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Research & Articles

Guides for advisers and private clients.

Detailed articles on CBI and RBI programme selection, FATF compliance, corporate structuring, and the tax and regulatory considerations behind cross-border investment migration.

TAX TECHNOLOGY

E-Invoicing Mandates: How Cross-Border Compliance Obligations Are Converging

Clearance and post-audit architectures, why multi-jurisdiction operations are disproportionately affected, and the failures that actually cause disruption — master data, non-standard billing, and rejection handling.

EU VAT & REPORTING

EU Digital Reporting Requirements: What the VAT Reform Changes

Three pillars of the reform, why the shift from periodic to transaction-level reporting changes control design, and the preparation that pays regardless of when any particular obligation bites.

INTERNATIONAL TAX

Permanent Establishment Risk in Cross-Border Operations

The fixed place of business and dependent agent routes, why formal signing authority is no longer the test, where exposure arises unintentionally, and why the consequences reach backwards.

CORPORATE STRUCTURING

Choosing a Holding Jurisdiction for International Operations

Why the headline corporate rate is usually irrelevant, how substance requirements and the principal purpose test changed the analysis, and the errors that recur.

COUNTERPARTY RISK

Third-Party and Supplier Due Diligence: Building a Defensible Programme

What risk-based tiering actually means, why beneficial ownership is the hard part, and the records that make a programme defensible when it is examined.

SANCTIONS

Sanctions Screening in International Supply Chains

Overlapping regimes and extraterritorial reach, why ownership and control tests catch entities absent from every list, and why disclosure decisions are time-sensitive.

LEGAL STRUCTURES

Legal Structures Behind Citizenship by Investment

How the legal architecture underpinning citizenship by investment programmes is constructed — statutory basis, administering bodies, and the contractual position of an approved applicant — and what that means when assessing how durable a programme is.

INVESTMENT MIGRATION

Residence by Investment vs Citizenship by Investment: What Corporate Clients Actually Need

The two routes serve different objectives. A comparative guide covering mobility, tax residency, travel documents, succession planning, timelines, and regulatory risk — with a clear account of which clients genuinely need citizenship versus those who only need residency.

COMPLIANCE

FATF Compliance and CBI Programs: How Due Diligence Standards Are Evolving in 2026

FATF's 2022 guidance on RBI and CBI programmes identified five structural risk factors. A guide to enhanced due diligence standards, PEP screening, source of funds documentation, grey listing risk, and what advisers must do to stay compliant.

CORPORATE STRUCTURING

Holding Company Structures for CBI Investors: Tax Efficiency Across Jurisdictions

A holding company manages income flows, accesses treaty networks, and supports estate planning — but only if structured around where the investor actually resides and what they earn. A cross-jurisdictional guide covering substance requirements, treaty shopping limits, and CFC rules.

PACIFIC PROGRAMS · VANUATU

Vanuatu DSP Citizenship in 2026: The Complete Investor’s Guide

Investment tiers, DSP screening (including Red Notice checks), processing timeline, passport value, tax implications, and what to prepare before engaging an agent.

LEGAL RIGHTS · ECHR

ECHR and Citizenship Revocation: Legal Protections for Investors

How European human rights law limits citizenship revocation — Article 8 proportionality, Malta/CJEU intersection, sanctions designation and ECHR challenges, and interim measures.

DUE DILIGENCE · RED NOTICES

Interpol Red Notice and CBI Applications: Legal Strategy Before You Apply

CCF deletion strategy, sequencing CCF vs. CBI application, Caribbean rejection database risk, documentation strategy for complex profiles, and what happens after rejection.


Articles are for general reference only — not legal, tax, or investment advice. Speak with a qualified adviser before making any investment migration or structuring decision. Contact BNO Partners.