Frequently Asked Questions
Everything you need to know about our services, tax residency planning, corporate structuring, and working with ITA.
ITA provides a full range of international tax advisory services, including:
- International Corporate Structuring — holding companies, IP structures, cross-border M&A
- Personal Tax Relocation — NHR Portugal, Italy Flat Tax, Spain Beckham Law, UAE residency
- US–Italy Tax Compliance — dual filers, FATCA, FBAR, treaty planning
- Estate & Wealth Planning — cross-border succession, trusts, family structures
- Tax Dispute & IRS Representation — audits, appeals, voluntary disclosure
- Real Estate Tax Advisory — cross-border property investment planning
Yes. We advise both high-net-worth individuals (entrepreneurs, executives, digital nomads, US expats) and corporate clients (multinationals, startups, family offices, private equity groups) across all our service lines.
Our core expertise covers the United States, Italy, the European Union (Portugal, Spain, Greece, Netherlands, Ireland, Luxembourg, Malta), the United Kingdom, and key Asian hubs (Singapore, Hong Kong, UAE/Dubai).
For offshore jurisdictions (BVI, Cayman, Delaware, Wyoming, Panama), we work with a trusted network of local counsel.
Our process is straightforward:
- Step 1 — Free Initial Call (30 min): We discuss your situation, objectives, and whether we are the right fit.
- Step 2 — Engagement Letter: We send a clear proposal outlining scope, deliverables, and fees.
- Step 3 — Analysis & Strategy: We prepare a detailed tax analysis and actionable recommendations.
- Step 4 — Implementation: We assist with filings, incorporations, registrations, and ongoing compliance.
All consultations are strictly confidential and protected by professional privilege.
Yes. Many of our clients engage ITA on a monthly retainer basis for ongoing tax advice, compliance management, and strategic planning. Retainers are tailored to each client’s complexity and volume of work. Please enquire during your initial consultation.
Tax residency determines which country has the right to tax your worldwide income. Moving to a different tax jurisdiction can significantly reduce your effective tax rate — but it must be done correctly, with genuine physical presence, substance, and compliance with exit rules in your home country.
Getting it wrong can result in double taxation, penalties, or deemed continued residency in your original jurisdiction.
The most competitive EU regimes in 2026 are:
- Portugal (NHR 2.0 / IFICI): 20% flat tax on qualifying Portuguese income, exemption on most foreign income — for qualifying professionals and researchers.
- Italy (Flat Tax Regime): €100,000 annual lump-sum tax on all foreign-source income — ideal for HNW individuals with significant overseas wealth.
- Greece (7% Pension Regime): 7% flat tax on foreign pension income for 15 years.
- Spain (Beckham Law): 24% flat rate on Spanish income for qualifying employed expatriates.
- Malta (Global Residence Programme): 15% minimum tax on remitted foreign income.
The best option depends entirely on your income profile, nationality, and objectives. We provide personalised analysis for each client.
Yes, but with important caveats. The US taxes its citizens on worldwide income regardless of residence (citizenship-based taxation). This means that even if you move to Italy and pay the €100,000 flat tax, you still have US filing obligations — including Form 1040, FBAR, and FATCA forms.
However, with careful treaty planning, the Foreign Tax Credit and Foreign Earned Income Exclusion can significantly reduce or eliminate double taxation. ITA specialises in exactly this type of US–EU dual compliance planning.
Many countries impose an exit tax when you cease tax residency — a deemed disposal of assets at fair market value on the date of departure. Key examples:
- United States (Section 877A): Applies to “covered expatriates” with net worth ≥ $2M or high average tax liability who renounce citizenship or abandon a long-term Green Card.
- Italy: Deemed disposal of business assets and shareholdings on exit.
- Germany, France, Netherlands: All have exit tax regimes on unrealised capital gains.
Pre-departure planning is essential to minimise exit tax exposure. ITA advises on timing, asset restructuring, and treaty relief before you move.
An international holding company is a legal entity incorporated in a tax-efficient jurisdiction that owns shares in operating subsidiaries across multiple countries. It can centralise dividend flows, capital gains, and IP income — and reduce overall group tax exposure.
You may benefit from a holding structure if you own businesses in multiple countries, receive significant dividend or royalty income, or plan to sell a company in the future. ITA analyses whether the benefit justifies the setup and compliance cost for your specific situation.
The optimal jurisdiction depends on your business, shareholders, and target markets. The most commonly used are:
- Netherlands: Participation exemption on dividends and capital gains, extensive treaty network.
- Ireland: 12.5% corporate rate, EU access, strong treaty network, English law.
- Singapore: 17% headline rate with extensive exemptions, 90+ treaties, excellent for Asia-Pacific.
- UAE (Dubai): 0–9% corporate tax, no withholding tax on dividends — requires genuine substance.
- Wyoming (US LLC): Pass-through taxation, privacy, low cost — ideal for certain non-US entrepreneurs.
Since 2024, OECD Pillar Two limits the benefits of zero-tax jurisdictions for groups with revenue above €750M. We factor this into all structuring advice.
Substance refers to genuine economic activity in a jurisdiction — local directors, employees, office space, board meetings held locally, and real management decisions made there. Tax authorities worldwide now require substance to recognise the tax benefits of a structure.
A holding company incorporated in Ireland or Singapore with no local presence, no local directors, and no real activity is increasingly vulnerable to challenge under anti-avoidance rules, CFC legislation, and the OECD Principal Purpose Test (PPT). ITA helps clients build and document appropriate substance from the outset.
Both are excellent jurisdictions, but they serve different purposes:
- Hong Kong is better if your primary market is mainland China — direct RMB access, CEPA benefits, and no GST.
- Singapore is better for broader Asia-Pacific coverage, IP-intensive businesses, and groups needing a wider treaty network (India, ASEAN, Middle East).
Many sophisticated groups use both in tandem. Read our full comparison article on the Insights page.
We offer a free 30-minute initial consultation to understand your situation and determine whether we can help. There is no obligation and no cost for this call.
For paid engagements, our fees depend on the complexity and scope of the work. We always provide a clear written proposal before any work begins — no surprises.
We offer both models depending on the engagement:
- Fixed fee: For defined-scope projects (e.g., tax residency analysis, company incorporation, compliance filing). You know the cost upfront.
- Hourly rate: For advisory work where scope may evolve (e.g., complex restructuring, ongoing retainer, dispute representation).
- Monthly retainer: For clients requiring regular ongoing advice and compliance management.
Absolutely. The majority of our clients are based internationally — in the US, Italy, Europe, the Middle East, and Asia. We work entirely remotely via video call, email, and secure document sharing. All documents can be signed electronically.
We have physical offices in New York, Milan, London, Hong Kong, Shanghai, and Miami for clients who prefer in-person meetings.
Yes. All client information is treated with the strictest confidentiality. Our engagements are protected by professional privilege where applicable. We are fully GDPR-compliant and never share client data with third parties without explicit consent. You can review our Privacy Policy for full details.
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