Case Study: How a French Entrepreneur Used Russia's Golden Visa After Non-Dom Abolition

Last updated: June 2026

By Dmitry Zapolskiy, Licensed Immigration Attorney | Cross-Border Advisory

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In March 2025, a French tech entrepreneur sat in our Moscow consultation room with three spreadsheets, two legal opinions from London tax counsel, and a problem that no amount of spreadsheet modeling was going to solve on its own. He had spent ten years as a UK non-dom — building a SaaS company, accumulating equity in three entities across two jurisdictions, and structuring his affairs around a tax classification that, as of April 6, 2025, no longer existed. His London advisor had estimated the annual tax impact of remaining in the UK under worldwide taxation at approximately GBP 840,000. His Paris accountant had run the numbers on returning to France: between IFI (Impôt sur la Fortune Immobilière), the progressive income tax schedule, and social contributions, the effective rate on his combined income would exceed 52%.

He was not looking for a tax haven. He was looking for somewhere he could run a technology business, maintain proximity to European clients, and avoid paying more than half his income in tax for the privilege of holding a passport he did not choose. Seven months later, he was a Russian permanent resident with a restructured holding company, a 13% flat tax rate on Russian-source income, and an annual tax liability roughly one-fifth of what either London or Paris would have collected.

This case study is a representative scenario based on anonymized client experiences. It does not describe a single individual or company. Identifying details — including the precise business vertical, exact financial figures, and specific dates — have been altered or composited to protect client confidentiality.

This content is for informational purposes only and does not constitute legal, financial, or tax advice. Tax laws change frequently and individual circumstances vary. Consult a qualified cross-border tax attorney and immigration practitioner for your specific situation.

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Background: Ten Years of Non-Dom Architecture

The client — we will call him Marc — is a French national, born and raised in Lyon. He studied engineering at INSA Lyon, worked briefly in Paris, then relocated to London in 2015 at age 29 to join a fintech startup. Within two years he had left that company and founded his own — a B2B SaaS platform serving mid-market financial services firms, primarily in the UK and continental Europe. By 2024, the company employed 22 people, generated approximately GBP 3.8 million in annual revenue, and had been profitable since 2021.

Marc claimed non-dom status from his first year in the UK. As a French national domiciled in France by origin, he qualified automatically — only a declaration on the annual self-assessment return. Under the remittance basis, his UK tax liability was confined to income earned in the UK. Dividends from his BVI holding company, capital gains on a Swiss-managed securities portfolio, rental income from an inherited Lyon apartment — none of it was taxed in the UK, provided it stayed offshore.

His corporate structure reflected standard non-dom planning: a BVI holding company owned the IP and received licensing revenue; a UK Ltd ran daily operations and employed staff; Marc drew a modest UK salary while accumulating wealth in the BVI entity. His total UK tax bill in 2023-24 was approximately GBP 67,000. Under worldwide taxation, that same income profile would have generated roughly GBP 840,000.

The structure was legal, well-documented, and — as of April 6, 2025 — obsolete.

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The Trigger: Non-Dom Abolition and the France Problem

The Finance Act 2025 abolished the UK remittance basis entirely. All UK residents now face worldwide taxation regardless of domicile. Marc's London tax advisor ran the projections in November 2024: remaining in the UK would cost approximately GBP 840,000 per year in additional tax. The Temporary Repatriation Facility — 12% rate on previously sheltered income through 2028 — offered a partial exit ramp for accumulated wealth, but did nothing about ongoing income.

Marc's first instinct was to go home. But his Paris accountant eliminated that option in a single phone call. France's progressive income tax reaches 45% at EUR 177,106. Social contributions (CSG/CRDS) add 17.2% on investment income. The IFI wealth tax would apply to his French real estate. Combined effective rate: exceeding 52%.

There was a deeper problem. France applies exit tax under Article 167 bis CGI — 31.4% on unrealized capital gains in securities portfolios exceeding EUR 800,000. If Marc relocated to France and then decided to leave again, he would face a departure levy on all accumulated gains — and France does not defer for non-EU moves. He would be walking into a jurisdiction that was expensive to inhabit and expensive to leave.

"The France option was not just expensive," Marc told us. "It was a trap. You go back, you get taxed at 52%, and if you ever want to leave again, they tax your unrealized gains on the way out."

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Research Phase: Four Jurisdictions, Four Trade-Offs

Marc spent January and February 2025 evaluating alternatives. His criteria were specific: effective tax rate below 20% on combined income, ability to run a European-facing technology business, no mandatory physical presence exceeding 90 days annually (his clients were in London, Frankfurt, and Amsterdam — he needed to travel), and a stable legal framework unlikely to face the political reversals that had destroyed non-dom status.

He evaluated four jurisdictions seriously. The UAE was the default recommendation from his London wealth manager — zero personal income tax — but maintaining tax residency requires 90+ days per year in-country, free zone operating costs had risen 18% since 2022, and deep Western financial integration meant his BVI holding structure would face the same CRS reporting and transparency pressures that had complicated his UK position. Portugal had killed NHR for new applicants in January 2024; without it, standard rates reach 48% plus solidarity surcharge — no better than France. Malta's remittance-based system (15% flat on remitted foreign income) looked attractive on paper, but the EU had been pressuring Malta's investment migration programs, and commercially, a Valletta headquarters would not play well with Frankfurt financial services clients.

Russia

Russia entered the picture through an unusual channel — a German fintech founder who had relocated to Moscow in 2023 mentioned the Golden Visa program at a Berlin conference. Marc had never considered Russia. But when he examined the legal architecture, three features stood out.

First, the Golden Visa grants permanent residence from day one. The government bond pathway requires 15 million RUB (approximately EUR 150,000). Physical presence requirement: zero.

Second, Russian tax residency is determined exclusively by physical presence — 183 days within any consecutive 12-month period. A Golden Visa holder below that threshold is taxed only on Russian-source income at 30%. All foreign-source income falls entirely outside the Russian tax base.

Third, Russia maintains double taxation agreements with more than 80 countries. The Russia-France DTA remains operational — it was not among the treaties Russia suspended in 2024. Dividends, interest, and royalties between France and Russia benefit from treaty-reduced withholding rates.

Marc flew to Moscow in early March for a three-day consultation with our team.

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Why Russia: The Decision Framework

The comparison, stripped down to numbers:

The last row decided it. Marc's qualifying investment — 15 million RUB in OFZ government bonds — was not dead capital. At 13.6% coupons (OFZ-PD series 26243, MOEX data, March 2025), the position would generate approximately EUR 20,400 in annual income. The investment effectively pays for itself within seven to eight years while qualifying him for permanent residence.

The zero physical presence requirement was the structural enabler. Marc could hold Russian permanent residence and continue living wherever his business required — London, Berlin, Lyon. His Russian tax exposure would be limited to OFZ coupon payments taxed at 30% as a non-resident (approximately EUR 6,120 annually). Everything else — SaaS revenue, portfolio gains, French rental income — would fall outside Russian jurisdiction entirely.

"The math was not even close," Marc said. "In the UAE I would pay zero tax but earn zero on the investment and spend three months a year in Dubai. In Russia, I pay six thousand in tax on the coupons, earn twenty thousand in coupon income, and I do not have to be physically present at all."

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Process: Golden Visa Application and Company Restructuring

Marc engaged our firm in late March 2025 for both the Golden Visa application and the concurrent corporate restructuring. The two workstreams ran in parallel.

Golden Visa: Government Bond Pathway

The application followed the standard bond-track process under Government Decree No. 2573 and Federal Law No. 115-FZ:

Week 1-2: Document preparation. Marc's French passport, birth certificate, and criminal background check were apostilled through the French Ministry of Justice. Medical certificates (HIV, tuberculosis, drug screening) were obtained at an accredited Moscow clinic during his March consultation visit. All documents were translated into Russian by a certified translator and notarized.

Week 3-4: Brokerage and bond acquisition. Marc opened a brokerage account at BCS (Broker Credit Service), a MOEX-member brokerage authorized for Golden Visa investments. KYC for EU nationals is standard — account opening took four business days. He then purchased 15.2 million RUB of OFZ-PD series 26243 (coupon: 13.6%, maturity: May 2031). The slight overshoot above the 15 million RUB minimum was deliberate — we advise all bond-track clients to maintain a 5-10% buffer against market value fluctuations. The National Settlement Depository (NSD) statement was generated the following business day.

Week 5: VNZh application filing. Filed at the Moscow MVD migration department via notarized power of attorney — Marc was already back in London. The package included the NSD depository statement, medical certificates, criminal background check, and standard application forms.

Weeks 6-19: Processing and issuance. MVD interdepartmental checks (FSB security clearance, Federal Bailiff Service, tax authority) took approximately thirteen weeks. No additional documents were requested. The permanent residence permit was issued in mid-August 2025 — five months from engagement — collected by our office under POA and shipped to London.

Company Restructuring

The corporate restructuring ran concurrently. Marc's existing structure — BVI holding company, UK operating company — needed careful unwinding to avoid triggering UK exit charges.

The UK Ltd was not closed immediately. Marc transitioned to a non-resident director role, appointed a UK-resident replacement managing director, and began migrating client relationships to a new Irish-incorporated subsidiary (Ireland imposes no individual exit tax). A Cyprus holding company replaced the BVI entity — chosen for its 12.5% corporate tax rate, EU membership (regulatory comfort for European financial services clients), and operational DTAs with both Russia and France. The Cyprus-Russia DTA reduces withholding on dividends to 5% (qualifying participations above 25%) and interest to 0%. IP and licensing arrangements were migrated to the Cyprus entity over four months.

Marc's French real estate remained in his SCI. French rental income continued to be taxed in France under domestic law — the Russia-France DTA allocates immovable property income to the source country. His French exposure was limited to this income plus 17.2% prélèvements sociaux at the non-resident rate.

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Tax Transition: The Critical Twelve Months

The tax transition was the most technically demanding aspect of the engagement. Marc was simultaneously exiting UK tax residency, managing French tax obligations, and establishing his position relative to Russian tax law. Each jurisdiction presented distinct issues.

UK Departure

Marc ceased to be UK tax resident under the Statutory Residence Test (SRT) from April 6, 2025 — the same date non-dom status was abolished. By leaving in the first tax year of the new worldwide taxation regime, he avoided any exposure to the new rules. The UK does not impose a formal exit tax on individuals, though Section 10A TCGA 1992 creates a five-year anti-avoidance window: if Marc re-establishes UK residence within five years, gains realized during the period of non-residence would be brought back into the UK tax net. Given his plan to base himself in continental Europe, this was manageable.

Before departure, Marc utilized the Temporary Repatriation Facility to bring GBP 1.2 million of previously sheltered BVI income onshore at the 12% concessionary rate — paying approximately GBP 144,000. The 12% rate is available only through April 2027 (rising to 15% in the final year), and the alternative was leaving the income offshore indefinitely with the risk of future UK claims under expanded CRS reporting.

French Obligations

As a non-resident French national, Marc's French tax obligations were limited to real estate income (taxed at the non-resident minimum of 20%, rising to 30% above EUR 27,478, plus 17.2% prélèvements sociaux). His French properties fell below the EUR 1.3 million IFI threshold — no wealth tax was due.

Critically, no French exit tax was triggered. Marc had not been French tax resident since 2015. Article 167 bis CGI only applies to individuals who have been French tax resident for at least six of the preceding ten years. His decade in London had cleared the window — the single most valuable structural advantage of the timing. Had he returned to France first and re-established tax residence, the six-of-ten-year clock would have restarted.

Russian Tax Position

Marc's Russian tax status was that of a non-resident permanent resident holder — a category that is more common than most people assume. Under Article 207(2) of the Tax Code, tax residency requires 183 days of physical presence within any 12-consecutive-month period. Marc spent approximately twelve days in Russia during 2025 (the consultation visit in March and two subsequent business trips). He was, for tax purposes, a non-resident.

His Russian tax exposure:

• OFZ coupon income: Taxed at 30% (non-resident rate). Annual coupons of approximately 2.04 million RUB generated a tax liability of roughly 612,000 RUB (approximately EUR 6,100). This was withheld at source by the brokerage.
• No other Russian-source income. Marc did not operate a Russian company, did not hold Russian real estate (beyond the bond position), and did not receive any employment income from Russia.
• Total Russian tax liability (2025): Approximately EUR 6,100.

For comparison, his estimated UK liability under the new worldwide taxation rules would have been approximately GBP 840,000 (EUR 980,000). His estimated French liability had he returned to France would have exceeded EUR 1.4 million (including social contributions). The differential was not marginal — it was transformational.

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Outcome: Timeline, Costs, and Results

Timeline

Golden Visa obtained in five months. Full restructuring — immigration, corporate, and tax — completed in seven.

Costs

The TRF payment was a one-time strategic decision — tax-efficient extraction of previously sheltered UK income at 12%, not a cost of the Russian relocation itself.

Annual Tax Comparison

These figures assume Marc maintains non-resident status in Russia (fewer than 183 days) and derives income primarily from non-Russian sources through the Cyprus holding structure.

Quality of Life

Marc did not relocate his daily life to Moscow. He rents an apartment in Berlin and travels to London, Frankfurt, Amsterdam, and Lyon for business and family. He visited Moscow twice in the first year — both times for meetings with our firm and his Russian brokerage. His physical location is determined by his client base and personal preferences, not by any residency obligation.

"The Golden Visa gave me something no other program offered — the ability to separate where I live from where I am legally resident," Marc said during our twelve-month review. "I am a European entrepreneur who happens to hold Russian permanent residence, and that single fact reduced my annual tax bill by roughly a million euros."

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Lessons From This Engagement

This case crystallized several patterns we see repeatedly in former non-dom relocations:

1. The underlying problem is structural, not event-driven. The non-dom abolition was the trigger, but the root cause is the absence of any European jurisdiction offering competitive tax treatment for mobile entrepreneurs with globally diversified income. The jurisdictions now attracting these clients are overwhelmingly outside Europe.

2. France is a destination trap for returning nationals. High marginal rates (45%+), social contributions (17.2% on investment income), IFI, and exit tax create a jurisdiction that is expensive to inhabit and expensive to leave. French nationals who have been non-resident long enough to clear the six-of-ten-year exit tax window should think carefully before re-establishing French tax residence.

3. The UK exit window is closing. The Temporary Repatriation Facility at 12% expires April 2027. Former non-doms who have not utilized it are facing a narrowing window that is unlikely to be extended.

4. Zero physical presence is the structural differentiator. Every alternative Marc evaluated imposed some form of mandatory presence. For an entrepreneur traveling across multiple European cities, any presence obligation creates scheduling conflicts and tax residency triggers in other jurisdictions. Russia's zero-presence architecture eliminates all of these.

5. The bond investment is not dead capital. At 13.6% annual coupons, Marc's OFZ position generates EUR 20,400 per year on a EUR 152,000 investment. After non-resident withholding (30%), net annual income is approximately EUR 14,300 — a 9.4% net return on sovereign-guaranteed debt.

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This case study is presented for informational and educational purposes only. It does not constitute legal advice, and it should not be relied upon as a basis for any business, investment, or immigration decision. The outcomes described reflect a specific set of circumstances and may not be representative of results in other cases. Tax laws and immigration regulations change frequently. Readers are strongly encouraged to consult qualified legal, tax, and immigration professionals before undertaking any cross-border relocation.

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Next Steps

If you are a former non-dom evaluating alternatives, or a European entrepreneur considering jurisdictional restructuring, our cross-border advisory team provides structured assessments covering Golden Visa eligibility, tax transition planning, corporate restructuring, and ongoing compliance.

Explore the Golden Visa program or schedule a consultation to discuss your situation.