Short answer: after becoming a new tax resident, existing low-tax holding companies may fall under CFC rules, taxing undistributed profits personally. Restructure or test exemptions before moving.
CFC Rules After New Tax Residence: Practical Impact
Written by Global Immigrate consultants · Reviewed by Oscar Yip, Founder & Managing Director
Summary
Low-tax holding profits may be taxed currently even if undistributed.
FAQ
Active trading companies?
Many regimes exempt them — thresholds differ.
Must dissolve?
Not always — migration of tax residence or distributions are options.
Immigration link?
Mainly tax — but it affects true holding cost.