Entrepreneur Exit Tax Planning Case Study: Cross-Border Tax Structuring & Relocation to Malta

The client was a technology entrepreneur preparing for a significant business exit with anticipated proceeds arising across multiple jurisdictions. At the outset of the engagement, the client was not resident in Malta and held business interests, assets, and future income streams in several countries. In parallel with exit planning, the client was considering relocation and required a jurisdiction that could support long-term residence, family planning, and ongoing international investment activity within a compliant and predictable legal framework.

Client identities and specific factual details are intentionally anonymised. As a firm of lawyers, Chetcuti Cauchi does not disclose client names or identifying information, in accordance with professional secrecy and lawyer–client privilege.

The principal challenge was to ensure that the timing and structure of the exit were aligned with the client’s future residence and tax position. This required early assessment of Malta as a potential relocation jurisdiction, analysis of how and when Maltese tax residence would be triggered, and careful planning around domicile exposure, remittance principles, and the characterisation of exit proceeds and future income.

Crucially, the client needed clarity before the exit occurred, as decisions taken at that stage would determine the tax efficiency of the exit and limit the scope for corrective planning afterwards.

Chetcuti Cauchi advised on the matter through an integrated private client, tax, and immigration law engagement, working alongside the client’s corporate and financial advisers. Our role included:

• Advising on exit tax planning and the interaction between the exit event and future tax residence
• Assessing the suitability of Malta under tax and immigration law in light of the client’s personal and commercial objectives
• Advising on the most appropriate immigration and residence routes available under Malta’s legal system
• Undertaking pre-immigration tax planning, including analysis of tax residence, domicile exposure, and remittance treatment
• Advising on the structuring of assets and revenue streams to align with Malta’s residence and non-dom tax framework
• Coordinating immigration processes with exit and tax planning to ensure consistency and legal certainty

This approach ensured that the exit, relocation, and tax position were planned as a single, coherent strategy.

The client completed the exit within a carefully planned tax and residence framework, followed by relocation to Malta under a defined residence and non-dom structure. Asset holdings and anticipated income streams were structured in advance to ensure clarity of tax treatment, compliance with Maltese law, and alignment with ongoing cross-border obligations.

The outcome was a tax-efficient entrepreneurial exit coupled with a predictable and sustainable long-term residence position in Malta, supporting the client’s personal, family, and investment objectives while reducing regulatory risk and post-exit uncertainty.

• Exit tax planning and relocation planning must be addressed together, not sequentially.
• Jurisdiction selection should precede the exit, not follow it.
• Malta’s non-dom framework is most effective when asset and income structuring is completed before tax residence is triggered.

Chetcuti Cauchi advises entrepreneurs, founders, and high-net-worth individuals on exit tax planning, cross-border structuring, jurisdiction selection, Maltese residence options, and non-dom tax frameworks. Our private client and tax lawyers provide integrated advice to ensure that exits, relocations, and long-term planning objectives are aligned from the outset.