Offshore Tax with HTJ.tax

When registering a Will in the UAE, individuals can choose from three primary jurisdictions—ADJD, Dubai Courts, and DIFC. Each offers different advantages in terms of cost, process, language, and flexibility.

1. ADJD (Abu Dhabi Judicial Department)

Best for: Cost efficiency, full virtual process, expat Muslims

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• Cost: AED 950
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• Process: Fully virtual; no in-person visit required
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• Language: Bil...

When a person passes away in the UAE, the procedure that follows depends heavily on whether a valid Will is in place.

With a Will

If a Will exists, the process is significantly simpler and more predictable.

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• The executor submits the Will, the death certificate, identification documents, and proof of assets to the court.
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• After the file is opened and reviewed, the court typically issues the probate ord...

In the UAE, having a legally registered Will is not optional — it is crucial. Without one, a person’s estate is automatically governed by Sharia inheritance rules, which impose predetermined shares for heirs regardless of the individual’s personal wishes.

When someone dies without a Will in the UAE, several complications follow:

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• Sharia rules apply by default, dictating how assets must be divided.
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• Guardiansh...

Custodial institutions and fiduciary structures may both “hold assets,” but legally they are completely different. The distinction comes down to the relationship, the level of discretion, and who is allowed to act on behalf of the owner. Under EU regulations, this difference determines why custodians remain allowed for Russians, while fiduciary services are banned.

A Simple Analogy: Safe Deposit Box vs. Personal Chef

Cus...

Top Company (Custodial Institution)

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• The company’s articles and memorandum allow its shares to transfer automatically to designated third parties (typically family members) upon the shareholder’s death.
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• This mechanism does not create a trust, because there is no fiduciary relationship—only a custodial structure.
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• Therefore, it does not fall under EU trust-related sanctions, which target fiduciary and ...

While custodians and fiduciaries are closely related, they serve fundamentally different roles in wealth management and trust structures. Importantly: all fiduciaries are custodians in some sense, but not all custodians are fiduciaries.

1. Custodial Institution (“Vault Keeper”)

Role: Safeguard and protect client assets.

Core Function: Holding assets securely against loss, theft, or error.

Key Responsibiliti...

In this episode, we break down the EU’s crackdown on Russian-linked trusts — now widely referred to as “zombie trusts” — following amendments to Article 5m of Council Regulation (EU) 833/2014. These rules have rendered many existing structures legally unserviceable and have effectively shut the door to new trust formation involving Russian nationals or entities.

Key Points Covered:

1. What Article 5m Now Prohibits

Under t...

In this episode, we explore how wealthy Russians are responding to the tightening global network of financial transparency — particularly the Common Reporting Standard (CRS) and the Automatic Exchange of Information (AEOI). These frameworks have dramatically reduced financial secrecy, forcing individuals to adapt quickly or risk exposure to Russian tax authorities and enforcement actions.

Key Discussion Points:

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3. Formal...

We examine why many wealthy Russians are especially worried about global information-exchange regimes. The Common Reporting Standard (AEOI/CRS) and Exchange-on-Request (EoR) create layered visibility that can expose residency, assets, and financial flows — with consequences ranging from tax assessments to targeted investigations. Host countries that once offered anonymity now participate in automatic reporting, and requests from fo...

In this episode, we explore how certain jurisdictions remain outside the reach of CARF (Crypto-Asset Reporting Framework) — and why Svalbard and UK non-resident trusts continue to offer unique confidentiality advantages.

Key Insights:

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• Svalbard’s Unique Legal Shield
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• Under Article 8 of the 1925 Treaty of Svalbard, no signatory nation may receive tax benefits or preferential treatment related to Svalbard a...

In this episode, we explain who must report under the Crypto-Asset Reporting Framework (CARF) — and why understanding your role is critical for compliance.

Key Takeaways:

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• RCASP Defined:
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• A Reporting Crypto-Asset Service Provider (RCASP) is any individual or entity that enables or carries out crypto exchange transactions on behalf of clients as a business.
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• Entities Typically Considered RCASPs:
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In this episode, we explain who must report under the Crypto-Asset Reporting Framework (CARF) — and why understanding your role is critical for compliance.

Key Takeaways:

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• RCASP Defined:
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• A Reporting Crypto-Asset Service Provider (RCASP) is any individual or entity that enables or carries out crypto exchange transactions on behalf of clients as a business.
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• Entities Typically Considered RCASPs:
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In this episode, we break down when crypto transactions become reportable under the Crypto-Asset Reporting Framework (CARF) — and why not every wallet movement or exchange triggers a filing.

Key Takeaways:

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• Spending Crypto Triggers Reporting:
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• Direct purchases of goods or services with crypto remain rare. Most users must convert crypto into fiat before spending — and that’s often where reporting begins.
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• Ac...

In this episode, we unpack how the Crypto-Asset Reporting Framework (CARF) differs from its predecessors — FATCA and CRS — and why these differences matter for compliance and reporting transparency in the crypto era.

Key Takeaways:

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• Transaction-Based Reporting:
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• Unlike FATCA and CRS, which focus on income and asset values, CARF requires Reporting Crypto-Asset Service Providers (RCASPs) to disclose transactions made b...

The Crypto-Asset Reporting Framework (CARF) is designed to bring order, oversight, and accountability to the fast-moving world of digital assets. Its goals align closely with global efforts to prevent tax evasion, money laundering, and the misuse of crypto for illicit activity.

Key Objectives:

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• Increase Transparency — Shine a light on crypto asset holdings and transactions to help authorities track the flow of funds ac...

The Crypto-Asset Reporting Framework (CARF) represents the next major evolution in global financial transparency. It builds upon a lineage that started with FATCA, evolved through the Common Reporting Standard (CRS), and now extends to the world of digital assets.

The Evolution:

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• FATCA (Foreign Account Tax Compliance Act) — Launched by the U.S., FATCA was the original model for cross-border reporting. It forced non-U.S...

For many expats and entrepreneurs, maintaining or managing a foreign company while living in Portugal seems straightforward — but Portugal’s corporate tax rules can make things more complex than expected.

Key Point:

Unlike some countries that rely heavily on the “Place of Effective Management” (POEM) as a tie-breaker rule, Portugal uses “effective management” as a primary test for determining corporate tax residency.

Here’s what t...

If you’re planning to live, work, or even spend extended time in Portugal, there’s one acronym you’ll hear again and again — NIF.

What Is a NIF?

The NIF (Número de Identificação Fiscal) is your personal tax identification number — a nine-digit code issued by the Portuguese Tax Authority (Autoridade Tributária e Aduaneira). Think of it as your financial identity in Portugal.

Who Needs a NIF?

It’s not just for taxpayers or reside...

It’s easier than many people think to become a tax resident in Portugal by accident — and the consequences can be significant.

What Happens If You Accidentally Become a Resident:

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• 💰 Worldwide Taxation: You’ll be taxed on all your global income — salaries, pensions, investments, and rental income.
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• 🧾 Annual Filing Required: You must file a Portuguese tax return each year, even if most of your income is earne...