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Relocating your wealth abroad can be a powerful strategy — to protect assets, access new opportunities, or align with a more favorable tax environment. Yet, without precise planning, it can also trigger one of the most complex and punitive fiscal outcomes: double taxation.
From Paris to São Paulo, from London to Dubai, governments increasingly coordinate to ensure that income, capital gains, and even unrealized profits remain taxable somewhere.
The challenge for global investors is therefore not to escape taxation, but to legally avoid being taxed twice on the same wealth.
At SBH Capital Partners, based in Saint-Barthélemy, we specialize in designing compliant, neutral, and secure wealth relocation structures that align with international law — enabling our clients to move capital, companies, or crypto assets abroad without fiscal friction.
Double taxation occurs when two or more jurisdictions claim the right to tax the same income or capital.
This usually happens when:
There are two main forms:
SBH Insight: Most double taxation risks arise not from earnings themselves but from residency and control mismatches — where your home country still considers you fiscally present even after you’ve moved.
To mitigate this, over 3 000 Double Tax Treaties (DTTs) exist worldwide, coordinated under OECD Model Convention Articles 4 and 7, defining which country has taxing rights based on residence, income source, and effective management.
However, applying these treaties requires substance, documentation, and proper timing — elements that few relocations get right without professional structuring.
Relocating assets or residency can activate multiple fiscal triggers if not planned correctly:
When you move abroad, some jurisdictions (France, Canada, Spain, the U.S.) tax unrealized capital gains on shares, crypto, or company holdings at the time of departure.
Owning property, having family dependents, or maintaining management control of a business can lead your previous country to retain fiscal jurisdiction.
If two countries apply different criteria (e.g., “183-day rule” vs. “center of interests”), both may claim residency in the same year.
A company incorporated abroad but managed from your home country can be deemed tax-resident in both, nullifying the intended benefit.
Failing to obtain or maintain a Certificate of Tax Residence, or misunderstanding DTT provisions, leads to default double taxation.
SBH Insight: Each relocation should begin with a residency audit — identifying every fiscal tie that may trigger taxation after the move.
Avoiding double taxation requires aligning personal, corporate, and asset dimensions of wealth.
The following strategies are universally recognized by OECD members and international tax courts.
Select a jurisdiction offering clarity, stability, and treaty coverage.
Saint-Barthélemy, for example, provides complete fiscal autonomy while remaining under the French legal system — recognized worldwide and compliant with OECD standards.
Maintain local management, bank accounts, and accounting records.
This ensures your structure is not considered a “shell” and that effective control truly resides in the chosen jurisdiction.
Leverage DTT provisions to allocate taxing rights properly — ensuring dividends, royalties, and capital gains are taxed in only one jurisdiction.
Relocate before realizing capital gains or major income events.
Proper sequencing often eliminates exit taxation or allows for deferred payment mechanisms.
Holding companies or real-estate entities in neutral jurisdictions like Saint-Barthélemy can centralize ownership while maintaining full transparency and neutrality.
Few jurisdictions offer the same mix of autonomy, legality, and discretion as Saint-Barthélemy.
As a French Collectivité d’Outre-Mer (COM) under Article 74 of the French Constitution, the island:
SBH Insight: Saint-Barthélemy is the only jurisdiction that offers French legitimacy with international fiscal independence — allowing lawful tax neutrality.
For wealth relocation, this means investors can legally hold, manage, and reinvest global assets without exposure to double taxation — while remaining entirely transparent.
At SBH Capital Partners, we design end-to-end frameworks to ensure that the relocation of your wealth is both efficient and defensible.
This model offers:
Our philosophy: neutrality through substance — because the best defense is transparency backed by structure.
A Swiss investor sells part of a crypto portfolio and reinvests through a Saint-Barthélemy company.
Conversion and reinvestment occur locally, under SBH management.
Outcome: No capital-gains tax, no double taxation, full compliance with French law.
A European family office relocates its holding company to Saint-Barthélemy.
Decision-making, banking, and accounting are transferred to the island.
Outcome: The structure becomes fiscally resident locally; profits distributed abroad are not taxed twice.
A French founder moves to Saint-Barthélemy before selling his tech start-up.
By relocating before the transaction, exit-tax exposure is neutralized.
Outcome: Sale proceeds are exempt from French mainland taxation and reinvested through a neutral vehicle.
SBH Insight: Each scenario demonstrates the same principle — double taxation disappears when residence, management, and compliance align under one jurisdiction.
The OECD 2025 standards will redefine global taxation:
jurisdictions will compete not on secrecy but on legitimacy.
Saint-Barthélemy’s model is already aligned with this future:
Under SBH Capital Partners’ guidance, your wealth relocation becomes a legal transformation, not a fiscal risk.
Because neutrality is no longer about hiding assets — it’s about placing them where the law itself protects them.
Double taxation is not inevitable; it is the result of poor structuring.
By anticipating legal definitions of residence and control, and by relocating through a compliant, autonomous jurisdiction such as Saint-Barthélemy, investors can achieve permanent fiscal neutrality.
At SBH Capital Partners, we provide the legal, operational, and managerial backbone to ensure your relocation is recognized globally — and never taxed twice.
Freedom today is not about moving wealth — it’s about moving it legally and intelligently.
1. What causes double taxation when moving abroad?
Conflicting residency rules or control between two jurisdictions.
2. How can it be avoided?
Through treaty application, local management, and compliant relocation structures.
3. Why choose Saint-Barthélemy?
It offers zero taxation under French law, full OECD compliance, and international credibility.
4. Can crypto assets be relocated without tax exposure?
Yes — when converted and reinvested locally within a compliant structure.
5. How does SBH Capital Partners assist?
By establishing residency, management, and compliance under one legally recognized framework.
Discretion, compliance, and excellence in Saint-Barthélemy.
Fill out the form below to access a private consultation with our expert team.
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