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🇩🇰 Rich expat stumbles: Sanjay Shah and the Danish cum-ex scandal

A headline-making case continues: Sanjay Shah, a British trader and founder of hedge fund Solo Capital, was sentenced in Denmark in late 2024 to 12 years in prison for orchestrating a massive dividend tax refund fraud (cum-ex deals) that allegedly defrauded the Danish treasury of over €1 billion.

The case has reverberated across Europe, spotlighting how aggressive tax structures used by high net worth individuals can unravel under scrutiny.

ProACT Sam says:

This is the kind of case that underlines why even the highest-net-worth expats can’t treat tax planning as a game of pushing the envelope. The Shah affair shows that what may seem like “clever arbitrage” can become a criminal case when regimes tighten oversight and litigation risk becomes real. For expats with cross-border income, especially dividends, it’s vital to prioritize transparency and conservative risk, not just maximisation.

🇬🇧 UK Budget looming - tightening the screws on wealth

The UK’s Autumn Budget (expected 26 November 2025) is already generating anxiety in expat and high-wealth circles. Analysts expect new tax rises to close a projected fiscal gap of £20–30 billion, with proposals targeting capital gains tax, property levies (or “mansion tax”), and inherited wealth.

Some speculations include:

• Capping or reducing reliefs on high-value properties (e.g. over £1.5 million)

• Further changes to inheritance tax or gift reliefs

• Pressure on wealth vehicles and offshore structuring as the government seeks more revenue from non-labour sources

ProACT Sam says:

This Budget has the potential to shift the ground under expat planning. The trend is clear: the UK is trying to tax “wealth” more aggressively, not just income. For expats with UK property, pensions, or offshore assets, it’s a moment to review structure. Don’t wait for the announcement - run scenario stress tests (if CGT or property reliefs are changed) and reconsider timing of disposals or gifting.

🇨🇾 Cyprus incentives & changing UK links

Cyprus continues to court expats and returning professionals with updated tax incentives. For example, legislation is under consideration to grant a 25 % tax exemption (capped at about £21,225) to professionals returning to Cyprus.

Meanwhile, UK tax reforms are starting to bite for expats in Cyprus - pension assets will now be subject to UK inheritance tax from April 2027, and new rules are narrowing or removing many favourable transfer exemptions to Recognised Overseas Pension Schemes (ROPS).

Also, Cyprus is trying to attract talent back home by increasing the tax break on first employment from 20% to 25%, and raising the maximum exemption to €25,000 per year.

ProACT Sam says:

Cyprus remains one of the more favourable jurisdictions in the Mediterranean mix, especially for those seeking sun, quality of life, and some tax advantages. But it’s no longer “set and forget.” The shift in UK rules means your UK pension (if left in the UK) may face inheritance tax exposure. Also, the new Cyprus incentives are not unconditional - timing, residence status, and qualification rules all matter. Any expat in Cyprus should revisit their plan now.

🇺🇸 U.S. expats souring on America

A recent survey by Internations revealed that the U.S. now ranks 36th out of 46 countries among expats, with declining satisfaction across personal finances, job security, and political climate.

Many respondents flagged concerns around freedom of speech, political instability, and regulatory unpredictability.

Also notable: in Q1 2025, 1,285 U.S. citizens formally expatriated - more than double the last quarter of 2024, suggesting that some are acting on dissatisfaction or tax pressures.

ProACT Sam says:

The U.S. remains one of the tougher jurisdictions for expatriates due to its citizenship-based tax regime. Diminished quality-of-life scores and rising regulatory uncertainty make the calculus more painful: staying may mean heavy compliance overhead; leaving means navigating exit taxes and repatriation of assets. For Americans considering their future, this is a window to review the real cost of U.S. citizenship and whether relinquishment (in extreme cases) might be rational.

🇪🇺 Wealthy Europeans hit with exit charges

In another trend, wealthy residents in Europe who attempt to leave for more favourable tax jurisdictions are increasingly facing exit charges or penalties. Bloomberg Law reports a spike in such charges across countries like France, Switzerland, and the UK - aimed at recouping revenue before the taxpayer departs.

ProACT Sam says:

Exit charges are a stealthy way for states to discourage capital flight. If you’re considering shifting your tax residence, you may not leave - you might owe charges the moment you leave. This demands pre-exit modelling… capital gains crystallisation, de-risking exposure on depreciation or unrealised gains, and ensuring that your departure plan includes the fiscal “brakes” governments can apply.


Insight from the ProACT Cyprus Office

Cyprus isn’t just about tax regimes and residency permits - there’s a distinct rhythm to daily life that surprises many newcomers.

Expect hot sun most of the year, impromptu invitations over coffee or wine, and the joy of buzzing local tavernas where the catch of the day might show up on your plate just hours after being hauled in. Locals often treat time more fluidly - “now” might mean 20 minutes later - so folks who move here learn (sometimes the hard way) that flexibility and patience go a long way.

Garden terraces, sea views, afternoon siestas and spontaneous walks on dusty olive-tree lanes become part of the weekly habits. Expat groups and English speakers are common, so you’ll often find weekend brunches swapping tips on car servicing, utility deals or the best local fish tavernas.

There’s also a strong mix of expat-local interaction: neighbours offering baskets of mandarins, village festivals with music and dance, and the odd political debate that gets louder over ouzo at midnight.

For help and guidance living or working in Cyprus you can contact us.



Deadlines

  • 31 December 2025

    • 2nd & final instalment of 2025 Provisional Tax

    • Payment for Special Contribution for Defence for last 6 months of 2025

  • 31 January 2026

    • 2024/25 UK Tax Return Deadline

Learn more about our Tax Return Service for expatriates

 

Need help & guidance?

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ProACT Sam Orgill

ProACT Sam Says for Expat Family & Business Living and Working Abroad across borders and down generations.

Follow me for insight and Know How for Expats.

Tax Saving Expat Experts

https://www.proactpartnership.com
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