Other Fiscal Heavens - Switzerland, Monaco & Cyprus

Fiscal Migration

In many instances, the subtle and somewhat semantic differences between being merely resident or domiciled and resident can have serious tax planning consequences.  In certain cases it may be necessary for an individual to change his or her place of residence to achieve a particular fiscal end. Some of our most popular residency/immigration jurisdictions include:

Switzerland, although not tax free, is one of the most popular fiscal migration jurisdictions in Europe mainly because of its strategic location, negotiable tax rates, stability and banking facilities. To successfully apply for permanent residence it is necessary to show significant assets, actual residence in Switzerland for 6 or more months per annum and a commitment to make Switzerland the centre of one's family and/or business life. Furthermore, it is also necessary to provide a wealth attestation, police certificate confirming that the applicant has no criminal record and a medical certificate. Exact tax responsibilities vary tremendously depending on which Canton one wished to reside in and whether one is retired or not.

Principality of Monaco is one of the most favoured residency locations for the wealthy primarily because of the lack of income taxes, ideal geographic position and absolute safety. To become an official resident it is necessary to obtain carte de sejour (residency permit) which can normally be obtained within 3 months of the original application date. Required documents include:

- a police certificate from the appropriate country confirming that the applicant(s) have no known criminal record(s),

- a valid French Visa issued by the French Embassy in the jurisdiction of current residence,

- a medical certificate provided by an approved physician in the jurisdiction of current residence,

- proof of property acquisition or rental providing either the requisite property deeds or lease (bail a loyer) corresponding to the size of the applying (where applicable) family unit,

- the completion of multiple application forms outlining the full personal details and circumstances of all applicants,

- a referee from Monaco, normally the local Monegasque advocate or immigration consultant and an attestation from a Monegasque bank that, at least, €800,000.00 (approximately FRF 5,000,000) or its equivalent has been lodged. Please note that the attestation must be given on each renewal date for the residency permit. While considering relocation to Monaco, one should borne in mind that it is expensive and time consuming to establish a local company. In addition when more than 25% of a business' revenue is derived from external trade a 33.3% tax will be levied on all profits. There may also be constraints on what activities an applicant can conduct from the Principality. Also the 1963 tax treaty between Monaco and France prevents French nationals from enjoying any of the indigenous fiscal benefits. Nevertheless, Monaco is often an ideal personal location, especially if employed in conjunction with an external tax planning structure. 

Cyprus is one of the most favoured jurisdictions for those seeking a residency permit at competitive rates. In effect, Cypriot legislation allows an investor establishing either a genuine offshore branch or an indigenous Cypriot company the ability to be granted an authentic Cypriot residency permit. In order to qualify, it is necessary to prove management and control will physically take place in Cyprus and to facilitate this SCF has its own office in Cyprus.