%.
  • Long-term residence permit holders are not eligible for the remittance basis of taxation and will be taxed on their worldwide income in Malta.

Conclusion

The introduction of this programme introduces an option for highly skilled third country nationals to obtain a work and residence permit in Malta, 15 days after the submission of the application and relevant documentation. Identitá have recognised the increased demand for such a work permit and this initiative will help improve processing time and efficiency.

Additional Information

For further information on the Specialist Employee Initiative, please do not hesitate to contact Henno Kotze: advice.malta@dixcart.com at the Dixcart office, in Malta or your usual Dixcart contact.

Dixcart Management Malta Limited Licence Number: AKM-DIXC-24

UK Non-Domiciled Individuals Seeking to Relocate to Cyprus

Introduction

Following the announcement in March 2024 from the UK’s Treasury Department, that the current UK non-domiciliation rules will cease to exist from 6 April 2025, many UK non-domiciled residents may start the decision process to relocate to tax efficient jurisdictions

The Benefits of Cyprus

  • attractive tax incentives for individuals wishing to become Cyprus residents.
  • excellent education infrastructure
  • reasonable cost of living
  • high quality public and private health care services
  • advanced infrastructure of services
  • a warm and friendly community in which to live.
  • simple tax regime that is fully EU and OECD compliant
  • well drafted laws on Corporate and Commercial matters
  • easy access to international litigation and arbitration

And last but not least, the excellent weather with beautiful surroundings and culture.

Moving to Cyprus

There are various options in terms of moving to Cyprus, as outlined below:

EU non-domiciled UK residents moving to Cyprus.

All nationals of the Member States of the European Union have the right to move freely within the European Union and to enter and reside in any EU Member State. This right to freedom of movement is guaranteed by article 21 of the treaty on the functioning of the EU (TFEU).

EU and EEA Citizens entering Cyprus to work, stay or remain as visitors for more than 3 months on the island need to register for a residence permit for EU citizens. The registration certificate they get is commonly known as Yellow Slip.

Third country non-domiciled UK residents moving to Cyprus.

A. Moving to Cyprus, from the UK, as an Investor

The recently revised Residency by Investment programme allows foreign nationals to obtain permanent residency by investing in a Cypriot property worth at least €300,000, plus VAT. Applicants must also have an annual income of at least €50,000 plus €15,000 for a spouse and €10,000 for each dependent child or family member included in the application.

The applicant and his spouse/husband must certify that they do not intend to be employed in the Republic of Cyprus except for their employment as Directors in a Company in which they have chosen to invest within the framework of the policy, as detailed below.

B. Living in Cyprus with a Temporary Residence Permit

1. Establishment of a Foreign Interest Company.

A Foreign Interest Company is an international company, which, subject to meeting specific criteria, can employ non-EU national employees in Cyprus. This programme enables employees and their families to gain residence and work permits under favourable terms.

The Main Requirements Enabling an International Company to Qualify as Foreign Interest Company

  • The third country shareholder(s) must own more than 50% of the total share capital of the company.
  • There must be a minimum investment of €200,000 or €260,000 (depending on the circumstances) into Cyprus by the third country shareholder(s). This investment can be used later to fund future expenses incurred by the company when it is established in Cyprus.
2. Acquiring a temporary residence permit as an employee at a Foreign Interest Company.

Employees at Foreign Interest Companies and their family members can acquire temporary residence and work permits which are renewable.

3. Temporary / Retirement / Self-Sufficiency Residence Permit

The Cyprus Temporary Residence Permit is an annually renewable self-sufficiency visa that allows an individual and their qualifying dependants, to live in Cyprus as a visitor, without employment rights.

The main qualification requirements are as follows:

  • Annual income, that is sourced from outside Cyprus, of a minimum of €24,000, which increases by 20% for a spouse and by 15% for each dependent child.
  • A title deed or rental agreement for a residential property in Cyprus that is for the sole use of the applicant and his/her family.
  • A certificate of ‘no criminal record’ and of not being under investigation for criminal offences, that is certified, by the relevant authorities of the applicant’s country of current residence.
  • Private medical insurance.
  • An original medical examination certificate to confirm that the applicant does not have certain medical conditions.

It is essential that the holder of a Cyprus temporary residence permit should not stay outside of Cyprus for more than three months at a time, because this could result in the permit being cancelled.

Additional Information

For further information about the attractive tax regime for individuals in Cyprus please contact the Dixcart office in Cyprus: advice.cyprus@dixcart.com.


Starter Kit for Indian Individuals Interested in a Portuguese Golden Visa Fund

Understanding the Portuguese Golden Visa Fund

The Portuguese Golden Visa Fund is an investment option that allows non-EU citizens, including Indians, to obtain a Portuguese residence permit. This residence permit provides visa-free travel within the Schengen Area, the right to live, work, and study in Portugal, and a path to Portuguese citizenship after five years.

I thought that the Portuguese Golden Visa had Ended?

Following a recent restructure of the programme, certain routes are no longer available, as finally voted on the 21 of September 2023. The new programme changes what types

of investment qualify for the scheme; real estate and capital transfer investments are no longer eligible.

What is a Collective Investment Entity (CIS)?

A Collective Investment Entity (CIS) is a type of investment fund that pools money from multiple investors, to invest in a diversified portfolio of assets.

To qualify for the golden visa, the CIS must be established under Portuguese legislation, with a length of maturity of at least five years, and with at least 60% of the value of the investments being made in commercial companies headquartered in the national territory of Portugal. A CIS is regulated by an independent body, which overseas such funds, and is known as the Portuguese Securities Market Commission (CMVM – Comissão do Mercado de Valores Mobiliários).

Evaluating a Good Investment Entity

When evaluating a CIS for the Portuguese Golden Visa, consider the following factors:

  • Track record: Choose a CIS with a proven track record of generating returns
  • Investment strategy: Understand the CIS’s investment strategy and ensure it aligns with your risk tolerance.
  • Fees: Compare the fees charged by different CIS’s.
  • Regulatory compliance: Verify that the CIS is fully compliant with Portuguese
  • regulations.
  • Management team and expertise: definitely consider experience to date.

Examples of Investments Made by CISs

CISs invest in a variety of asset classes, including private equity, where companies, with a mature profile or promising growth, are invested in. Specific examples include; operating hotels and resorts, solar project developments, annual crop yield improvement projects, farm development, amongst many examples. There is an investment for almost every interest!

Tangibility and Risks of a CIS

CISs are intangible assets, meaning they do not have a physical form. However, they represent ownership in a portfolio of tangible assets. Investing in a CIS involves risks, including:

  • Market risk: The value of a CIS investment can fluctuate with market conditions.
  • Credit risk: There is a risk that the companies or securities invested in, by the CIS, may default on their obligations.
  • Liquidity risk: There may be a delay in selling your investment in a CIS.

Comparability to other EU Residency Programmes

The Portuguese Golden Visa Fund offers several advantages when compared to  other EU residency programmes, including:

  • Lower investment requirement: The minimum investment for the Portuguese Golden Visa Fund is €500,000, which is lower than the investment requirements for many other EU passport programmes.
  • Flexibility of stay: You are only required to spend seven days per year in Portugal to maintain your residence permit.
  • At the end of five years of legal residency, you can apply for a Portuguese passport, which is not permitted in all of the other residency programmes available in the EU.

Navigating Indian Exchange Control Issues

Indian residents are subject to exchange control regulations that restrict the amount of foreign exchange they can transfer out of the country. Dixcart Portugal Lda has assisted many Indian clients with their investments in Portugal, and you are welcome to discuss such matters with us.

Portugal – A preferred Route for Indian Nationals?

According to the Portuguese Immigration Authorities, as of October 2023, a total of 1,234 Indian nationals have applied for the Portuguese Golden Visa. This represents almost 5% of all Golden Visa applications received to date!

It is therefore not surprising that, there is a large and growing Indian community in Portugal.

How to choose the right partner for your Portuguese Golden Visa?

When selecting a partner to assist with your Portuguese Golden Visa, consider their; experience, reputation, communication, fees, location, and expertise in your investment type. Additionally, try to ensure that they are responsive, keep you updated, and can explain complex concepts clearly.

Dixcart Portugal Lda: Your Experienced Partner for the Portuguese Golden Visa

Dixcart Group has over 50 years of experience, with 35 years of experience in Portugal, working with private clients and advising corporates. We are headquartered in the UK and have a proven track record. We have clientele based all over the world – including a substantial client book of business from India.

We have also been able to refer specific cases to the right legal team in instances  where biometrics have been lost, or other challenges have arisen, such as missed biometric appointments. These are special cases which require expertise and experience to manage successfully – which we have been able to achieve to date.

Dixcart Portugal Lda were one of the first companies to coordinate and help manage golden visa applications, through introductions to Portuguese legal advisers, who have assisted many individuals and families to complete the programme and obtain a Portuguese passport. In addition, Dixcart Portugal Lda already have experience of the many changes that have been made to the programme over time, and have helped clients deal with these revisions.

Contact Dixcart Portugal Lda Today to Learn More

If you are an Indian individual interested in a Portuguese Golden Visa Fund, please contact Dixcart Portugal Lda today, to learn more about your options and how we can help you achieve your immigration goals and connect you with the right legal advisers: advice.portugal@dixcart.com

Tax Efficiencies Available in Cyprus: Individuals and Corporates

Why Cyprus?

Cyprus is an appealing European jurisdiction, located in the eastern Mediterranean Sea offering a warm climate, attractive beaches and the perfect balance of cosmopolitan living and rural villages. Strategically located at the crossroads of three continents, Cyprus is accessible from Europe, Asia and Africa. Nicosia is the centrally located capital of the Republic of Cyprus however, the growing financial hub is Limassol on the southern coast. The official language is Greek, with English also being widely spoken. Cyprus offers a palette of both corporate and personal tax incentives for expatriates and high net worth individuals relocating to Cyprus. Cyprus has a favourable business environment and, as a result, has become an attractive an international business hub.

Are you looking to relocate your business and/ or start a new business in Cyprus? Maybe you’re considering setting up a holding company or restructuring the fiscal position of a family office structure? If you are, please consider the below information and become convinced of a great way to optimize your business structure We will start by looking at the tax benefits available to individuals and to corporates.

Tax Benefits Available to Individuals

What are the Advantages of Becoming Cyprus Tax Resident?

Cyprus non-domicile status can be an effective means to optimise personal wealth planning. The advantages of becoming Cyprus tax resident, an option for individuals not previously tax resident in Cyprus, include the following:

  1. Non-Domicile Status

The non-domicile tax regime is particularly interesting for individuals whose main source of income is either dividend or interest income, as these sources of income are not taxed in Cyprus.

Individuals can also take advantage of the exemption from taxation of capital gains, other than on the sale of immoveable property in Cyprus.

In addition, there is an exemption from taxation on capital sums received from pensions, provident and insurance funds as well as several other tax advantages, including; a low rate of tax on foreign pension income, and no wealth or inheritance taxes in Cyprus.

The zero tax benefits, mentioned above, are enjoyed even if the income has a Cyprus source and/or is remitted to Cyprus.

  1. Employment Income Tax Exemption

New incentives for first employment in Cyprus

The 50% exemption:

As from 1 January 2022, 50% of the remuneration of employees whose first employment in Cyprus began on, or after, 1 January 2022 is exempt from income tax for a period of 17 years, provided that their annual remuneration exceeds €55,000 (previous threshold €100,000), and the employees were not residents of Cyprus for a period of, at least, 15 consecutive years before the commencement of their employment in Cyprus.

In cases where in a tax year the relevant conditions are not satisfied (e.g., annual remuneration is less than €55,000) the above-stated exemption will not be granted for that specific tax year. This exemption is available for a period of up to 17 years.

The 20% exemption:

Individuals whose first employment in Cyprus began after 26 July 2022 and earn less than €55,000 are eligible for a 20%, or €8,550 exemption (whichever is lower) from their employment income, for a maximum period of 7 years provided that the employees were not residents of Cyprus for a period of, at least, 3 consecutive years before the commencement of their employment in Cyprus.

This exemption can be claimed from the year following the year of commencement of employment in Cyprus.

  1. Tax Exemption on Income from Employment Outside Cyprus

Individuals who are employed outside of Cyprus, for more than 90 days in aggregate in a tax year, by a non-Cyprus tax resident employer or foreign permanent establishment of a Cyprus tax resident employer, are exempt from income tax on this income.

Tax Benefits Available to Companies

  1. Corporate Tax Rate

Cypriot companies enjoy a 12.5% rate of tax on trading, and a zero rate of capital gains tax.

  1. NID

NID is deducted from taxable income. It cannot exceed 80% of the taxable income, as calculated prior to the NID, arising from the new equity.

A company could achieve an effective tax rate as low as 2.50% (corporate tax rate 12.50% x 20%). Please contact the Dixcart office in Cyprus for further information: advice.cyprus@dixcart.com

  1. Increased Tax Deduction for Research and Development Expenses

 Eligible research and development expenses can be deducted from taxable income equivalent to 120% of the actual spend.

Additional Information

For further information about the attractive tax regimes available to individuals and companies in Cyprus, please contact the Dixcart office in Cyprus: advice.cyprus@dixcart.com.

 

Multi-Jurisdictional

Residence and Citizenship Programmes (Comparison Table)

This information is correct as of January 2024.

The comprehensive PDF below details the Residence and Citizenship Schemes available in: Cyprus, Guernsey, Isle of Man, Malta, Portugal, Switzerland and the UK.

Please note that as a general principle EEA citizens are free to move to other EEA countries.

Switzerland is in the Schengen Area and as such EEA citizens can move there and vice versa.

The residence schemes detailed for: Cyprus, Malta, Portugal, and Switzerland are applicable to non-EEA individuals.

Guernsey, the Isle of Man, St Kitts & Nevis, and the UK are not in the EEA and therefore their schemes apply to EEA and non-EEA individuals. Please note, however, that where freedom of movement is not the prime motivator, a number of the programmes may be of interest to other EEA citizens and are open to them.

Dixcart look forward to being able to assist you with any change of citizenship or residence plans that you may have: advice@dixcart.com

Services Provided by Dixcart

  • Staff resident in Cyprus, Guernsey, Isle of Man, Malta, Portugal (Lisbon and Madeira), Switzerland and the UK
  • Expertise regarding each jurisdiction: lifestyle, tax regime etc.
  • Organising visits if required
  • Coordination of the application process
  • Undertaking/coordinating requisite legal work
  • Wealth management
  • Assistance with relocation
  • Provision of personal and corporate professional services once relocation has taken place

St Kitts & Nevis: details provided in this document are for information only.

PLEASE NOTE: In addition to the Financial Criteria detailed in the pdf, Government Fees are payable which vary considerably depending on the particular Residence Scheme. Information is available on request.

Dixcart Trust Corporation Limited, Guernsey: Full Fiduciary Licence granted by the Guernsey Financial Services Commission, registered company number: 6512.

Dixcart Management (IOM) Limited is licensed by the Isle of Man Financial Services Authority.

Dixcart Management Malta Limited Licence Number: AKM-DIXC-24

Lisbon,,Portugal,Skyline,With,Sao,Jorge,Castle

Portugal Non-Habitual Resident Regime Update

On 29 November, it was confirmed, that the changes to the Non-Habitual Tax Resident (NHR) regime will become effective – amending the current regime and introducing a new regime.

When will the Current NHR regime end?

The current NHR regime will end on two different dates for two separate groups of people – namely:

  1. Those who become tax resident before 31 December 2023; and
  2. Those who qualify to become tax resident before 31 December 2024 (under specific conditions referred below).

Those Who Become Tax Resident Before 31 December 2023 – Under the Current Regime

Anyone who becomes a tax resident in Portugal (as an EU national or through a qualified visa), before 31 December 2023, and are performing a high value-added activity or an activity of a scientific, artistic, or technical nature, and who have not been tax resident in Portugal in the last five years, will be able to apply for the NHR. They will have until 31 March 2024 to register for their NHR status.

Those Who Become Tax Resident Before 31 December 2024 – Under the Current Regime

The grandfathering rule will also apply to taxpayers who become tax residents of Portugal during the next year, by 31 December 2024, if one of the following conditions is met:

a. A promissory employment agreement or promissory secondment agreement (or employment or secondment agreement) is signed by 31 December 2023, to perform activities in Portugal; OR

b. A lease agreement or other agreement granting the use or possession of property located in Portugal before 10 October 2023 (the day when the NHR withdrawal was officially announced); OR

c. Reservation or promissory contract, for the acquisition of property located in Portugal before 10 October 2023 (the day when the NHR withdrawal was officially announced); OR

d. Enrolment or registration of dependents at a Portuguese educational establishment before 10 October 2023 (the day when the NHR withdrawal was officially announced); OR

e. Possession of a residence visa or residence permit that is valid by 31 December 2023; OR

f. A procedure, is initiated by 31 December 2023, to obtain a residence visa or residence permit from the competent authorities, in accordance with the current immigration legislation. This can be done by requesting an appointment or attending an appointment to submit the application for a residence visa or residence permit, or by submitting the application for a residence visa or residence permit directly; OR

g. The taxpayer is a member of the household of a taxpayer, who meets one of the above conditions.

I am currently an NHR – does this affect me?

As the current NHR regime will be grandfathered (for all applications made under the existing regime), there is no impact for individuals already enjoying NHR status (or who will become NHR under the conditions mentioned above). The regime will continue to exist until the 10-year NHR period is reached, from when each specific individual registered for NHR.

When will the New NHR regime take effect?

A new NHR regime is applicable to those who do not meet the conditions mentioned above.

The new regime is effective from 1 January 2024, and offers a narrower scope of eligible professions, than the current NHR regime.

Individuals who become tax residents of Portugal from 1 January 2024 (under the new NHR regime), and have not been tax resident in Portugal in the previous five years may qualify for the new NHR. Please see below, specific criteria to meet to be eligible under the new NHR.

Who will be eligible for the new NHR regime?

The following individuals may be eligible for the new NHR regime:

  1. Teaching in higher education and scientific research, including scientific employment in entities, structures, and networks within the Portuguese science and technology system, as well as positions on the governing bodies of entities recognised as technology and innovation centres;
  2. Qualified jobs within the scope of ‘contractual benefits towards productive investment’, as defined in Chapter II of the Portuguese Investment Tax Code;
  3. Qualified jobs recognised by AICEP Portugal Global – Trade & Investment Agency or by IAPMEI – Agency for Competitiveness and Innovation as being relevant to the national economy, particularly in the context of attracting productive investment;
  4. Research and development personnel whose costs are eligible for the purposes of the tax incentive system for research and business development, as defined in the Investment Tax Code;
  5. Employment in entities certified as start-ups under the Portuguese Start-Up Law;
  6. Activities carried out by tax residents in the autonomous regions of the Azores and Madeira, as specified by regional decree.

What are the tax consequences of the new NHR regime?

Taxpayers who meet the requirements and fall into one of the categories, detailed above, may be taxed at a preferential fixed rate of 20%, on employment or self-employment, Portuguese sourced income, earned from such activities, for a period of 10 consecutive years (with the option of utilising the marginal rates, if lower).

To maintain eligibility for this regime, taxpayers must continue to earn active income, with a maximum interim period of 6 months between activities.

Eligible taxpayers may be exempt from taxation on foreign income from various sources, including; employment income earned abroad, self-employment income earned abroad, foreign rental income, and capital gains from foreign assets, with the exception of pension income (taxed at the progressive tax rates – previously 10% under the old NHR regime). Income derived from blacklisted tax havens will be subject to a 35% tax rate.

Summary of Tax Consequences Differentiating between the Current and New NHR Regime

Categories of IndividualsCurrent NHR RegimeNew NHR Regime
Employees or contractors of a Portuguese based entity20% taxation for high value-added activities for 10 years. Other foreign passive income may be exempt for 10 years.20% taxation for work for certain eligible activities for 10 years. 20% taxation for high-value added activities carried out by tax residents in the autonomous regions of Azores and Madeira. Exempt on foreign income from several categories of income for 10 years.
Employees or contractors working for a foreign based company (exception for exempt salary income)20% taxation for high value-added activities for 10 years if the income is not taxed in the source state. Other foreign passive income may be exempt for 10 years.Progressive taxation up to 48% plus surtaxes. 20% taxation – possible coverage for “activities carried out by tax residents in the autonomous regions of the Azores and Madeira, under terms to be defined by regional decree.”
HNWI deriving only passive related incomeOnly certain foreign passive income may be exempt for 10 years. Portfolio gains generally taxed at 28%.Flat tax on passive income generally at 28% with credit of foreign taxes (no exemption method).
Pensioners10% taxation for 10 years. Other foreign passive income may be exempt for 10 years.Progressive taxation up to 48% plus surtaxes. Flat tax on passive income generally at 28% with credit on foreign taxes.
R&D work performed in Portugal20% taxation for high value-added activities for 10 years. Other foreign passive income may be exempt for 10 years.20% taxation for work for certain eligible activities for 10 years.Exempt on foreign income from several categories of income for 10 years.

What other tax benefits exist for Portuguese tax residents from 1 January 2024?

Individuals becoming tax resident in Portugal, as long as they have been Portuguese non-tax resident during the past five years and were previously tax resident in Portugal, will enjoy a 50% exemption from personal tax under the ‘Regressar’ programme. This relates to income, under the marginal tax rate, for the first €250,000 of taxable income from employment and independent business income. Income above this threshold will be taxed at the standard rate.

This exemption is valid for five years and is available for new tax residents from 1 January 2024 to 31 December 2026. Any individual, regardless of their expertise is eligible to benefit, high value-added criteria is not required.

To Conclude and for further advice and assistance

It is important to distinguish between the old regime ending on 31 December 2023, although with some exceptions valid until 31 December 2024, and the new regime (effective 1 January 2024).

There is an overlap in timings between the current and new NHR regimes, and it is important to engage with a technically qualified expert, such as Dixcart to advise further on the impact specific to you.

NHR does not need to be a complex topic when you consult with a relevant expert – reach out to Dixcart for more information: advice.portugal@dixcart.com.

The Ultimate Guide to Relocating to Switzerland

Switzerland, with its snow-capped peaks, pristine lakes, and efficient infrastructure, has long been a dream destination for many individuals seeking a balance between a high-quality lifestyle and professional opportunities. As one of the most prosperous and picturesque countries in Europe, it also attracts individuals due to its strong economy, political stability, and exceptional living standards. If you are considering making Switzerland your new home, here’s the ultimate guide to navigating the logistics of working and living in this alpine haven.

You may find also find this Dixcart Swiss Article of interest to read: Switzerland – Could this be your Next Move? – Dixcart

Relocating Logistics

Visa and Residency

Before planning your move, it is essential to understand Switzerland’s visa and residency requirements. Depending on your nationality and purpose of stay, you might need to obtain a visa or a residence permit. Ensuring you have the necessary paperwork in order, will smooth the transition process.

Accommodation

Switzerland boasts a diverse housing market, from urban apartments to picturesque countryside chalets. Local real estate agents and online platforms can help you find the perfect place to call home.

Healthcare System

Switzerland is renowned for its excellent healthcare system, which is often ranked among the best in the world. Familiarise yourself with the country’s health insurance requirements and the different insurance providers available, to ensure that you and your family have comprehensive coverage.

Working in Switzerland

Job Market

Switzerland is home to a thriving economy, particularly in sectors such as finance, pharmaceuticals, and technology. Understanding the job market, networking with professionals in your field, and researching employment opportunities will increase your chances of finding a fulfilling career.

This Dixcart Article includes a useful section regarding working in Switzerland: How Can I Relocate to Switzerland and What Help is Available? – Dixcart

Work Culture

Swiss work culture is known for its punctuality, precision, and strong work ethic. It’s crucial to familiarise yourself with the local customs and etiquette, including the importance of maintaining professionalism and respecting hierarchical structures within the workplace.

Taxes and Finance

Switzerland has a well-established tax system, but it can be complex for newcomers. Educate yourself on the tax regulations and financial planning to ensure compliance and make the most of the various benefits offered to residents.

It is worth seeking professional advice and the Dixcart office in Switzerland can help guide you regarding the various taxes: advice.switzerland@dixcart.com

Living in Switzerland

Cultural Immersion

Embrace the Swiss way of life by participating in local cultural activities, festivals, and events. Learning one of the country’s official languages—German, French, Italian, or Romansh can also help you integrate more seamlessly into the community.

Outdoor Lifestyle

Switzerland’s breathtaking natural landscapes offer an abundance of outdoor activities, from skiing and snowboarding in the winter to hiking and swimming in the summer. Embrace the Swiss passion for nature and adventure by exploring the country’s extensive network of hiking trails and ski resorts.

Community Engagement

Swiss communities value active participation and engagement. Get involved in local community initiatives, clubs, or volunteer organisations to build meaningful connections and foster a sense of belonging in your new surroundings.

For Expert Assistance, Reach Out to advice.switzerland@dixcart.com

Relocating to Switzerland can be a rewarding and enriching experience, but it requires thorough preparation and a comprehensive understanding of the country’s customs, laws, and lifestyle.

For personalised guidance and professional support in navigating the intricacies of the relocation process, reach out to our expert advisers at advice.switzerland@dixcart.com. Our team at Dixcart Switzerland is dedicated to ensuring a seamless transition and helping you make the most of your Swiss adventure.

Malta

Moving to Malta – Using the Isle of Man to Structure Your Assets Efficiently

Located in the heart of the Mediterranean, between the north of Africa and southern Europe, Malta is a modern international commercial hub with a global draw.

Malta boasts a diverse economy with well-developed Financial Services, Fintech, Science and Technology, eGaming, Maritime Services and Aviation sectors. Additionally, the island offers extensive Residency routes available, Schengen area status, fantastic travel links and potentially beneficial tax regime. For these reasons and many more, Malta is a destination of choice for wealthy families, entrepreneurs and businesses around the world. 

Malta offers people relocating to her shores a very attractive Non-Domicile regime that provides individuals with a great deal of flexibility when it comes to structuring their financial matters – this is precisely where the Isle of Man can offer clients a platform for optimising their wealth.

In this article we take a brief look at how Dixcart can assist with moving to Malta and how those individuals can utilise the Isle of Man to protect and grow generational wealth, covering:

  1. How to Become a Maltese Tax Resident?
  2. What are the Tax Rules of the Maltese Non-Domicile regime?
  3. How Maltese Non-Domicile Individuals Utilise the Isle of Man for Wealth Planning?
  4. How Dixcart can Support your Move to Malta & Wealth Planning Goals

1. How to Become a Maltese Tax Resident?

There are two distinct groups of people when we consider the method of becoming Malta Tax Resident – these are 1) EU / EEA / Swiss Nationals, and 2) Third Country Nationals. Importantly, for the purposes of this article, where either type of individual does not intend to remain in Malta permanently and has no substantial connection to Malta, both groups may be deemed a Tax Resident Non-Domiciled individual. There are also compelling Residency Programmes available to each group which offer the same benefits and broadly have the same requirements.

Malta is a member of the European Union (EU) and European Economic Area (EEA). As such, EU / EEA Nationals can live, work and study in Malta indefinitely without a Visa or Work Permit. Swiss Nationals also enjoy this right. These individuals can apply for the Residence Programme via an Authorised Registered Mandatory, such as Dixcart Malta. The Residence Programme offers a special tax status to successful applicants who meet the requirements.

Third Country Nationals will be required to take part in a programme such as the Global Residence Programme or successful applicants also gain a special tax status and are granted a residence permit which also extends to their dependents, including spouses and children. The special tax status received under either programme entitles the individual to a beneficial flat rate of 15% on foreign source income remitted to Malta, with the possibility of claiming double taxation relief where an appropriate Double Tax Treaty is in place. Income that arises in Malta is taxed at a flat rate of 35%. The beneficial rate is subject to a minimum yearly tax contribution of €15,000.

The Malta Residency Programme and Global Residence Programme requirements include:

  • Applicants must pay a one-time non-refundable registration fee of €6,000 to the Maltese Government. This is reduced to €5,500 where the Qualifying Property Holding is purchased in Gozo or the South of Malta.
  • Not have benefitted from a number of previous or existing Malta regimes.
  • Evidence of a Lease Agreement and Rental Declaration, or Purchase Agreement relevant to a Qualifying Property Holding. A Qualifying Property Holding requires a minimum investment in a Maltese property of €275,000, or €220,000 if the property is in Gozo or the South of the island. In the instance of a Rental Agreement, rent must cost not less than €9,600 per annum, or €8,750 if the property is in Gozo or the South of the island. The property cannot be let or sub-let.
  • Evidence of self-sufficient means of subsistence (e.g. bank statements, pension, secure bonds, etc).
  • Posses a valid travel document.
  • Evidence of comprehensive health insurance OR Certificate of Entitlement issued by the Entitlement Unit. Must provide cover within the EU for the applicant and all dependents.
  • Be proficient in one of Malta’s official languages (English is an official language of Malta).
  • Applicants and dependents over 18 years of age must satisfy the fit and proper person requirements.
  • Submit an Annual Return – with any material changes that affect the beneficiary’s special tax status.
  • Not spend more than 183 days in any other jurisdiction, in any single calendar year.

2. What are the Tax Rules of the Maltese Non-Domicile regime?

Liability to Maltese Income Tax arises in three forms, dependent on the Tax Residency and Domicile status of the individual – these are on a Worldwide, Remittance or Territorial basis.

Ordinary Residents of Malta who are Tax Resident and Domiciled are taxed on their worldwide assets; meaning that all Income and Capital Gains are subject to Maltese taxation regardless of where they arise or are received. This also applies to persons who hold the status of Long-term Resident or are in possession of a Permanent Residence Certificate or a Permanent Residence Card.

Maltese Ordinary Residency status is determined by a question of fact, relating to the length of stay along with personal and economic ties. Factors which the authorities will consider, include:

  1. Permanent or Indefinite Basis: Individuals living in Malta permanently or for an indefinite period are typically considered ordinarily resident.
  2. 183 Day Requirement: If an individual stays in Malta for more than 183 days in a single year they may be deemed Ordinary Resident.
  3. Regularity of Stays: Persons who do not meet the 183-day requirement, but who regularly visit over a long period of time e.g. over 3 years, can also be considered Ordinarily Resident.
  4. Personal and Economic Ties: Establishing personal and economic ties in Malta is a significant factor in determining Ordinary Residency e.g. purchasing a family home etc.

The Maltese authorities do not define Domicile by nationality, but where the individual considers their permanent Home i.e. where the person ‘belongs’, which implies more significant ties than Residency alone. This can be the individuals Domicile of Origin i.e. normally the Domicile of their parents, regardless of the country where the individual is born. An individual may acquire a Domicile of Choice if they take up Residence in a country with the intention of making it their permanent home. However, they do not acquire Domicile status if they intend to return to their country of Domicile or resettle in another someday, even where the period is long or indefinite. No person can be without a Domicile, and no person can have more than one Domicile at the same time.

A person that is an Ordinary Resident but not Domiciled in Malta is taxed under the Remittance Basis, and therefore:

  • All income arising in Malta is subject to tax, regardless of where it is received.
  • Income arising outside Malta is subject to Maltese tax only if and to the extent that it is received in Malta.
  • Capital gains arising outside Malta are not subject to tax, even if they are received in Malta.

Individuals taxed under the Remittance Basis are subject to the special rule providing for a minimum tax liability of €5,000 per annum (this minimum tax is different to the Global and Residence program which is 15%).

Unlike many equivalent Non-Domicile regimes, an individual can remain Non-Domiciled in Malta indefinitely.

This means that where the Tax Resident Non-Domiciled individual can show that monies received in Malta originate from assets held abroad as capital e.g. inheritance, proceeds from the sale of capital assets etc. they will be regarded as remittances of capital and will not suffer Maltese tax.

Dixcart Malta are equipped to provide Tax Advice regarding Maltese taxation and the Maltese Non-Domicile regime. If you would like to discuss how the regime works and any opportunities relevant to your circumstances, please get in touch with Jonathan Vassallo at Dixcart Malta.

3. How Maltese Non-Domicile Individuals Utilise the Isle of Man for Wealth Planning?

The Isle of Man is globally recognised as an international financial centre of excellence, boasting a sophisticated legal and regulatory system, a developed professional services industry and a long running heritage in Private Client and Corporate planning.

The Isle of Man was named ‘Best International Financial Centre’ at the prestigious International Investment Awards 2023, beating off stiff competition from Jersey and Guernsey.

The island is a self-governing Crown Dependency which makes its own laws. The Statute book and Case Law is modern and business friendly yet enduring, with a wide array of corporate entities and Trusts available. The jurisdiction is also politically agnostic and therefore clients can take comfort from the stability and reliability offered.

The island also sets its own tax regime and offers headline rates which include:

  • 0% Corporate Tax
  • 0% Capital Gains Tax
  • 0% Inheritance Tax
  • 0% Withholding Tax on Dividends
  • Isle of Man companies are able to register for VAT, and businesses in the Isle of Man fall under the UK’s VAT regime.

Owing to the attractive neutral tax regime, Non-Domiciled individuals seeking to live and work in Malta can potentially structure their non-Maltese assets in such a way that facilitates optimal growth via a potential nil rate in the Isle of Man, remitting withdrawals of capital to Malta free from Maltese taxation. Jonathan Vassallo at Dixcart Malta can provide certainty regarding the Maltese tax treatment of your potential Isle of Man structuring in this regard.

Taxation is a complex area and professional Tax Advice should always be sought before establishing any offshore structure.

4. How Dixcart can Support your Move to Malta & Wealth Planning Goals

After more than 50 years, the Dixcart Group remains proudly privately owned by the same family. the Group consists of 10 offices in 9 jurisdictions across the globe, including both Malta and the Isle of Man. Dixcart are very well positioned to assist clients and their advisers who are considering moving to Malta and seeking to structure their non-Maltese assets, or participation within a Maltese business, in a tax efficient manner via an Isle of Man structure.

Dixcart Malta are experts in all Residency programmes available and are Licensed to act as Authorised Registered Mandatory for clients wishing to apply for either the Malta Residence Programme for EU / EEA / Swiss Nationals, or the Malta Global Citizenship Programme for Third Country Nationals. Further, Dixcart Malta can provide Tax Advice for those looking to take advantage of the very beneficial Non-Domicile regime within Malta.

Dixcart Isle of Man are a Licensed and Regulated Trust and Corporate Services Provider that has developed an extensive range of services over its 30+ years of operation. Our team on the Isle of Man consists of professionally qualified experts and senior employees who possess a wealth of experience. This means that our Isle of Man office can support your corporate and/or Trust planning, at every stage.

Get in Touch

If you would like to discuss how our Dixcart can support your plans regarding Malta and the Isle of Man, please feel free to get in touch with Nathan Hellmann of Dixcart Malta or David Walsh of Dixcart Isle of Man via:

Dixcart Malta: advice.malta@dixcart.com

Alternatively, you can connect with Nathan Hellmann on Linkedin.

Dixcart Isle of Man: advice.iom@dixcart.com

Alternatively, you can connect with David Walsh on Linkedin.

Dixcart Management (IOM) Limited is Licensed by the Isle of Man Financial Services Authority

Dixcart Management Malta Limited Licence Number: AKM-DIXC-23