The pressure does not arrive in headlines. It arrives in the small print.
Your bank asks for a tax residence certificate. Your adviser uses the phrase "attributable income". A form asks who controls the company, not who owns it.
Behind all of this sits one family of rules. In its corporate form it is called CFC rules, for Controlled Foreign Company. For private individuals the same idea usually travels under other names: transfer of assets abroad, settlements, attribution.
The power they give a tax authority is simple to state. Your home country can tax the income of a foreign structure you control as if it were your own, even if nothing is ever distributed to you.
What attribution rules allow
The pattern is the same almost everywhere. You are tax-resident in a country with such rules. You own or control an entity abroad, often in a jurisdiction with low or no tax. The entity earns passive income: dividends, interest, rent, royalties, gains on investments or crypto assets.
Your home country then treats that income as yours. It taxes it now, not when it is paid out.
Control does not have to mean ownership. Depending on the country, the rules reach:
- the founder of a foundation,
- the settlor of a trust who can still benefit from it,
- a director or anyone with decisive influence,
- the person who funded the structure and still steers it.
A structure that answers to you is, for these rules, usually treated as you.
Where the rules reach individuals
United Kingdom. The UK's CFC regime in Part 9A of the Taxation (International and Other Provisions) Act 2010 charges UK-resident companies, not individuals. For individuals the work is done by two older codes. The transfer of assets abroad rules (sections 714 to 751 of the Income Tax Act 2007) charge a UK-resident individual on the income of a person abroad that he has power to enjoy as a result of a transfer. The settlements rules treat income arising under a settlement in which the settlor keeps an interest as the settlor's income alone (section 624 of the Income Tax (Trading and Other Income) Act 2005). Since 6 April 2025, HMRC's own helpsheet HS262 states, the old protections for non-resident trusts no longer apply and a settlor is assessed on the income of the trust and its underlying entities as it arises.
Ireland. Section 806 of the Taxes Consolidation Act 1997 serves the same purpose: it exists to stop individuals living in Ireland from avoiding income tax by transferring assets abroad.
Every EU member state, for companies. The Anti-Tax Avoidance Directive (EU) 2016/1164 obliges member states to apply CFC rules to taxpayers subject to corporate tax. Under its Article 7, an entity is a CFC where the taxpayer holds more than 50% and the tax it actually pays is lower than the difference between the tax it would have paid at home and the tax it actually paid. In plain terms: less than half the home country's tax.
Norway. The Norwegian rules for companies in low-tax countries (sections 10-60 to 10-68 of the Tax Act) apply to individuals as well as companies. Where Norwegian taxpayers together control at least half of a foreign company, or control another independent arrangement or pool of assets from which they benefit, and that entity pays less than two thirds of the tax it would pay in Norway, each owner is taxed on his share of its profit, regardless of whether anything is distributed.
Sweden. Chapter 39 a of the Income Tax Act works the same way for any Swedish taxpayer who, alone or with related persons, holds at least 25% of the capital or votes in a foreign legal person whose income is low-taxed. Low-taxed means taxed less than a Swedish company would pay on 55% of that income.
The Netherlands. Here the rule goes beyond companies. Under Article 2.14a of the Income Tax Act 2001, the assets, debts, income and expenses of a separated private fund, the Dutch term for a foundation or trust that serves a private interest, are attributed to the person who set it up. After that person's death, they are attributed to the heirs.
United States. A US citizen or green card holder who funds a foreign trust is generally treated as its owner under the grantor trust rules (sections 671 to 679 of the Internal Revenue Code) and taxed on its income. Forms 3520 and 3520-A, Form 8938 and the FBAR come on top, and the IRS warns of significant penalties for missing them.
Where the rules end: residence
Every rule above hangs on one thing. They apply because you are resident there. Change your residence and the question changes with it.
Some countries tax individuals on a territorial basis, or not at all. A few examples, as their own law states it today:
United Arab Emirates. The UAE does not levy income tax on individuals. Since 2023 a natural person pays corporate tax only on business activities with a turnover above AED 1 million a year, and Cabinet Decision No. 49 of 2023 states expressly that wages, personal investment income and real estate investment income do not count as such activities.
Philippines. Under Section 23(D) of the National Internal Revenue Code, an alien individual, whether resident or not, is taxable only on income derived from sources within the Philippines.
Uruguay, a precedent for change. Until 2025 Uruguay was widely used as a base for international holding and foundation structures. Law 20,446 of 16 December 2025 changed that. Under Decree 95/2026, from 1 January 2026 income obtained by a non-resident entity is attributed directly to the Uruguayan-resident individuals who are its beneficial owners, from a holding of 5%, at the moment the entity receives it. The interposed company no longer defers anything. A structure built for the old rules needs recalculating.
Uruguay shows what territorial systems are: law, not a promise. A country that did not attribute yesterday can attribute tomorrow. The choice of residence has to be checked against the statute in force, and checked again.
The second question: where the business is run
Leaving a country with attribution rules removes one risk. It does not remove all of them.
Holding and managing your own wealth passively is one thing. Running an active business through a foreign company is another. If you work for clients, issue invoices and take the decisions from the country where you now live, that country can treat the business as being carried on there. Tax treaties call this a permanent establishment.
The UK shows how far this goes. A company incorporated abroad is UK-resident if its central management and control is exercised in the UK; HMRC's International Manual still cites the case that set this out in 1906, De Beers Consolidated Mines v Howe. A board that meets at your kitchen table in Manchester makes a Manchester company.
The UAE draws its own line: business activity by an individual above AED 1 million in turnover is within its corporate tax.
So the working rule is this: passive wealth can be held from almost anywhere; an active business is taxed where it is actually run.
What this means for your wealth
Structures abroad are legal. A foundation in Nevis, a company in Wyoming, a trust: none of them is a problem in itself. What matters is that income stays taxable where you are resident, and that every structure is reported where the law asks for it. We help nobody hide anything.
The consequence is just as plain. As long as you live in a country with attribution rules, a structure abroad changes how your wealth is protected, not how it is taxed. The tax position moves only when you do. That is why a move abroad is planned first and the structure second, and why the comparison of a Nevis trust and a Nevis foundation starts with your residence, not with the vehicle.