Liberty Stack

Structure where you live, build, and invest.

A jurisdictional stack weighted to your priorities.

Open Ranking

Why a stack?

Residence, company and capital follow different rules. Stacking them in one place can feel simple, until the rule changes, a bank closes the door, or you want to leave. Then everything moves at once: your life, your business, your capital.

A stack keeps you mobile: live here, incorporate elsewhere, hold capital where the rules stay readable. Separate the layers when you need to, align them when it helps, so one local decision doesn’t freeze the others.

Liberty Stack exists to keep that room to manoeuvre: compare territories against your priorities, then assemble life, company and capital. Ranking weights 238 territories.

Holding

Optimized setup

The existing company moves under a Cyprus holding. The owners receive holding shares, not cash.

  1. Share swap

    Same owners, same value, one company added on top. In the published example, tax on the exchange is €0.

  2. Reinvestment

    Dividends stay in the holding, then go into real estate, other companies, or stocks.

  3. A later payout

    Moving to Cyprus as a non-dom opens a personal distribution. The post puts dividend tax at 0%, aside from the GESY contribution.

Figures, cited statutes, and the graphic

Diagram by Ricardo Gorski: a 0% share swap into a Cyprus holding, 0% reinvestment (real estate, companies, stocks), then a non-dom payout.
Graphic “The 0% Tax Loophole via CY Holdings”, Ricardo Gorski (@ricardogorski, Tax.One), 15 October 2026. Source tweet.

Essential guides

Countries to incorporate

See all 16 countries → · Europe (stay on the continent) → · All guides →