Speaking at the Hubbis Wealth Planning & Structuring Forum in Dubai on 7 October 2026, Michael Velten, Founder of Velten Advisors, outlined why internationally mobile families need to establish and document their tax-residence position before choosing wealth-holding vehicles or financial products, Hubbis reported.
According to Velten, planning must start with a family's factual circumstances and long-term objectives. He noted that where members live, which connections they maintain, where decisions are executed, and how specific domestic regulations and double tax treaties interact will determine the effectiveness of any wealth structure. A residence permit or a specific financial product cannot independently settle cross-border tax questions.
Velten highlighted that immigration status does not equal a conclusive tax-residence determination. In particular, obtaining permanent residency or a UAE Golden Visa does not on its own eliminate or settle tax obligations across other jurisdictions. Instead, advisors and clients must review all material links, including days spent in each jurisdiction, available residential properties, family relationships, and personal economic interests.
Velten also stressed that domestic tax residence and treaty residence operate as two separate stages. Taxpayers must first apply the domestic tax criteria of each relevant jurisdiction before evaluating whether treaty tie-breaker rules resolve conflicting claims. Furthermore, self-certifications, physical residence records, and the day-to-day management of structures must strictly align.
To illustrate these complexities, Velten presented a case study of an individual with connections to mainland China and Hong Kong, Singapore permanent residency, a UAE Golden Visa, and links to European jurisdictions. In the scenario, the individual spent 150 days in Singapore, 60 days in the UAE, and 55 days in Germany, demonstrating how multi-jurisdictional physical presence and trust arrangements complicate tax exposure.
Sources
- Hubbis · 2026-10-26
