A Czech entrepreneur sells a software company for €8 million. He wants to reinvest into Gulf real estate and private credit, hold some capital in a family reserve, and eventually move to the UAE. He asks how to structure this.
The first question is exit tax. If he moves residency while holding the €8 million in a Czech entity, the Czech Republic will assess exit tax on unrealized gains. The sequence matters: structure the holding correctly before triggering the exit, or accept the tax. In this case, the capital has already been realized as cash, so the immediate exit tax question is less acute — but future assets need to be held outside Czech entities before he changes residency.
He sets up a UAE FZCO (free zone company) as his primary holding vehicle. This captures the zero-corporate-tax environment and gives him a credible operational base when he relocates. The UAE FZCO holds stakes in two structures: a Dubai-based SPV for each real estate deal, and a Luxembourg SICAV-RAIF for the private credit allocation (chosen for its regulated structure and European investor familiarity).
The family reserve sits in a Liechtenstein private foundation, which separates legal ownership from beneficial ownership and provides a clean succession mechanism for the next generation without requiring probate across multiple jurisdictions.
Management fees for his advisory activities flow from a Czech operating company (where he retains some clients) to the UAE FZCO at arm's length pricing. Once he establishes UAE residency, his personal income is taxed in the UAE — zero rate — rather than in the Czech Republic.
This is not the only way to structure this situation. It is one way that addresses the specific requirements: capital mobility, zero-tax holding, regulated investment access, family succession, and clean residency transition. Every element connects back to a requirement. Structure without purpose is just overhead.