The IBSA Club Podcasts

Cyprus has become a magnet for people who want a clean break from high-tax complexity without giving up access to Europe, but the real story is more nuanced than a single “low tax” headline. We sit down with Theodora Alexandrou of Elias Neocleous Co. in Limassol to explain how Cyprus tax planning actually works when you zoom in on the rules that matter: immigration permission, tax residency tests, treaty access, and the incentives that can stack together if you plan the move early.

We walk through the practical immigration routes a UK national typically considers today, including the Cyprus golden visa with a €300,000 investment, temporary residence permitting employment, and the Business Facilitation Unit pathway for companies of foreign interest. From there, we break down the Cyprus 183-day rule and the Cyprus 60-day rule, including the “permanent home” and employment or office requirements, the limit on spending more than 183 days in another country, and why treaty tie-breakers may still decide the outcome if another jurisdiction also claims you as resident.

Then we dig into the big-ticket incentives people ask about most: the Cyprus non-dom regime (and how the 17 out of 20 years lookback really behaves), employment income exemptions that can dramatically reduce effective tax rates for senior hires, and the common exemption for gains on the disposal of securities, including the important caveat around Cyprus immovable property. We also cover how to obtain a tax residence certificate and the foreign pension option that can tax pension income at a flat 5% after the first €5,000, while noting when progressive rates might be better.

If you’re considering Cyprus relocation, listen and share this with someone considering a move. 

Everyone talks about “the Italy flat tax,” but that headline hides the real story: Italy has built several distinct tax regimes for people relocating, and the best choice depends on who you are and how you earn. We sit down with Italian tax lawyer Matteo Rapinesi of Orisea to map the landscape in plain terms, so you can stop guessing and start planning your move with facts.

We dig into the new residents flat tax (now commonly discussed at €300,000 per year), what it actually covers, and why the ability to work in Italy can make it more practical than some other European models. Matteo explains how the ruling process can create a safer path for high-net-worth individuals who want confirmation that their situation fits the regime, and we talk through cases where the flat tax is not automatically the best deal, especially when foreign tax credits matter.

Then we widen the lens: Italy’s inbound workers regime, the separate incentives for lecturers and researchers, and the retiree option that can apply a 7% substitute tax to foreign income in qualifying Southern municipalities. We also cover immigration routes like the investor visa and elective residence visa, plus why Italy is increasingly attractive for business investment, with Milan’s rapid evolution and a more investor-friendly approach inside government.

If you’re comparing Italy tax incentives, Italian tax residency, the UK-Italy double tax treaty impact, or simply trying to understand which relocation regime matches your income mix, this conversation gives you a solid framework. 

Switzerland gets called “high tax” so often that people stop questioning it, and that’s where expensive mistakes begin. We sit down with Geneva-based Swiss tax lawyer Ali Kanani to map the real landscape: 26 cantons, municipal differences, and a system where your address can change your outcome as much as your income.

We break down the ordinary Swiss taxation of income and net wealth, including how the Swiss wealth tax works and why inheritance and gift tax can be surprisingly favourable for transfers between parents and children in some cantons. We also talk through a major draw for founders and investors: for many private individuals, Switzerland generally does not tax capital gains on securities, which shapes how entrepreneurs think about selling a business after establishing Swiss tax residency.

Then we go deep on the Swiss forfait, also known as lump-sum taxation. We explain how the taxable base is built from annual living expenses, what minimums apply, how a written ruling gets negotiated with cantonal authorities, and why the “no work in Switzerland” rule can become the defining issue for active business owners. We also cover pensions and Switzerland’s wide double-tax treaty network, plus what changes for UK nationals navigating immigration after Brexit.

If you’re considering Switzerland for personal migration, tax planning or international succession planning, this will answer many of your questions.

Malta keeps showing up on shortlists for relocation, retirement, and international business, but the real question is whether the tax outcome matches the plan you have in your head. We sit down with Geraldine Schembri of EMCS in Malta to unpack how Malta tax residency actually works, why “183 days” is only one doorway, and how ordinary residence can depend on intention, facts, and connecting ties rather than a purely mechanical test.

We also get specific about the resident non-domiciled framework and the remittance basis. If you are resident but not domiciled, Malta can tax Maltese source income and foreign income you remit, while foreign capital gains can sit outside the net, even when remitted, a detail that changes planning decisions fast. From there, we shift into pension planning and the UK Malta double tax treaty angle, including what retirees should know about domestic pension thresholds and Malta’s retiree programme, where a 15% rate and minimum tax come with clear eligibility rules and full remittance expectations.

For professionals and entrepreneurs, we cover the most talked about incentives: the highly skilled routes for defined sectors, the Nomad Residence Permit for people working for foreign employers or foreign clients, and why the first year and later year tax treatment can look very different. We also tackle a point many people miss: visa status does not automatically equal tax residence, and without a tax residency certificate you may not access treaty benefits. We close with the Malta Permanent Residence Programme overview and a grounded look at how Malta has adjusted programmes by raising thresholds rather than wiping them out.

If you are weighing Malta for a move, listen, share this with someone planning a relocation, and subscribe so you do not miss the rest of the destination series.

A lot of people talk about “moving for tax reasons,” but the real question is: which rules will still work after the headlines change? Roy Saunders, Founder and Chairman of the IBSA Club, sits down with Jose Aguilar Shea, a Spanish tax lawyer at Squire Patton Boggs in Madrid, to unpack what personal migration to Spain and Portugal actually looks like right now for professionals, entrepreneurs, and high-net-worth individuals.

We start with Spain’s special tax regime known as the Beckham Law, including what it does (and doesn’t) cover: a flat 24% rate on employment income up to €600,000, a focus on Spanish source income, and why scrutiny from the tax authorities has increased even as access has broadened. Jose explains the 2023 changes that opened the door wider for remote workers, and how that connects to the remote work visa often called the digital nomad visa for non-EU nationals. We also dig into the “active business” requirement for founders who want to set up in Spain without losing the benefit.

Then we get honest about retirees. Spain can be an incredible lifestyle destination, but the incentives are not built around pensioners. We walk through the non-lucrative visa, the repeal of Spain’s Golden Visa, and what progressive Spanish income tax can mean for pension income under double tax treaty planning. Finally, we compare Portugal’s dramatic shift away from its old retiree-friendly framework, the newer 20% approach for qualifying work, and how Portugal’s Golden Visa now leans toward funds and business activity rather than real estate.

If you’re weighing Spain vs Portugal for tax residence, succession planning, or a digital nomad relocation, this is your roadmap. 

The fastest way to get UK tax wrong is to assume one simple rule controls everything. We sit down with Dmitry Zapol to break down what “UK tax residence” really means in practice, from the 183-day threshold to the quieter danger zone where you spend fewer days but keep enough UK ties to stay within the statutory residence test. We also flag the timing issue that catches people off guard: the UK tax year runs April 6 to April 5, and that mismatch with foreign tax years can create gaps in planning and reporting. 

From there, we get into the post-April 2025 reality. Domicile and the remittance basis may be gone, but remittances still matter for anyone who built up foreign income and gains before the change. We talk through how old pools can remain outside UK tax if handled correctly, and how everyday steps like borrowing against foreign proceeds, moving sale funds, or structuring support payments can trigger UK taxation under extended remittance concepts. Dmitry also explains the Temporary Repatriation Facility (TRF), why deadlines and nomination matter, and why selling a foreign asset can create unexpected tax issues when you trace the original purchase funds and even exchange rate movements. 

We then zoom out to what counts as “foreign” under the foreign income and gains (FIG) framework, including tricky instruments where the underlying assets point back to the UK. We cover crypto tax basics, why situs can follow the owner’s UK tax residence, and what that can mean for staking income. Finally, we connect residence to inheritance tax through long-term residence rules, outline the temporary non-residence five-year return trap for leavers, and explain who qualifies for the four-year FIG regime based on the 10-year non-residence lookback and the rising disclosure expectations driven by HMRC data sharing. 

Dubai keeps showing up on relocation shortlists, but the real story is more complicated than “move there and pay no tax.” We sit down with Jimmy Sexton of the Esquire Group in Dubai to unpack why entrepreneurs, investors, and globally mobile families are choosing the UAE, and what you need to understand before you follow the trend. For Americans especially, we talk candidly about citizenship-based taxation and why many moves are driven by business access, deal flow, and practical freedom rather than a simple tax play.

From there, we zoom out to the bigger migration patterns. With the UK non-dom regime ending and tax pressure rising across parts of Europe, Dubai is increasingly treated like a modern base for wealth. We also get into the non-financial reasons people stay: personal safety, lifestyle stability, and day-to-day convenience that can be hard to find in other major global cities.

We then move into the nuts and bolts that make or break a relocation plan: free zone vs mainland company formation, the shift to 100% foreign ownership, and what the UAE’s 9% corporate income tax means for operating businesses and self-employed trading income. Just as important, we clarify a common misconception: having a UAE residence visa is not the same as being a UAE tax resident. We explain day-count rules, tax residency certificates, and why the UAE’s extensive double tax treaty network can still have limitations, including nationality requirements and look-through rules.

If you’re thinking about moving to Dubai, expanding a business to the UAE, or simply trying to compare jurisdictions more intelligently, this conversation gives you a clear framework. 

A great incentive plan is not about “perks” it's about making sure the people building the company feel the upside at the right time, with tax outcomes that do not backfire. We end our Growth of a Business series by diving into management incentives for a scaling business, starting with the hardest practical question: when should you put incentives in place if your share value is rising fast and your leadership team is still forming?

We sit down with Jeremy Glover, Partner at Jurit LLP and Consultant at Howard Kennedy, to unpack how equity incentives work in the real world, including the tax trap every founder should fear: a dry tax charge, where someone owes tax without having cash to pay it. From there, we break down why the UK Enterprise Management Incentive (EMI) scheme is so widely used by growth companies, how qualifying EMI share options can defer tax until a sale, and why capital gains tax treatment can be so much more efficient than income tax. We also discuss National Insurance Exposure, and how employers think about risk, retention, and fairness all at once.

Valuation and leavers are where the details matter. We talk through agreeing values, how minority discounts can affect option pricing, what “good leaver” treatment can look like, and how vesting protects the cap table while still rewarding real contribution. We then zoom out to cross-border reality: an Irish parent, UK operations, a US expansion, and what happens to options when employees move between the UK and US under a double tax treaty. We finish by comparing EMI options with growth shares, including hurdles and the risk of getting day-one valuation wrong.

If you care about management incentive planning, employee share options, EMI schemes, and tax-efficient ways to retain key talent through an exit, this podcast is for you. 

A funding plan can look perfect on paper and still fail in the real world because the “where” is inseparable from the “how.” We sit down with Bern Gilbey and Sam Meiklejohn, Partners at Gateley, to unpack the decisions founders wrestle with when they need serious capital: stay UK-based and build toward AIM, chase a NASDAQ listing for higher valuations, or design a path that gets the best of both.

We get specific about why teams move operations to the United States, from deeper venture capital pools to the sheer scale of the US market and the power of the right regional ecosystem. Then we pressure-test the assumption that a higher IPO valuation is always the win. Growth-stage companies are often capital intensive, and if you need to raise again in a tougher market, today's premium can become tomorrow's down round. Stability, investor fit, and a credible growth trajectory matter just as much as price.

From there, we go into the mechanics founders often hear about too late: pre-IPO venture rounds, dual-listing strategies (AIM first, NASDAQ later), and the corporate structuring issues that come with cross-border growth. We break down holding company choices, Foreign Private Issuer status, and how US investor tax preferences can drive decisions around US topcos, tax transparency, and blocker companies, especially when UK EIS and VCT investors are involved.

R&D tax credits can be a lifeline for early-stage companies and a useful tool for large ones too, but the rules have become increasingly complex, especially when you can’t substantiate what you did. We sit down with Paddy Hobbs of S&W to unpack how the UK R&D tax credit landscape has rightfully evolved from a “how much can I claim” mindset into a compliance-first world where documentation, decision logs, and an audit trail can make or break the benefit. If you’re building a product in software, medtech, engineering, or any science and technology field, this conversation helps you think like HMRC will think. 

We dig into the big structural shift: the UK merged R&D regime (introduced for periods following April 2024) and how it has replaced the old SME and RDEC approaches. Paddy explains what “above-the-line” credit means in real terms, and why R&D tax credits look backwards while grant funding looks forward. We also talk about the practical risk that scares founders the most: not whether your work is innovative, but whether you can evidence the uncertainty you tackled and the work you actually performed. 

Additionally, we discuss Ireland’s R&D tax credit becoming even more competitive, and its stricter habits around timesheets and record keeping offering a useful model. The US comparison is a different kind of complexity, with federal and state R&D credits that vary widely depending on where you operate and how you structure the work. Finally, we tackle subcontracted R&D and contracts: who initiated the project, who directs it, and who bears technical risk often determines who can claim the relief, especially under the updated UK rules. 

If you want your R&D claim to fund growth without turning into a painful distraction, hit play, take notes, and tighten your process.