Singapore-based company xxx intends to distribute dividends in the form of crypto tokens to its major shareholder, Mr. Z, a dual tax resident of Australia and Spain. To minimize tax burdens, Mr. Z seeks legal advice on setting up a tax-efficient structure for receiving the dividend.

Objectives:

1. Set up a legal entity in a country with minimal or no taxes on receiving overseas dividends (the "accumulation stage").
2. Use this legal entity as an investment vehicle for EU and non-EU markets.
3. Distribute the dividend to Mr. Z at a future date, minimizing tax burdens (the "distribution stage").

## Limitations
Regarding the restructuring of equity interests, when an individual shareholder, initially the sole owner of shares in a Singapore-based entity, decides to modify this ownership by introducing an interposing entity (e.g., a corporate body or trust), the tax implications depend on the shareholder's residency.

For Australian tax residents, under rule 122-A, if the interposing entity's ownership mirrors the original (owned by the same individual), no Capital Gains Tax (CGT) event occurs. Otherwise, a CGT event is triggered.

Similarly, for Spanish tax residents, the situation is assessed under Spain's global income taxation principles. If the restructuring involves a shift to an interposing entity not identically owned by the individual, it could be viewed as a transfer of shares for tax purposes, potentially subjecting the individual to Capital Gains Tax in Spain.

## Tools in the toolbox:

1. Mr. Z and his family can move to a tax-friendly country for the distribution stage.
2. Gibraltar has friendly tax laws, but Spanish tax authorities may scrutinize the arrangement.
3. Mr. Z could consider living in Singapore for at least three years to avoid CGT and dividend taxes. See below Bottom Line method:

### Bottom line method:

1. Mr. Z can receive the dividend directly as an individual without replacing the owner with a fund or trust. This approach is straightforward and tax-free, but it requires Mr. Z to be living in Singapore for at least three years.
2. Due to his children's school requirements, this may not align with Mr. Z's desire to live in Spain.