Cases

A group of three clients held a real estate portfolio in one European jurisdiction — the residential part directly, the commercial part through a holding structure shared with local partners. Over time, all sides reached a decision to unwind the project. Several processes had to run in parallel: negotiating exit terms with the local partners on the commercial side, structuring the withholding tax position correctly in the property jurisdiction, liquidating the holding structure, and declaring the corresponding income in the clients' country of residence.

Equally important was the banking side: ensuring all three clients could receive their proceeds. Two of the three needed new banking relationships in their receiving jurisdictions; we assisted with account openings and prepared the source-of-funds documentation that the receiving banks required for compliance.

The outcome: the commercial structure was wound down, the residential portfolio was sold, the tax treatment was completed in both jurisdictions, and the proceeds were distributed and received in the clients' new banking relationships. The exit from the local partners closed without dispute.

This case illustrates how multi-party work — multiple clients, foreign co-investors, several assets in different formats, several receiving banks — calls not only for tax and legal sequencing, but for precise control of timing. A misstep in any link can stall the entire chain.

A client who had operated through a foreign holding structure with an account at an international private bank found ongoing operations increasingly unpredictable after several waves of compliance tightening across the international banking environment. Each standard transfer required multiple rounds of approvals; the bank requested expanded source-of-funds documentation; some transactions were delayed by weeks.

The client decided to wind down the structure and reorganise their international banking infrastructure. We worked on three tracks at once: aligning the wind-down with the servicing bank, structuring the tax exit correctly in both the structure's jurisdiction and the client's residence, and identifying a receiving bank willing to take on the funds with a clear history.

The structure was closed, the funds were placed into new banking relationships, and tax filings were submitted in both jurisdictions. The client now operates within the rebuilt infrastructure.

A client was changing their tax residency to a European jurisdiction. The asset structure was typical for families at this level: a private offshore company (CFC), personal accounts at a Swiss private bank, and the company's operating accounts at the same bank. The move triggered the standard set of questions: how to declare the CFC correctly in the new country, which local CFC rules applied, how those rules sat alongside the client's continuing obligations in their home jurisdiction, and how to explain the source-of-funds picture to the bank after the residency change.

The work ran on three parallel tracks. First, preparing audited financial statements for the offshore company — these became the factual basis for taxation under local CFC rules. Second, building the tax position for the local advisors: they would file the return in the new jurisdiction, but the reporting position on the structure, on the company's historical base, and on the treatment of different income categories required familiarity with the structure that the local advisor did not have. Third, the banking side: realigning the KYC file with the client's updated profile, preparing responses to compliance queries, and documenting the ongoing ties to the home jurisdiction.

The tax position was settled, filings submitted correctly in both jurisdictions, and the banking relationship preserved. The client now operates from the new residency with a clear tax picture and no open questions on the structure.

This type of work — residency-position analysis at the point of relocation — is a frequent role for us. The local advisor knows their system but does not know the client's structure or history. EMET builds a coherent client position that all local sides can work with, including local partners where they are engaged.

The client spent the reporting year across three countries — Russia, an EU country, and Montenegro — without staying in any of them for longer than six months. Physical presence was distributed roughly evenly, and no single day-count test, taken on its own, gave a clear answer. The asset picture made the question material: the client owned residential property in each of the three countries, operating businesses in two of them, and held accounts at Swiss and Luxembourg private banks. Each country had real grounds to claim residency, and each could do so under its own rules.

The question was not one of day-count arithmetic but the determination of the centre of vital interests — and how to align it with the residency rules of each jurisdiction. Russia applies its centre-of-vital-interests criteria as a refining factor on top of the 183-day test. The EU country uses a combination of formal and factual indicators, weighted across housing, economic ties, and family circumstances. Montenegro draws on its own criteria, including physical presence and the centre of economic interests. Under each of these frameworks, the client could formally be treated as resident, and therefore obligated to declare worldwide income.

We analysed the reporting year under each of the three regimes separately: counted days of presence, mapped residential and commercial property in each country, examined the nature of business activity (where management decisions were taken, where key counterparties were located, where the main cash flow originated), assessed family and personal ties, and weighed each factor under the rules of each jurisdiction. The outcome was a coherent position: the country in which the client's centre of vital interests sat with the strongest evidentiary support, accompanied by a prepared line of argument in case either of the other countries raised claims. The return was filed in the country of actual residency; foreign accounts were declared correctly.

This type of work — establishing residency where several countries have real grounds to claim it — has become increasingly common for HNWI clients with assets and businesses spread across multiple jurisdictions. Often the client does not even know where they are formally resident and comes to us asking “what do I do about my return.” Our role is to assemble the facts of the year, apply the rules of all relevant jurisdictions, build the centre-of-vital-interests argument, and shape a defensible position before any of the countries begins to ask questions.

The client remains under our ongoing engagement.

A client who had invested in foreign real estate together with a co-investor decided to exit the project. The property had not been generating the expected income, and continuing to hold it no longer made sense. By the time we were engaged, a buyer had been found and the notarial documents were being drawn up — but several pressures had built up around the deal: the two investors' positions needed to be reconciled, the seller's bank wanted updated documentation on the origin of the property, the client's receiving bank wanted source-of-funds clarification before the funds arrived, and the entire package had to be assembled within the transaction window, without moving the closing date.

The tax side ran in parallel: taxation of the sale in the property jurisdiction, reporting in the client's country of residence, and aligning the two investors' positions so that each side received its share with a clear tax history. One of the banks mid-process requested an additional documentation pack that had not been foreseen — that had to be handled alongside the notarial preparation, without slipping the deadlines.

The transaction closed within its original window. The funds arrived in the client's receiving jurisdiction, the proceeds were distributed between the investors as agreed, and the tax position was settled in both countries.

This type of work is our home practice: we handle foreign real estate from inside the jurisdiction where the property is located, and we see the full chain — from sale preparation through to the moment the funds appear in the receiving account.