Client Profile
| Detail |
Info |
| Name |
The Dumont family (anonymized) |
| Ages |
Pierre (52), Isabelle (49), two children (16, 19) |
| Nationality |
French |
| Residence |
Paris, France (lifelong) |
| Net worth |
~€5M |
| Composition |
€2M Paris apartment, €1.5M securities portfolio, €800K assurance-vie, €500K cash, €200K crypto |
| Income |
Pierre: €180K (executive), Isabelle: €60K (consultant) |
The Problem
The Dumonts faced a convergence of concerns:
| Issue |
Detail |
| IFI (wealth tax) |
€5M puts them well into IFI territory — ~€7,500/year on real estate assets above €1.3M |
| Inheritance exposure |
French succession tax: up to 45% above €1.8M per child |
| Portfolio taxation |
30% flat tax (PFU) on all investment gains |
| Older child's studies |
Son accepted at a university in Dubai — family considering following |
| Pierre's career |
Can transition to consulting role for his employer, working remotely |
Pierre asked: "We're not trying to hide anything. We just want to structure our wealth intelligently for the next 20 years."
The Solution: Three-Jurisdiction Architecture
Structure Overview
┌────────────────────────────────────────────────────┐
│ 🇦🇪 UAE (Dubai) │
│ Personal residence — Golden Visa │
│ Pierre's consulting via Freezone │
│ Personal banking: Wio + ENBD │
└───────────────────────┬────────────────────────────┘
│ owns 100%
┌───────────────────────▼────────────────────────────┐
│ 🇱🇺 Luxembourg SOPARFI │
│ Holding company for investments │
│ Banking: BIL private banking │
│ Holds: listed securities + fund units │
└───────────────────────┬────────────────────────────┘
│ subsidiary
┌───────────────────────▼────────────────────────────┐
│ 🇨🇭 Switzerland │
│ Swissquote brokerage account │
│ Direct market access for trading │
│ CHF diversification │
└────────────────────────────────────────────────────┘
Phase 1: UAE Setup (Month 1-3)
| Action |
Timeline |
Cost |
| Dubai Freezone (DMCC) — consulting license |
3 weeks |
€8,500 |
| Golden Visa (via company) |
4 weeks |
€3,200 |
| Family visas (spouse + 2 children) |
2 weeks |
€4,800 |
| Apartment rental (Dubai Marina, 3BR) |
1 week |
~€42,000/year |
| Wio accounts (Pierre + Isabelle) |
3 days |
Free |
| Emirates NBD Signature (private banking) |
3 weeks |
€2,500 |
| School enrollment for younger child |
Concurrent |
~€25,000/year |
Phase 2: Luxembourg SOPARFI (Month 2-4)
| Action |
Timeline |
Cost |
| SOPARFI S.à r.l. incorporation |
4 weeks |
€12,000 |
| BIL private banking account |
3 weeks |
€3,500 |
| Transfer securities portfolio (€1.5M) |
2 weeks |
Via transfer of ownership |
| Substance requirements (local director, registered office) |
Ongoing |
€8,000/year |
Why SOPARFI?
| Benefit |
Detail |
| Participation exemption |
Dividends from qualifying subsidiaries: exempt |
| Capital gains exemption |
Gains on qualifying participations: exempt |
| Treaty network |
80+ DTAs, including France and UAE |
| EU Parent-Subsidiary Directive |
Tax-free dividend flows within EU |
| Reputation |
Luxembourg is tier-1, never questioned by banks |
Phase 3: Swiss Banking (Month 3-5)
| Action |
Timeline |
Cost |
| Swissquote account opening |
2 weeks |
€2,000 |
| Transfer of CHF allocation (~€300K) |
1 week |
Wire transfer |
Handling the French Exit Tax
| Asset |
In scope? |
Latent gain |
Exit tax (30%) |
| Securities portfolio (€1.5M) |
✅ Yes |
~€400,000 |
€120,000 |
| Crypto (€200K) |
✅ Yes |
~€130,000 |
€39,000 |
| Assurance-vie (UC portion) |
⚠️ Partial |
~€80,000 |
€24,000 |
| Paris apartment |
❌ Not exit tax (different regime) |
— |
— |
| Cash |
❌ No |
— |
— |
| Total exit tax exposure |
|
|
€183,000 |
Strategy: Automatic sursis (France-UAE treaty). Hold all assets for 5 years post-departure. Exit tax = €0 at expiry.
Paris Apartment Decision
| Option |
Consequence |
| Keep and rent |
Rental income taxed in France (20% + 17.2% social charges) |
| Sell before departure |
Capital gains tax with abatements (22+ years ownership → significant reduction) |
| Sell after departure |
19% + 17.2% on non-residents (no abatement reset) |
Decision: Keep for 2-3 years (rental income via agency), then reassess. Keeps optionality if family returns.
Financial Impact (Annual)
| Item |
France (before) |
New structure |
Difference |
| Pierre's income tax |
~€45,000 |
€0 (Dubai) |
+€45,000 |
| Isabelle's income tax |
~€12,000 |
€0 (Dubai) |
+€12,000 |
| Social charges (both) |
~€55,000 |
€0 |
+€55,000 |
| IFI wealth tax |
~€7,500 |
€0 |
+€7,500 |
| Investment gains tax (avg) |
~€15,000/year |
€0 (via SOPARFI) |
+€15,000 |
| Total annual tax savings |
|
|
~€134,500 |
| Structure maintenance costs |
— |
-€25,000/year |
— |
| Higher Dubai cost of living |
— |
-€30,000/year |
— |
| Net annual benefit |
|
|
~€79,500 |
Succession Planning Impact
| Scenario |
French regime |
New structure |
| €5M estate, 2 children |
Up to 45% on amounts above €1.8M per child = ~€700K+ in estate taxes |
UAE: no inheritance tax. Luxembourg SOPARFI: shares transfer via controlled process |
| Potential estate tax savings |
|
€500K-€700K+ |
Timeline
Month 0 → Engaged Private Office
Month 1-2 → UAE company + visa + banking
Month 2-4 → Luxembourg SOPARFI setup + banking
Month 3-5 → Swiss account + portfolio restructuring
Month 4 → Fiscal domicile transfer to UAE
Month 5 → Exit tax declaration filed
Month 6 → Fully operational — three jurisdictions active
Year 2-5 → Annual exit tax attestations
Year 5 → Exit tax dégrèvement → €0
Services Used
| Service |
Cost |
| Private Office — Plan B Fiscal UAE (Resident package) |
€38,000 |
| Luxembourg SOPARFI setup |
€18,000 |
| Swiss account opening |
€2,000 |
| French tax advisor (exit tax + apport structuring) |
€12,000 |
| Total |
€70,000 |
| Payback period |
~10 months of tax savings |
Key Takeaways
- Multi-jurisdiction structuring isn't just for the ultra-wealthy — at €5M, the numbers are compelling
- The combination of UAE (personal), Luxembourg (holding), and Switzerland (banking) is a proven triangle
- French exit tax with proper sursis management leads to zero payment after the holding period
- Succession planning is a major driver — French inheritance tax at 45% is a significant wealth erosion
- Genuine relocation is essential — the Dumonts actually live in Dubai, children attend school there
- Annual maintenance costs (~€25K) are real but marginal versus the savings
⚠️Disclaimer: This case study illustrates a multi-jurisdiction approach. Individual circumstances require bespoke analysis by qualified professionals in each jurisdiction.
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