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UK income tax at 45%. Capital gains at 24%. Inheritance tax at 40% on estates above £325,000. Non-dom status — the last domestic refuge for mobile wealth — was abolished in April 2025 with no replacement. France, Italy, and Germany are moving in the same direction.

CRS automatic exchange operates in 120+ jurisdictions. OECD BEPS Pillar Two is in force. BVI, Cayman, and Jersey have become operationally expensive and reputationally dangerous. The compliance cost now exceeds the yield benefit. The offshore era is structurally over.

Prime London commercial yields average 3.2%. Paris and Frankfurt are lower. After tax, management fees, and inflation, the real return on Western real estate is negligible or negative. Capital is sitting in the wrong place — not because better options don't exist, but because they are not yet visible to Western advisors.

HNWIs with crypto and digital asset exposure operate in a regulatory gap. MiCA imposes compliance obligations without providing the custody infrastructure that family offices require. There is no European platform that handles tokenized real assets, digital custody, and wealth planning within a single regulated framework. Until now.

This is the right question to ask and we raise it ourselves. The current Georgian government has distanced itself from EU accession talks — a political decision with real geopolitical consequences. What it has not done, and what no Georgian government has ever done, is touch the tax code, impose capital controls, or interfere with the banking system. TBC Bank and Bank of Georgia have operated through every Georgian political crisis since 1991 and remained fully functional, LSE-listed, and Basel III compliant throughout. The territorial tax system is codified law, not a concession — it does not require political goodwill to maintain. Aurum structures are built on legal foundations that have outlasted every Georgian political cycle to date. We hold cash in LSE-listed banks and assets in SPV-isolated structures. The exposure to political risk is real but bounded and manageable.

TBC Bank (TBCG.L) and Bank of Georgia (BGEO.L) are not Georgian domestic banks in any conventional sense. They are internationally listed, Basel III regulated, with full SWIFT correspondent relationships through major European clearing banks. Both hold capital ratios well above Basel III minimums. Both are audited by Big Four firms and report to the London Stock Exchange. Georgia has never imposed capital controls in its 30+ year history as a sovereign state — including through the 2008 war, the 2014 Russian sanctions crisis, and the COVID shock. Client assets within Aurum vaults are held in SPV-isolated structures, not on bank balance sheets. Custody risk and bank credit risk are separate.

Georgia imposes no exit tax — unlike France (which charges a departure tax on unrealised gains), the US (which taxes citizens globally regardless of residency), or most European jurisdictions. Selling Georgian assets, closing a Georgian bank account, or ending Georgian tax residency is straightforward and involves no punitive exit event. Vault positions can be sold on the secondary market. SPV structures can be wound down. Georgian tax residency simply lapses if the 183-day rule is not met in a given year. There is no lock-in. Aurum is designed to be entered and exited cleanly — because clients who feel free to leave are the ones who choose to stay.

Georgia has 58 double tax treaties covering every major jurisdiction including the UK, Germany, France, UAE, and most of the CIS. Georgian tax residency certificates are recognised by treaty partner countries. Aurum structures every client arrangement to be fully reportable, fully documented, and fully compliant with home-country disclosure obligations under CRS. We engage international law firms, including Mayer Brown where required, alongside local tax counsel in the client's home jurisdiction to ensure the structure is defensible in front of any tax authority. This is onshore, transparent, and treaty-backed — the opposite of an offshore structure that relies on opacity.

Consider a client with a USD 20M estate. In the UK, that estate faces 40% IHT above the £325,000 nil-rate band — a tax bill approaching USD 8M. In Georgia, the same estate passes to the next generation with zero inheritance tax, zero gift tax, and zero wealth tax. Over two generations, the compounding of that saving — reinvested at 7–12% commercial yields — is transformational. Aurum can structure trust-equivalent arrangements using Georgian legal vehicles for estate planning. The HNWI route to residency can be obtained by family members independently, creating a family-wide Georgian tax position.

You do not need to. The HNWI tax residency route requires approximately three weeks of physical presence in Georgia per year — not 183 days. A USD 500,000 investment in Georgian assets (qualifying property, bank deposits, or vault allocations) plus proof of GEL 3 million in global wealth establishes the HNWI status. You can continue to live in London, Dubai, or anywhere else and retain Georgian tax residency as your primary legal tax position, subject to ensuring you do not trigger tax residency in your country of presence. Aurum's tax counsel will model this precisely for your situation.