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🇵🇦 Panama’s Golden Visa: Permanent Residency and Citizenship Through Investment

Panama offers investors permanent residency under its Qualified Investor Visa program. The minimum investment is $300,000.

Processing time: from 3 months.

Investment Options:

$300,000 — real estate (residential or commercial).

$500,000 — Panamanian securities.

$750,000 — a fixed-term deposit with a local bank.

Key Advantages:

Permanent residency for 5 years from the outset
(No intermediate temporary residence permits required.) Processing takes 1–1.5 months. A quick one-week visit is required for biometrics.

Citizenship after 5 years
Visa-free access to 147 countries, including the Schengen Area, the UK, and Japan.

Freedom of movement
No residency requirements. Visiting Panama once every two years is sufficient.

Key Drawbacks for Russian Citizens:

Opening a bank or brokerage account using a Russian passport before obtaining residency is almost impossible. As a result, purchasing real estate is the only viable route for Russian applicants.

Panama is a relatively small country, and the supply of genuinely liquid real estate assets is limited.

Panama vs. Uruguay vs. Paraguay:

Banking
Panama is a major financial hub, ideal for international trade and managing foreign-source income.
Uruguay is too conservative, while Paraguay offers more limited opportunities, particularly for international business.

Residency
Panama offers the fastest route, but at a higher cost.
Uruguay and Paraguay have longer processes, but more affordable options are available.

Safety
Overall, Uruguay is safer.
In Panama, modern, well-developed neighborhoods are considered safe.
Paraguay lags behind, and expats tend to prefer living in gated communities.

Compliance and Crypto:

Residency makes banking easier, but compliance requirements are strict, including an in-person visit and comprehensive checks on the source of funds.

Panama is crypto-friendly, but its regulatory framework is still underdeveloped. For legalizing crypto wealth with a clean source of funds, El Salvador may be worth considering, as it has an official citizenship-by-investment program involving cryptocurrency.

Overall, Panama’s investment-based permanent residency is an option for high-net-worth investors seeking a backup destination, greater flexibility for international business and banking, no minimum-stay requirements, and potential tax efficiency.
WEEKLY NEWS

The key developments of the week in tax, offshore jurisdictions, and compliance

GSL, in collaboration with the Action Group, has developed a course titled: “VAT, Corporate Income Tax, Personal Income Tax, and Social Security Contributions: How to Optimize Your Tax Burden Without Fear of Tax Authority Challenges”

🇸🇪 Sweden proposes introducing a range of tax incentives to develop employees’ skills and potential.

🇦🇪 Dubai abolishes the minimum property value requirement for obtaining a two-year investor visa.

🇧🇪 On May 28, 2026, Belgium’s Council of Ministers gave the green light to a draft law on DAC9.

🇭🇺 Hungary has introduced an expanded form for paying the top-up tax.

🏳️ Panama has begun discussions on a draft law taxing foreign passive income derived from the activities of shell companies.

🏛️ The OECD has published a common agreement between implementing jurisdictions, along with additional administrative guidance to support compliance with the global minimum tax requirements.

🇭🇰 Hong Kong’s corporate redomiciliation regime: the first results.

🇪🇺 Ten European countries have concluded negotiations on a multilateral convention establishing an International Tax Dispute Resolution Commission.

🇺🇸 The US President has issued an executive order tightening customer due diligence requirements.

🇬🇧 The UK tax authority (HMRC) has published a policy paper outlining planned changes to the taxation of foreign permanent establishments.

🇹🇼 Taiwan reminds taxpayers of the approaching deadline for filing 2025 income tax returns.

🇹🇷 Turkey’s parliament has approved comprehensive reforms to support investment and manufacturing.

🇹🇷 Turkey’s tax authority has announced extensions to filing deadlines for several taxes.

🇬🇧 The UK proposes a new investment visa.
A Remote Worker’s Laptop as a Tax Trap for Your Business

A sales manager relocates to Barcelona and continues working remotely while the company remains registered in another jurisdiction.

Two years later, the Spanish tax authorities demand that the company pay corporate income tax. The reason? That very employee. Since the OECD updated its guidance on remote work, cases like this have become increasingly common.

This is a classic risk of creating a Permanent Establishment (PE).

How Does It Work?

Under Article 5 of the OECD Model Tax Convention, if an employee regularly acts on behalf of a company abroad, negotiating or concluding contracts, the business may establish a taxable presence in that country.

A physical office is not required: a remote worker’s home office can now also be considered a place of business for the company.

Which Employees Create Risks for the Company?

The biggest misconception is that only employees authorized to sign contracts pose a risk.

The OECD makes it clear: regularly negotiating the material terms of contracts may be sufficient.

High risk (external-facing roles): Sales representatives, account managers, senior executives, lawyers, and business development managers (BDMs). Anyone who negotiates deals, seeks partners, or prepares commercial proposals.

Lower risk (internal-facing roles): Developers, designers, and analysts. They perform internal tasks and do not create obligations toward third parties. However, they still need to monitor their personal tax residency status.

What Are the Potential Consequences for Your Business?

➡️ Mandatory tax registration in the country where the employee is located.

➡️ Corporate income tax on a portion of the company’s profits (25% in Spain; up to 33% in Germany, including municipal trade taxes).

➡️ A significant risk of double taxation, even where a Double Taxation Agreement (DTA) applies, as well as penalties for previous tax periods.

The Scale of the Problem: €500,000 in profits generated through a “high-risk” employee in Germany could result in up to €165,000 in unexpected taxes.

What Should Management Do?

- Audit the authority and responsibilities of all remote employees working abroad.
- Review the DTAs between the company’s country of registration and the countries where its employees actually work.
- Mitigate risks: where the exposure is high, consider moving employees to local contracts through a local legal entity or an Employer of Record (EOR) or B2B service provider.

Remote work does not eliminate tax geography. The question is not where an employee sits, but where the business is actually conducted.

If you are unsure about the status of your remote workers, it is time to investigate before a foreign tax authority does it for you.
Permanent Residency Without the Queue or Taxes: Paraguay’s New Investment Program

Paraguay has long been a quiet haven for those seeking a straightforward path to legal residency without excessive bureaucracy. But in April 2026, the country launched the official Paraguay Investor Pass program, offering investors a fast, business-oriented route directly to permanent residency.

3 Key Advantages Over Europe and the UAE

Low Investment Threshold
The minimum investment starts at $150,000. In Greece or Portugal, “Golden Visa” programs can cost between €250,000 and €800,000.

0% Tax on Foreign-Sourced Income
Paraguay applies the territorial tax principle. Income earned outside the country is not subject to local tax. The tax rate on domestic income is 10%, while the dividend tax rate for investors has been reduced from 15% to 8%.

Speed
Applications are currently submitted through a one-stop service center in Asunción, but the authorities promise to introduce a fully online application process by the end of 2026.

Where Can You Invest?

- $150,000 — in approved tourism projects.
- $200,000 — in the local stock market.
- $200,000 — in Paraguayan real estate.

All applicants undergo rigorous Source of Funds (SoF) and Source of Wealth (SoW) checks through the local anti-money laundering authority. Preparing the application package well in advance is essential.

The Budget Option: Business-Based Permanent Residency for $70,000

If you do not have $150,000 available, a traditional company-based program has been in place since 2013.

Requirements: You must register a company and commit to investing $70,000 in it over 10 years, while creating five jobs for local residents.

You do not need to show the entire amount in your bank account upfront. An adequate business plan is sufficient at the initial stage.

The Value of the Status: Why Do Investors Want a Paraguayan Passport?

Visa-Free Access to the EU and the UK
The Paraguayan passport consistently ranks among the world’s top 30 strongest passports. It provides visa-free access to more than 140 countries, including the entire Schengen Area and the UK. It also offers access to a simplified US visa application process, with B1/B2 visas available for up to 10 years, as well as visa-free travel to Taiwan.

Freedom Across Latin America (MERCOSUR)
Holders of Paraguayan permanent residency and citizenship can benefit from simplified procedures for traveling, living, and working in Brazil, Argentina, Uruguay, and other South American countries.

Banking
With Paraguayan permanent residency and a local ID card (cédula), you may find it easier to establish banking relationships internationally. Opening personal and corporate accounts in the EU and the US, as well as accessing payment service providers, can become more straightforward.

Citizenship and a Passport After 3 Years

You can apply for citizenship after three years of living in Paraguay with permanent resident status. However, there are a couple of important nuances:

➡️ Paraguay officially restricts dual citizenship. In practice, the authorities may be more flexible and rarely require formal renunciation of an existing passport. However, the risks under the laws of your country of origin must be assessed individually.

➡️ You will need to demonstrate basic Spanish proficiency (A1 level) and pass a simple test on Paraguayan history and law.

Investor Pass can be a useful tool if you are looking for a second residency status, a clear compliance framework, and a legal way to eliminate taxes on worldwide income.
Dubai: Real Returns vs. Marketing Hype

“This studio cost AED 480,000, and just a few months later, it was worth AED 800,000.”

Stories like these are common in Dubai’s real estate market. But where do genuine investment opportunities end and sales pitches begin?

In the latest episode of our “The World of Real Estate Investment” series, we take an honest look at the market and share insights from leading developer Azizi Developments.

- How to avoid delayed or stalled construction projects and check a developer’s track record.
- What returns look like today once the marketing hype is stripped away — and why investors continue to choose Dubai.
- How buyer protection actually works under UAE law.
- Which neighborhoods could gain momentum in the coming years — and where it may already be too late to invest.

▶️ Premiere today at 8:00 PM. Don’t miss it!
WEEKLY NEWS

The key developments of the week in tax, offshore jurisdictions, and compliance

🇮🇸 Iceland’s government has approved a new industrial policy setting out a long-term vision for economic growth, productivity, and competitiveness through 2035.

🏳️ Panama has adopted exemptions from economic substance requirements under its territorial tax system.

🇭🇰 Hong Kong has published the Stamp Duty (Amendment) (No. 2) Bill 2026.

🇰🇿 Hong Kong and Kazakhstan plan to hold negotiations on a tax treaty.

🇿🇦 The South African Revenue Service (SARS) has published new and updated guidance on filing and paying taxes under the Global Minimum Tax (GMT) framework.

🇬🇧 The UK tax authority (HMRC) has updated its guidance on disclosing tax avoidance schemes.

🇺🇸 The US Treasury Department and the Internal Revenue Service (IRS) have issued proposed regulations providing tax exemptions and transitional relief for sovereign investors.

🇨🇿 The Czech Republic has confirmed the adoption of the Side-by-Side Package, providing relief from penalties and protection against requirements to file a local GloBE information return.

🇳🇿 New Zealand is adding a donation option to its NZD 5 million “Golden Visa” program.

🇪🇺 The European Commission has confirmed that Cyprus has a qualified Income Inclusion Rule (IIR) under the EU’s Pillar Two Directive.

🇵🇱 Poland’s government has approved a further extension of temporary measures reducing fuel taxes.

🇪🇸 Spain has approved tax returns and guidance for reporting corporate income and non-resident income for 2025.

🇮🇹 The Court of Justice of the European Union has confirmed access to beneficial ownership information relating to trust arrangements in Italy.

🇹🇷 Turkey is introducing electronic document issuance through next-generation fiscal devices.

🇪🇺 The European Union intends to step up its fight against cross-border tax crimes involving VAT.
Compliance and KYC in 2026: How to Avoid Getting Blacklisted

Imagine the following situation.

You run an IT or trading company serving clients across Europe, Asia, and the CIS. Your company has been operating for several years, turnover is stable, and you hold accounts with several banks.

Another client payment of €20,000 arrives in your account.

Nothing unusual.

But a few hours later, the bank sends you a request for:

The contract with the client;

The invoice;

Proof that the services were delivered;

Information about the end customer;

An explanation of how your company generates revenue, as well as how you earn your own income as the owner.

Sound familiar?

In 2026, this is no longer an exception. It is the new reality.

Banks no longer limit their checks to the account-opening stage. Monitoring is now ongoing, and every transaction is assessed through a risk-based lens.

What Most Often Raises Red Flags?

A company develops software, but receives payments from dozens of counterparties across different countries for various reasons that do not clearly align with its stated business activities.

You live in one country, your company is registered in another, and your clients are based in a third.

Your account receives payments for consulting, marketing, or IT services, but the supporting documents are merely formalities or are missing altogether.

The account was used for small transactions for a long time, and then turnover suddenly increased.

Even if every transaction is entirely legitimate, the bank may simply fail to understand your business model.

That is when enhanced due diligence begins.

What Do Banks Request Most Often Today?

➡️ Contracts and invoices;

➡️ Proof of service delivery;

➡️ Tax returns;

➡️ Information about counterparties;

➡️ The business structure and source of funds.

One relatively new trend is requests for correspondence with clients, information from CRM systems to demonstrate that services were actually delivered, and detailed explanations of individual transactions.

In our experience, the problem for most clients is not the payments themselves. The problem is that they only start gathering documents after receiving a request from the bank.

What Works in 2026, Based on Our Experience?

We do not simply submit random applications to open bank accounts. We build a system designed to withstand compliance checks, drawing on more than 30 years of experience.

How does the process work?

We analyze the business structure and the flow of funds.

We prepare the supporting documentation in advance.

We select a bank or payment service provider that matches the client’s specific risk profile.

We establish backup banking infrastructure.

We provide ongoing support with annual reviews and responses to additional information requests.

In 2026, the winners are not simply those whose operations are “completely legal.”

They are the ones whose business activities are transparent to the bank and supported by proper documentation.
WEEKLY NEWS

The key developments of the week in tax, offshore jurisdictions, and compliance

🇰🇬 Cyprus and Kyrgyzstan have signed a tax treaty.

🇧🇴 Bolivia is introducing a tax relief program.

🇦🇺 The Australian Taxation Office (ATO) has issued general guidance on reporting income earned through digital platforms and apps.

🇺🇸 The US Internal Revenue Service (IRS) has outlined its activities in its report for fiscal year 2025.

🇧🇲 Bermuda is consulting on proposed amendments to the Corporate Income Tax Act and the Tax Credits Act.

🇹🇷 Turkey is implementing comprehensive reforms to support investment and manufacturing.

🇰🇾 A court ruling has confirmed that Cayman Islands courts can issue confidentiality orders in private trust proceedings.

🇦🇷 Argentina is extending the filing deadlines for individual income tax returns for the 2025 tax year.

🇸🇰 Slovakia’s Ministry of Finance has proposed amendments to the VAT Act.

🇹🇷 Turkey has ratified the Multilateral Competent Authority Agreement on the Exchange of GloBE Information.

🇬🇧 The UK is temporarily reducing VAT on family entertainment during the summer.

🇵🇹 Portugal is introducing tax measures to stimulate the housing market and increase the supply of affordable rental housing.
How Double Taxation Treaties Can Save Millions Through Careful Structuring

Here is a recent case from our practice that illustrates how it works.

Our client, a Cypriot company, needed to sell a major real estate asset in Montenegro. The property was held through a Montenegrin company.

The straightforward approach

A direct sale of the property would trigger capital gains tax in Montenegro at a rate of 15% — or potentially 30% if the owner is based in an offshore jurisdiction.

GSL’s legal solution

We identified a way to avoid the tax by selling the shares of the company that owns the property instead of selling the property itself. This is possible because the double taxation agreement (DTA) between Cyprus and Montenegro contains a gap.

Here is the logic:

➡️ Selling shares in a company that holds real estate on its balance sheet, rather than selling the property directly, is a classic tax planning mechanism. Countries are increasingly countering this approach through specific provisions, including those in double taxation treaties.

➡️ Most treaties contain a rule stating that if more than half of a company’s assets consist of real estate, gains from selling its shares may be taxed in the country where the property is located, just as if the property itself had been sold.

➡️ However, the DTA between Cyprus and Montenegro does not contain this rule. We therefore structured the transaction so that the capital gains tax in Montenegro would be 0%.

This is not limited to Cyprus

Similar gaps can still be found in Montenegro’s tax treaties with:

Russia, the United Kingdom, the Netherlands, Turkey, the Czech Republic, Sweden, Poland, Malta, Denmark, Austria, Belgium, Kuwait, and other countries.

However, caution is essential: some treaties have already closed this loophole. For example, under Montenegro’s agreements with the UAE, Latvia, Slovakia, and Monaco, selling shares in a company that owns real estate can still trigger tax in Montenegro.

Important considerations and risks

1. Don’t restructure solely for a single transaction.

Changing a company’s tax residency to Cyprus for the sake of one deal is generally not worthwhile given the administrative burden and other tax costs associated with Cyprus. We recommend considering this opportunity much earlier, when planning the ownership structure.

2. The MLI factor.

The Multilateral Instrument (MLI) allows participating jurisdictions to modify their tax treaties without renegotiating each agreement individually. Its provisions may close such gaps automatically, depending on the countries’ positions and the applicable treaty provisions. We recommend monitoring these developments continuously.

3. The risk of reclassification.

Tax authorities may argue that a share sale should be treated as a direct sale of the underlying real estate. Although the likelihood of this may currently be considered low in some circumstances, the risk must be assessed against the applicable legislation and case law.

Every case must be analyzed individually, taking into account:

- The parties involved in the transaction;
- The location of the property and the applicable domestic laws;
- The MLI provisions applicable to the jurisdictions concerned.

In international tax planning, some of the most interesting opportunities arise at the intersection of domestic legislation and international tax treaties.

What appears to be an unavoidable tax of 15% or 30% may sometimes be reduced to 0% through a lawful and carefully designed transaction structure.
Cyprus Offers Up to €32,000 for Home Renovations: What Is the Program and Who Is Eligible?

The Cypriot government, in cooperation with the European Union, has launched another phase of its home energy-efficiency subsidy scheme, “Save and Upgrade Your Home.”

The program has a total budget of €70 million. On May 15, 2026, Cyprus’s Ministry of Energy announced the third round, with a budget of €20 million. Applications are scheduled to open in September 2026.

The government will reimburse part of the renovation costs if the work improves the energy efficiency of a house or apartment.

What Renovation Works Are Eligible for Subsidies?

The program has two main categories:

1. Building Improvements (maximum subsidy: €32,000)
Wall, floor, and roof insulation; replacement of window frames; and installation of external shading systems.

2. Engineering Systems (maximum subsidy: €24,000)
Purchase and installation of solar thermal collectors for hot water, air conditioners, heat pumps, and high-efficiency boilers.

The exact figures for this round will be published in September. Based on previous rounds, the government reimbursed around 60% of eligible costs for standard applications and 80% for preferential categories, including low-income households, residents of the Troodos mountain region, and Greek Cypriot refugees.

Who Can Apply?

The program is open to individuals who own residential property and plan to renovate it. Each applicant may submit only one application per round.

Property Eligibility Criteria:

- The property must be owned by a private individual.
- There must be a valid household electricity bill issued in the individual’s name.
- The property must have been first connected to the electricity grid before January 1, 2008, or its building permit application must have been submitted before December 21, 2007.
- The property must not be used for commercial activities.

How Can You Apply?

1. Obtain an initial Energy Performance Certificate (EPC)

The certificate must be issued by a certified professional listed in the Energy Service’s official register. It must be dated strictly after May 15, 2026; earlier certificates will not be accepted. Renovation work may begin only after the certificate has been obtained.

2. Ensure energy savings

The main condition for receiving the subsidy is that the renovation must reduce primary energy consumption by at least 60% compared with the original level. Once the work is complete, a final certificate must confirm that this target has been achieved.

3. Submit an application

Applications are scheduled to open in September 2026 through the Ministry’s official portal. Detailed guidance, including the subsidy rates, will be published at the same time.

Important: The program does not provide advance payments. Applicants must initially pay for all renovation work out of their own funds. The government reimburses the approved portion of the costs only after the completed property has been inspected.
WEEKLY NEWS

The key developments of the week in tax, offshore jurisdictions, and compliance

🇺🇾 Uruguay announces rules for taxing individuals’ income from foreign sources.

🇱🇰 Sri Lanka amends its tax legislation.

🇭🇰 Hong Kong’s government announces an action plan to promote the development of corporate treasury centers in Hong Kong.

🇬🇬 Guernsey publishes its 2026 tax reform package.

🇹🇷 Turkey introduces a 20-year income tax exemption for eligible foreign nationals.

🇰🇬 Kyrgyzstan ratifies a new tax treaty with Japan.

🇱🇺 Corporate taxation in Luxembourg.

🇷🇴 Romania amends its e-invoicing rules for B2C transactions.

🇬🇧 Mandatory financial reporting requirements for small UK companies are postponed by one year.

🇵🇭 The Philippines issues additional guidance on VAT for digital services.

🇸🇬 Singapore introduces a simplified regulatory framework for family offices.

🇷🇴 Romania introduces an amendment to simplify the RO e-Factura system.

🇸🇰 Slovakia proposes a postponement of the upcoming mandatory e-invoicing requirements.

🇭🇰 Hong Kong and Cyprus sign a tax treaty (with photos).

🇳🇴 Norway launches a consultation on implementing the Side-by-Side Package under Pillar Two.
IP Ownership When Relocating Your Business Abroad

When relocating an IT business overseas, founders often make a critical mistake: they move the legal entity and the team but forget about intellectual property (IP).

If the software, brand, or patents are not legally transferred, you risk losing control over the company’s most valuable assets.

Here’s how to secure ownership of your product and legally reduce your tax burden.

How to Transfer Your IP Properly

1. Inventory

Identify all IP assets, including trademarks, patents, and source code. Check whether ownership has been legally established and whether all documents involving previous contractors and developers are properly executed.

2. Transfer

Transfer the IP to a company in the new jurisdiction. This can be done either through a full assignment of rights or through a licensing agreement.

3. Registration

Protect your assets in each target country or obtain international registration under the relevant conventions.

Do not postpone registration. In many jurisdictions, the “first to file” principle applies: whoever files the application first may secure the relevant rights.

Developer Contracts: Why an Invoice Is Not Enough

A common scenario: a freelance remote developer based in another country writes your software. Is paying their invoice enough to make the code the company’s property?

❌ No. Absolutely not.

To protect your asset, you need a comprehensive contract — an IP Assignment Agreement. For the code to legally belong to your company, the agreement should include:

- An unequivocal assignment of rights (Assignment / Transfer of Rights).
- Clearly defined territorial scope and duration of the rights.
- A Waiver of Moral Rights. This is a critical requirement in common-law jurisdictions such as the US and UK, where legally permissible. The developer should formally waive or agree not to assert claims relating to moral rights, such as attribution and certain rights concerning modifications or publication, to the extent permitted by applicable law. In civil-law jurisdictions, similar arrangements may take the form of broad consent to use and modify the work, where permitted.

Can you start selling software through a new legal entity in the UAE or Cyprus if it was originally developed under your previous company?

Not without a legally valid transfer of rights (Step 2) and any required registrations or record updates (Step 3). Otherwise, the new entity may be using IP without the necessary authorization, potentially creating serious legal exposure.

How Can You Legally Reduce Taxes on IP Income?

With the right compliance framework, international IT jurisdictions may offer substantial tax incentives.

Cyprus (effective rate potentially as low as 2.5%)

Cyprus operates an IP Box regime. To qualify, the software must meet the applicable development and nexus requirements, and the asset must fall within the category of qualifying assets. The tax benefit depends on the qualifying income and eligible R&D expenditure; a local office and development team alone do not guarantee the preferential rate.

UAE (0% on qualifying income)

Free zone companies may benefit from a 0% corporate tax rate on qualifying income, subject to the relevant conditions. Companies must meet applicable requirements, including adequate economic substance, where required.

Malta (effective tax rate potentially around 0%–5% in certain cases)

Malta operates a tax refund system. A company generally pays the standard 35% corporate tax rate, after which shareholders may be eligible for a substantial refund following a dividend distribution. The effective rate depends on the applicable refund mechanism and the circumstances.

Technical and Legal Measures to Prevent IP Leakage in Remote Teams

When your team is spread across multiple countries, protecting your product depends on three key pillars:

- Strong contractual safeguards: Well-drafted developer agreements and a clearly defined IP ownership structure.
- Access control and infrastructure security: Implement the principle of least privilege, use VDI / Cloud Workstations where appropriate, and secure Git repositories end to end.
- Data and code protection: Mask or anonymize sensitive data (Data Masking / Anonymization) and consider embedding traceable, discreet watermarks in source code (Watermarking).

Relocating your business is not just about moving the company and its people. Your IP ownership, contracts, tax structure, and security controls must move with it.
Alternatives to the UAE: Can Mauritius, Bahrain, and Russia’s Special Administrative Regions Replace Dubai?

The UAE’s “golden age” as an unquestioned tax-free haven is evolving. An increasingly clear trend is emerging: businesses are looking for alternative jurisdictions. There are three fundamental reasons for this shift:

1. Introduction of corporate tax (9%) — the era of “zero taxes” is over. The rate may seem modest, but tax administration, auditing, and transfer pricing requirements have made doing business more complicated.

2. Increasingly demanding banking compliance — opening a corporate bank account in the UAE has become a challenge for companies with Russian citizens among their owners or stakeholders.

3. The cost of maintaining a company — office rent (physical presence and substance are strictly monitored), employee accommodation, license renewals, and visa costs make the UAE a relatively expensive location for small and medium-sized businesses.

None of the alternatives under discussion offers Dubai’s versatility, where a single jurisdiction combines:

- a strong passport;
- the status of a “neutral haven”;
- a developed banking sector;
- a global logistics hub.

Relocating a corporate structure to Mauritius, Bahrain, or a Russian Special Administrative Region (SAR) always involves trade-offs and a focus on specific niches.

Nevertheless, let’s take a closer look at each option.

🇲🇺 Mauritius

➡️ Tax incentives combined with strict compliance requirements.

➡️ The jurisdiction positions itself as an established financial hub but requires full transparency of operations.

➡️ The standard corporate income tax rate is 15%, while eligible export-oriented companies may benefit from a reduced rate of 3%.

Potential pitfalls: Access to tax incentives depends heavily on substance requirements. Companies may need to lease actual office premises, hire local employees, and demonstrate that business operations are genuinely managed from the island.

Local banks apply particularly stringent AML/KYC screening procedures.

Best suited for: Large international holding companies, investment funds, and ultra-high-net-worth individuals (HNWI).

🇧🇭 Bahrain

Bahrain has traditionally been regarded as a jurisdiction with no corporate income tax for many businesses. There is still no personal income tax. However, a 15% minimum tax applies to certain large multinational enterprise groups.

A major tax reform is underway, and requirements for international businesses are becoming stricter.

Bahrain offers an excellent base for trade across the Middle East, but its evolving legislation calls for caution when developing tax-planning strategies.

🇷🇺 Russia’s Special Administrative Regions (Russky Island and Oktyabrsky Island)

A domestic mechanism for redomiciling foreign companies into the Russian legal system.

Significant tax incentives: Corporate income tax and taxes on incoming and outgoing dividends may be reduced to as low as 0%, subject to applicable requirements.

High entry threshold: This option is generally inaccessible to small and medium-sized businesses. Applicants must invest at least RUB 300 million in the region, hire at least 15 local employees, and ensure that genuine management takes place within the SAR.

Best suited for: Large Russian businesses and industrial groups.

Our conclusion: Mauritius, Bahrain, and Russia’s SARs are unlikely to replace Dubai on a broad scale as a versatile global hub. However, each jurisdiction can be an effective solution for specific, narrowly defined business needs.
WEEKLY NEWS ROUNDUP

The key developments of the week in tax, offshore jurisdictions, and compliance.

🇳🇱 The Netherlands announces preliminary measures under its 2027 Tax Plan package.

🇬🇧 The UK’s updated anti-money laundering rules come into force on June 30.

🇰🇿 Kazakhstan approves a list of IT goods exempt from VAT on imports by Astana Hub participants.

🇱🇺 Luxembourg’s Ministry of Health and Social Security publishes updated social security parameters.

🇦🇺 Australia’s Prime Minister announces capital gains tax relief measures for discretionary trusts.

🇵🇰 Pakistan’s Finance Minister presents the federal budget for the 2026–2027 fiscal year to the National Assembly on June 12, 2026.

🇳🇱 Corporate taxation in the Netherlands.

🇵🇹 Portugal extends the deadline for filing corporate income tax returns to June 30.

🇭🇰 Hong Kong tightens the requirements for the automatic exchange of financial account information.

🇹🇷 Turkey updates its guidance on accommodation tax.

🇮🇪 Ireland’s National Risk Assessment prompts the development of a comprehensive action plan.

🇦🇿 The Republic of Azerbaijan and the United Kingdom hold the first round of discussions on a new double taxation agreement.

🇧🇪 Belgium confirms the adoption of a common agreement to waive penalties and refrain from introducing a local GloBE information return filing requirement.

- The FATF updates its “grey list.”

🇲🇹 Malta launches an online process for changing VAT registration status.
Business Without People: Argentina Could Become the First Country in the World to Legalize Companies Run Without Human Management

In June 2026, Javier Milei’s government submitted a bill to Congress proposing the creation of non-human corporations — companies that could be managed by AI agents without directors or a board of directors. This would be the world’s first attempt to legally recognize businesses operating without humans in their governing bodies.

For the past 15 years, the OECD, tax authorities, and banks have been moving in the same direction: requiring companies to prove that real people are managing them.

That is precisely why substance requirements emerged, including the need for directors, employees, office premises, and evidence of genuine management.

The entire modern system of international tax oversight is built on one fundamental assumption: there is always a human being behind every company.

Milei’s initiative challenges this principle for the first time.

If a government officially recognizes that a company can be managed by AI, a question arises:

Why do we need directors, board meetings, proof of the place of effective management, and many other elements of traditional substance?

Argentina is proposing not merely a new corporate structure, but an alternative philosophy of corporate law. That is why the biggest challenge may emerge not for tax authorities, but for banks.

Today, compliance procedures revolve around several key questions:

- Who controls the company?
- Who makes the decisions?
- Who bears responsibility?
- Who should be screened against sanctions lists?

If the answer becomes “an algorithm,” a significant portion of conventional KYC and AML procedures may lose their purpose.

That is why the success of this model could trigger changes far more profound than the emergence of yet another low-tax jurisdiction.

The question is no longer where a company is located. The question is whether a company needs a human being to manage it at all.

Who would be interested in this, and why?

AI startups — today, early-stage companies often have to build a full corporate infrastructure before generating any revenue. This model could potentially reduce substance-related costs.

Crypto projects — many are already effectively governed by algorithms, yet legislation still requires formal governing bodies.

Autonomous trading systems — investment decisions in these structures are often made automatically.

Fully digital businesses — services whose operations are not tied to a particular country, office, or workforce. For them, substance requirements can often be one of the most expensive elements of a corporate structure.

What about liability?

It remains unclear how this model would work in practice. However, global experience suggests that when an algorithm cannot be held legally accountable, liability is usually shifted to a human being or to available capital.

Three broad approaches are therefore likely to emerge, potentially alongside other safeguards:

- Ultimate beneficial owner liability.
- A mandatory “human guarantor.” Instead of a director, the company would appoint a specially designated responsible person who would not participate in day-to-day operations but would be required to interact with banks, regulators, and courts.
- Mandatory risk insurance.
- Guarantee deposits or reserve capital.
- AI developer liability. This is the most controversial option. If an error results from a model’s architecture or training, some liability could potentially shift to the algorithm’s developer. Similar reasoning is already being discussed in the regulation of autonomous vehicles.

Similar questions have already arisen in the crypto industry.

In practice, regulators almost always seek to identify a specific person or a source of compensation for any resulting damage.

Complete anonymity is unlikely. Based on the bill’s proposed concept, ultimate beneficial owners would still have to be disclosed.

The likely formula would look like this:

- Management — AI
- Directors — none
- Ultimate beneficial owner — identified

If the initiative becomes operational, the market may gain not another offshore jurisdiction, but an entirely new format for corporate structures.

What do you think? Share your predictions in the comments.
A Co-Founder of a Foreign Company Has Disappeared. What Should You Do?

A partner’s disappearance is a critical operational risk that can bring a business to a standstill overnight.

To develop an action plan, it is essential to distinguish the missing partner’s roles. The options for saving the company depend fundamentally on whether the person was a shareholder, a director, or both.

What are the risks if a business partner disappears?

Scenario A: The partner is only a founder or shareholder (equity owner)

In this case, day-to-day operations may continue, but the company inevitably faces several challenges:

➡️ Strategic decision-making may be blocked.

➡️ Major commercial transactions may be delayed or postponed.

➡️ The company’s bank account may be at risk of being frozen.

➡️ Profit distributions may become impossible.

Scenario B: The partner is also a director (the primary authorized signatory and key decision-maker)

This is a critical situation. The company’s administrative and commercial operations may be effectively paralyzed, making it impossible to:

➡️ Sign routine commercial and corporate documents.

➡️ File mandatory financial statements and tax returns on time.

➡️ Renew corporate licenses, where applicable.

➡️ Complete required bank account updates and verification procedures.

The consequences: Missed deadlines can lead to rapidly accumulating penalties and the risk of the company being forcibly removed from the official register (striking off).

Can you remove or dismiss a business partner unilaterally?

If the person is a director — potentially yes, if the required voting majority is available.

The procedure for removing a director is governed by local company law (such as the Companies Act in the UK or Cyprus) and/or the company’s constitutional documents.

Legally, replacing a director may be relatively straightforward, but the risk of subsequent objections or legal challenges must always be considered.

You should formally document all attempts to contact the missing partner in writing, closely monitor reporting deadlines, and promptly engage a corporate lawyer in the company’s jurisdiction of incorporation.

🚫 If the person is a shareholder — generally, no.

Shares are private property. A person cannot ordinarily be deprived of ownership without their consent or a court order.

Available options include: initiating court proceedings, pursuing a voluntary buyout, or activating specific protective mechanisms if they were предусмотрены in advance in the shareholders’ agreement.

What if the partner’s involvement is urgently required?

Contact the corporate secretary or registered agent.

- Build an evidentiary record. Keep copies of correspondence, notices, and documented attempts to establish contact.
- Contact the company registry. Clarify the available procedures and any applicable deadlines.
- As a last resort, seek judicial intervention. A court may be able to provide a solution where ordinary corporate procedures are no longer workable.

Preventive compliance: How can you protect your business in advance?

Prepare a comprehensive shareholders’ agreement. This is where mechanisms for dealing with a partner’s disappearance should be established. Consider including the following provisions:

Extended absence clause: If a shareholder fails to respond for more than an agreed number of days, the remaining shareholders may be permitted to take specified actions without them, subject to applicable law.

Compulsory buyout mechanism: The other shareholders may be given the right to acquire the missing shareholder’s stake according to a pre-agreed formula, subject to the agreement’s terms and applicable legal requirements.

Deadlock clause: Establish a procedure for resolving deadlocks, such as negotiations, professional mediation, and, if necessary, a buyout or auction among the shareholders.
WEEKLY NEWS ROUNDUP
The key developments of the week in tax, offshore jurisdictions, and compliance.
🇸🇦 Saudi Arabia extends its tax penalty exemption initiative through the end of 2026.
🇯🇪 Jersey consults on expanding the role of limited liability companies (LLCs).
🇺🇿 Uzbekistan introduces new tax incentives to support arts and culture.
🏛️ The OECD announces the publication of Revenue Statistics in Asia and the Pacific 2026.
🇬🇧 The UK tax authority consults on proposed changes to the rules governing the taxation of distributions to shareholders.
🇬🇷 Greece extends the deadlines for filing GloBE information returns and notifications.
🇹🇷🇺🇿 Turkey and Uzbekistan conclude negotiations on a social security agreement.
🇭🇰 Hong Kong updates its lists of debt instruments and sovereign bonds eligible for profits tax concessions or exemptions.
🇦🇱 Albania plans to increase property taxes.
🇦🇹 Corporate taxation in Austria.
🇪🇸 Spain amends non-resident income tax return forms.
🇻🇳 Vietnam extends tax payment deadlines in 2026.
🇧🇷 Brazil introduces new mandatory crypto-asset reporting requirements, effective from July.
🇿🇦 South Africa’s Constitutional Court clarifies the application of the zero-rated VAT treatment to gold.
🇮🇪 Ireland’s National Money Laundering Risk Assessment prompts the development of a comprehensive action plan.
“They’re Giving Away Half a Billion Euros”

Greece Launches a Record-Breaking Housing Renovation Subsidy Program

The Greek government has allocated €500 million to a major renovation initiative called Renovate (Anakainizo).

The goal is straightforward: modernize the country’s aging housing stock and bring vacant houses and apartments back onto the market. And here’s an important detail for investors: applications are open not only to Greek citizens but also to foreign property owners.

If you own an older property acquired under the Golden Visa program or an apartment that has been sitting empty, this could be an opportunity to renovate it with government support.

Which properties are eligible?

The program covers apartments in multi-unit residential buildings and standalone houses. However, the eligibility criteria are strict:

➡️ The property must be officially classified as residential and have remained vacant for the past year.

➡️ The building permit must have been issued strictly before December 31, 1990.

➡️ The property must have a floor area of no more than 120 sq. m. (The limit rises to 150 sq. m for large families.)

➡️ Applicants’ incomes must not exceed the established thresholds (for example, €35,000 for married couples).

How much money can you actually receive?

Payments are made through the Gov.gr portal based on completed renovation work.

- The government reimburses up to 90% of renovation costs.
- The maximum grant per property is €36,000, calculated at up to €300 per square meter.
- The amount depends on the region and household composition. For example, properties on islands and large families qualify for an additional 5%.
- An advance payment of up to 50% may be available.

You cannot use the money simply to redecorate, install new laminate flooring, repaint walls, or replace kitchen cabinets. The program strictly regulates how the budget must be allocated: 60–80% must go toward general renovation work, such as replacing plumbing and electrical systems and upgrading waterproofing, while the remaining 20–40% must be spent on energy-efficiency improvements, including wall insulation, new double-glazed windows, and solar water heaters.

The ultimate goal is to improve the property’s energy-efficiency rating.

Is Airbnb rental really prohibited?

Yes. The program completely prohibits short-term rentals. Property owners must sign an undertaking that, following renovation, the property will either be used as a private residence or rented out on a long-term basis for at least five years.

Your action plan: How to apply

Funding is allocated on a first-come, first-served basis. Here’s how the process works:

1. Prepare your documents

You will need Taxisnet credentials (for Greece’s tax system), the property’s ATAK cadastral identification number, and an E9 property declaration extract.

2. Complete the preliminary eligibility check

The Gov.gr portal automatically verifies the relevant information, including income, the property’s residential status, and the date the building permit was issued.

3. Submit your application and renovation budget

If you pass the initial screening, you must upload a detailed cost estimate showing how the funds will be allocated between general construction work and energy-efficiency improvements.
How to Open a UAE Bank Account for an Export Business After a Categorical Rejection

After a month and a half of exhausting waiting and endless checks, a major UAE bank delivers its verdict: an outright rejection.

An international business belonging to a major exporter is at risk of grinding to a complete halt.

Many people still believe that a second passport or a business license in a supposedly more accommodating free zone automatically opens every door in the Emirates. This is a myth.

➡️ Local compliance departments are tightening controls amid fears of secondary US sanctions. If a bank sees even the slightest risk to its US correspondent banking relationships, your application may be rejected immediately.

Here’s how the GSL team helped a client navigate an exceptionally difficult situation after the doors of first-tier banks had nearly closed.

The starting point: Assets, passports, and hidden red flags

Our client was a major Russian seafood exporter with a fully integrated business, from fishing and processing to international trade. The beneficial owner was a Russian and Turkish citizen holding UAE residence status. The key export markets were Norway, the Netherlands, and the UAE.

We initially faced three objectives:

- Move the business from the expensive JAFZA free zone to a more cost-effective and straightforward alternative.
- Register a new company under the beneficial owner’s exclusive 100% control.
- Minimize the company’s Russian connections as much as possible by registering the business using the Turkish passport and operating without direct payments from Russia, through a Dubai-based payment agent.

Why was the application rejected?

In late 2023, Russian fish products became subject to stringent US sanctions. Although the client’s company did not trade with the United States at all, the UAE bank — which had already successfully maintained an account for the client’s existing corporate structure — became concerned about the risk of secondary sanctions.

After a month and a half of silence, the bank issued a firm rejection for the new company.

How to restructure a case when a project reaches a dead end: Our strategy

Once the first bank had shut its doors, we realized that following standard templates would be pointless. GSL’s experts completely redesigned the strategy and launched a second attempt through alternative banking channels.

❌ Challenging the first bank’s decision would have wasted precious time while the business remained idle. Instead, we immediately redirected the application to another bank operating in the same market but with a more flexible compliance approach.

We rebuilt the company’s business and investment profile from scratch. We removed references that could trigger additional scrutiny related to Russia and focused the presentation on the beneficial owner’s international trading activities in his capacity as a Turkish citizen.

In practice, the fish originated in Russia, but shipments to Europe were operationally handled through a Turkish agency company.

We reviewed a substantial volume of shipping documents, including bills of lading and invoices, and submitted documentation intended to demonstrate the legitimacy of the international trading operations and address the bank’s compliance concerns.

The result speaks for itself

The new bank approved the application in a short time.

An account was opened for a company operating in a sector that could be perceived as high-risk in the UAE.

Payments under international contracts resumed, and the client’s business continued operating without interruption.

The key takeaway for international businesses

The UAE remains a major hub for international financial flows, but the era of simple, straightforward solutions is firmly behind us.

Holding a Turkish or any other passport perceived as more favorable no longer guarantees success. Today, opening a bank account depends heavily on the quality of the documentation, the transparency of the business model, and how effectively the case is presented to the bank.

If your business operates in a sector exposed to potential sanctions risks, or you have already faced rejections from foreign banks’ compliance departments, do not put your company’s track record at risk.

Every additional rejection may complicate future banking applications in the region.

Contact our experts to discuss your case.
No Renders, No Presentations: How Major Investors Buy Into Dubai Before the Official Launch

Today at 8:00 PM — the premiere of a new episode in our World of Real Estate Investment series.

In Dubai’s maturing property market, traditional strategies based on selecting properties from glossy marketing brochures are no longer enough.

Today, the most liquid premium properties are increasingly snapped up behind closed doors — before developers release official price lists and final renders.

Can private investors safely enter a project at this stage? And how do pre-sales work when it comes to protecting capital?

In our new interview with an official representative of Ellington Properties, we take a behind-the-scenes look at private property sales in the UAE.

The phenomenon of private reservations

Why are experienced investors willing to sign documents before the official sales launch?

How EOI (Expression of Interest) works

How does this instrument work, what does participation cost, and how can investors position themselves to secure the best layouts ahead of the competition?

Capital protection

How do escrow accounts actually work in the UAE, and what legal safeguards does the government provide to foreign property buyers?

Case study: Playa Del Sol

Why has this particular project generated unprecedented investor interest, and what lessons should the market draw from this case right now?

Reputation vs. appearance

Why can relying on beautiful renders lead to costly mistakes, and which metrics should investors use to assess a developer’s actual reliability?

This episode will be useful both for those seeking to preserve capital in a stable foreign currency and for investors planning to relocate assets to the Middle East.

🕗 Premiere today at exactly 8:00 PM!

📺 Watch the episode on YouTube.
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