Published on and written by Cyril Jarnias
For an investor already well exposed to the eurozone—French real estate, European stocks, euro bonds—the real question is no longer “where to pay less tax”, but “which country adds a new building block that truly diversifies risk while staying within a clear European framework.” From this perspective, Cyprus and Portugal come up systematically in discussions: attractive tax regimes, gateways to the EU, promising real estate markets, and specific programs for entrepreneurs and investors.
Cyprus is more aggressive tax-wise, especially for entrepreneurs and financial income. Portugal offers a more conventional system with higher taxes, but a deeper real estate market, a larger economy, and a more stable, transparent political environment.
The challenge for an already structured European portfolio is to understand what each of these two countries really adds: geographic and tax diversification, exposure to different real estate markets, corporate structuring strategies, estate planning, and family mobility. And what these choices entail, both in opportunities and risks.
Cyprus: A Highly Competitive Tax and Wealth Platform
Cyprus has built a reputation as a hub for entrepreneurs, startups, and holders of mobile income (dividends, interest, capital gains on securities). The island once had a reputation as an opaque center, especially around Russian flows, but today it is integrated into European standards (CRS, FATCA, BEPS) and cooperates with the FATF. Since joining the EU and the official end of the “offshore” regime, Cypriot companies operate within standard European law.
Corporate Tax, IP Box, and the 2026 Reform
For years, Cyprus boasted one of the lowest corporate tax rates in the European Union at 12.5%. Under pressure from the OECD Pillar Two, a reform voted in late 2025 raises this rate to 15% effective January 1, 2026. This puts the country at the floor of the new global minimum while remaining competitive within the EU.
The key point for an investor or entrepreneur looking to diversify asset ownership is the combination of this rate with the Cypriot IP Box regime. This allows a deduction of 80% of eligible profits from intellectual property. In practice, with a nominal rate of 15%, the effective rate on IP income drops to around 3%. Some sources historically refer to an “IP Box” bringing the tax burden to about 2.5%, but the logic remains the same: for a business heavily focused on software, platforms, patents, or digital content, Cyprus offers a tax environment that is hard to beat within the EU.
The 2026 reform affects not only corporate tax but also the taxation of individuals: the exemption threshold rises to €22,000 of annual income, a progressive rate schedule ranging from 0% to 35%, adjustments to special contributions, and overall better clarity of the system.
We can summarize the basic framework as follows: the fundamental elements that define the structure and principles of a system or theory.
| Key Parameter | Cyprus (as of 2026) |
|---|---|
| Standard CIT | 15% |
| IP Box Regime | Effective rate ≈ 3% on IP |
| PIT (general schedule) | 0% – 35% |
| PIT exemption threshold | €22,000 |
| Wealth tax | None |
For an operating holding company or an IP licensing structure, this architecture remains a significant advantage for diversifying a group already present in France, Germany, Benelux, or Spain.
The Non-Dom Regime: A Major Lever on Dividends and Interest
The other pillar making Cyprus a serious candidate for wealth diversification is the “non-domiciled” (Non-Dom) status. It applies to individuals who become tax residents in Cyprus without being considered “domiciled” there under local law. In practice, the Non-Dom status provides a very broad exemption from the Special Defense Contribution (SDC) on dividends, interest, and certain worldwide real estate income.
The essential elements of the regime are as follows:
| Non-Dom Regime Element | Main Features |
|---|---|
| Basic condition | Be a tax resident but not domiciled in Cyprus |
| Initial duration | 17 years of SDC exemption on dividends, interest, certain rents |
| Possible extension | Up to 27 years via flat contributions (€50,000/year or €250,000/5 years) |
| SDC rate on dividends (domiciled) | 5% as of 2026 (previously 17%) |
| Dividends received by a Non-Dom | 0% SDC (i.e., 0% on dividends under this contribution) |
| Wealth tax, inheritance, gifts | 0% (no wealth tax, no inheritance/gift duties) |
For an investor already holding a significant portion of their wealth in unlisted securities, group holdings, or dividend portfolios, the ability to channel these flows into a Cypriot Non-Dom residence can radically transform the overall tax burden on the estate. The absence of wealth tax and inheritance/gift duties further enhances the appeal for intergenerational transfer strategies.
Note: the 2026 reform introduces the possibility of extending this regime via an annual or 5-year flat contribution, offering visibility for up to nearly three decades for families planning long-term succession.
Personal Taxation: Rate Schedule, Pensions, Capital Gains
Outside the Non-Dom regime, Cyprus’s personal income tax schedule remains moderate:
– 0% up to €22,000 of taxable income.
– Progressive rates up to 35% above €72,000.
– Full exemption for income below the threshold.
– Flat tax of 5% on foreign-source pensions.
Added to this are targeted measures: deductions for family and housing expenses, capped based on income level, and a clarification of crypto-asset taxation with a flat rate of 8% under certain conditions.
On capital gains, Cyprus applies a very favorable logic for financial capital:
The exemption threshold for capital gains on a primary residence in Cyprus is raised to 150,000 euros.
The practical consequence is clear: for a portfolio already heavily exposed to residential real estate in France and subject to wealth tax (ISF / IFI), parking part of the financial assets and “investment” real estate in Cypriot structures helps reduce the tax friction on securities arbitrage and dividend distribution.
Legal Security, Treaties, and Economic Environment
Cyprus has a very dense network of bilateral tax treaties, with more than 65 double taxation agreements in force. The country has ratified the BEPS multilateral instrument, including the introduction of a “Principal Purpose Test”: purely artificial structures designed to capture a tax advantage without economic substance are theoretically targeted.
On the macroeconomic front, the island shows a robust growth profile, driven by services, tourism, and information technology. The European Commission projects growth around 3% in 2025 and 2.5% in 2026, placing Cyprus near the top of the eurozone range. The economy was certainly shaken by the war in Ukraine and the reduction in Russian presence, but the authorities are betting on innovation, startups, and “clean” finance to reposition the country.
Real Estate in Cyprus: Yield and Capital Appreciation Rather Than Steady Income
For a portfolio already well seated in “city center” residential real estate in France or Germany, the question is: does Cypriot real estate offer anything more than sunshine?
Recent data show a dynamic market, but one that is normalizing after several years of strong increases:
Expected price increases and rental yields on the Cypriot market
In 2024, prices rise by about 4.2%, and stay around 5% in 2025.
For 2026, the average increase is between 3% and 7%, with a central scenario close to 5%.
New seafront apartments in Limassol or Paphos can see increases of 8% to 10%.
Average gross residential yields of 4% nationwide, 5.5-6% in major cities, and up to 7-9% for highly sought‑after properties or seasonal rentals.
An investor can hardly ignore figures like these:
| Cypriot Real Estate Market (order of magnitude) | Typical Value 2025‑2026 |
|---|---|
| Annual price increase (national) | 3% – 5% (up to 7‑8% on certain axes) |
| Gross yield on apartments (national average) | ≈ 5.2% |
| Gross yield in Limassol (apartments) | 5.5% – 7% |
| Gross yield in Paphos (apartments) | 5% – 6.5% (up to 8‑9% seasonal) |
| Gross yield in Larnaca | 5% – 6% |
| Gross yield in Nicosia | 4% – 5% (6‑8% on targeted small units) |
The abolition of the Special Defense Contribution on rents for residents (and its absence for Non-Doms) further improves net yields. Rents continue to grow by about 4‑5% per year, supported by strong rental demand (expats, students, IT and finance professionals, tourism).
Cyprus is not a “steady income” market like a Parisian city center; it is more of a high yield/risk profile, with:
– strong seasonality in certain areas (Ayia Napa, Protaras),
– dependence on tourism and international expat flows,
– a smaller market and therefore more exposed to sectoral or geopolitical shocks.
On the flip side, a well‑located apartment in Limassol or Paphos can generate a net yield significantly higher than most Western European capitals, while also offering good capital appreciation potential.
Residence, Visas, and Investor Programs
For an investor looking to combine wealth diversification with personal mobility, Cyprus offers:
– A “Golden Visa” granting a permanent residence permit in exchange for a real estate investment of at least €300,000 (plus VAT), along with a bank deposit of €30,000 and a minimum annual income (around €50,000) from non‑Cypriot sources.
– A lifetime residence permit, requiring a visit to the country at least once every two years.
– A Startup Visa program open to entrepreneurs from third countries, with residence and work rights for up to three years, renewable, and relatively modest capital requirements (starting from €20,000 in capital for certain forms).
Cyprus is not in Schengen, which limits the “mobility passport” effect within the European area compared to Portugal. However, for an entrepreneur who already travels extensively outside the EU (Middle East, Israel, Asia), being based in Cyprus can fit into a broader Mediterranean / Near East logic.
Portugal: Heavier Taxation, but Market Depth and Stability
In contrast to Cyprus’s very tax‑driven profile, Portugal today presents itself as a “more normal” destination from a European perspective: high individual tax brackets, standard CIT rate, 23% VAT, significant social charges. The country has also turned the page on its famous NHR (non‑habitual resident) regime for new entrants, replaced by more targeted measures.
For an already structured European portfolio, Portugal’s appeal now lies mainly in:
– the depth and dynamism of its real estate market,
– the quality and size of its economy compared to Cyprus,
– still attractive tax niches (Madeira, funds, IFICI for very specific profiles),
– a relatively reassuring legal and inheritance framework.
Corporate Taxation: 21% (and a Mosaic of Exceptions)
The standard corporate tax rate in Portugal is 21%. On top of this, there are:
– a municipal surcharge (“derrama municipal”) that can go up to 1.5% depending on the location,
– a progressive state surcharge of 3% to 9% on profits exceeding €1.5 million.
SMEs benefit from a reduced rate on the first tranche of profits:
| CIT in Portugal (general regime) | Indicative Rate |
|---|---|
| Standard national rate | 21% |
| Municipal surcharge (max.) | + 1.5% |
| State surcharge (above €1.5M profit) | 3% to 9% |
| SME – 1st tier (up to €50,000 profit) | 17% currently, 15% as of 2026 |
| Qualified startups (Law 21/2023) – 1st tier | 12.5% on €50,000, subject to aid constraints |
The autonomous regions of Madeira and the Azores apply a 30% reduction on the national rate, bringing effective CIT down to around 13% for certain activities. In Madeira, the “Free Trade Zone” (MIBC) even offers a rate of 5% on certain qualified income, subject to local substance and numerous conditions.
Overall, a group already established in several member states will find in Portugal a more conventional environment than Cyprus, poorly suited to purely tax‑driven structures, but relevant for setting up an industrial, logistics, or high‑value‑added services subsidiary, especially if leveraging investment incentive mechanisms (RCPBI, SIFIDE II).
Personal Taxation: A Return to Standard… With a Few Niches
For newcomers, Portugal now applies a progressive income tax schedule ranging from about 14.5% to 48%, to which a solidarity contribution of up to 5% on income above €80,000 may be added. Social security contributions are high: in an employee regime, about 34.75% of gross salary is paid (23.75% by the employer, 11% by the employee).
The NHR regime for retirees and qualified professionals has been closed to new entrants since 2024. Previous beneficiaries keep their advantages for 10 years. For 2026, the new scheme to use is the IFICI (NHR 2.0).
The salient features of this new regime:
| IFICI / NHR 2.0 in Portugal | Main Features |
|---|---|
| Target audience | Highly qualified profiles (tech, R&D, innovation, higher education, strategic management) |
| Residency condition | Not have been a Portuguese tax resident in the previous 5 years |
| Duration | 10 years, non‑renewable |
| Rate on Category A and B income | 20% (instead of schedule up to 48%) |
| Dividends / interest / foreign rents | Possible exemption, subject to conditions and treaties |
| Pensions | No specific advantage for new applicants |
In other words, for a highly qualified executive or a tech entrepreneur who genuinely wants to settle and work in Portugal, the IFICI remains attractive. For a rentier or retiree primarily seeking massive tax relief on passive income, the country is much less appealing than it was between 2010 and 2020.
Portuguese-source dividend income is, by default, taxed at 28% for individuals, with options to opt for the regular schedule. Under IFICI, specific flows may benefit from better treatment, but this is far from Cyprus’s 0% for Non-Doms on worldwide dividends.
Wealth Taxes, Transfers, and Capital Gains
Unlike Cyprus, Portugal has a wealth tax, the ISF (Imposto sobre o Património), applicable to individuals holding net real estate assets exceeding €600,000. The rate ranges from 0.4% to 1% on that base. For an investor already heavily exposed to residential real estate, this is a factor to include in the analysis: adding Portugal means adding a country that explicitly taxes wealth holdings above a certain threshold.
On inheritance, however, Portugal appears surprisingly gentle. There is no, in the French sense, inheritance tax for spouses, children, grandchildren, or parents: the rate is 0% for direct descendants/ascendants. However, heirs outside the direct line (siblings, nieces/nephews, friends) are subject to a 10% duty via the “stamp duty” mechanism.
For a family estate already structured, the combination of:
– no inheritance tax in the direct line,
– a limited wealth tax,
– possible high exposure to real estate,
creates an interesting profile: Portugal can be a good base for housing assets intended to stay in the family for several generations, while anticipating the local wealth tax.
On capital gains:
Real estate gains are generally treated as income, with half included in the taxable base for residents, then subject to the progressive schedule up to 48%. A non‑resident is taxed at a rate calculated by taking into account their worldwide income to determine the bracket, which can result in high effective taxation. For securities, the standard rate is 28% on gains, with certain possibilities of exemption under the old NHR regimes or via treaties.
Compared to Cyprus, Portugal is clearly less favorable for capital gains on securities and dividend distribution, but represents a well‑known and acceptable terrain for many European investors accustomed to high tax brackets.
Portuguese Real Estate: Depth, Tension, and Long‑Term Outlook
Where Cyprus offers a smaller but very profitable market, Portugal has a deep, diversified, highly sought‑after real estate market by foreign investors – and one that is already very expensive.
Recent figures show:
– A national average price around €2,200 to €2,600/m² at the start of 2026, with a median price close to €1,923/m².
– Spectacular increases in recent years: +17.6% in 2025 nationally, +18.9% in the fourth quarter alone.
– For 2026, a “soft landing” scenario with a national increase around 2% to 4%, or even 5% to 8% in the tightest areas.
– Fitch Ratings has raised the possibility of a further increase of 15% in certain particularly undersupplied segments, after about +18% in 2025.
The major markets stand out clearly:
| Area | Average Price/m² (order of magnitude 2025‑2026) | Recent Change | Typical Gross Rental Yield |
|---|---|---|---|
| Lisbon city | ≈ €5,000 to €6,000/m² (more in hyper‑center) | +115% since 2017, +9‑18% in 2025 | 3% – 4.5% |
| Lisbon region | ≈ €3,100 to €4,500/m² | Strong rise, gradual stabilization | 3.5% – 5% |
| Porto | ≈ €3,000 to €4,000/m² | Sustained increase, catching up with Lisbon | 4% – 6% |
| Algarve | ≈ €3,000 to €4,000/m² (Lagos ≈ €4,450/m²) | +16.6% in some areas | 5% – 7% seasonal |
| Interior | €1,000 – €1,800/m² | Moderate rise | Up to 5‑6% |
The implicit message is twofold:
– for an investor seeking pure yield, the centers of Lisbon and Porto already offer levels similar to major European capitals: high rents but even higher prices, limiting gross yields to 3‑4% in the most expensive neighborhoods;
– for opportunistic diversification, the outskirts, mid‑sized cities (Braga, Setúbal, Coimbra, Viseu, Évora, etc.) and parts of the Algarve can still offer 5‑6% gross with medium‑term capital appreciation potential.
Acquisition costs are not negligible: between 5 and 7% of the price via IMT, stamp duty, notary and registration fees. IMT can go up to 7.5% on the most expensive properties, which requires a long‑term investment horizon.
On the other hand, the structural stability of the market is an important argument for someone looking to diversify a large volume of assets: city sizes, rental depth, infrastructure, tourist flows, and expat demographics give Portugal a visibility that few Mediterranean markets can offer.
Funds, Private Equity, and Investment Vehicles
The closure of the direct real estate route for the Portuguese Golden Visa has shifted interest toward investment funds and private equity. Capital‑investment funds governed by Decree‑Law 7/2015 benefit from a very favorable regime:
For a non‑resident, income distributed by a Portuguese fund is subject to a 0% withholding tax. For a Portuguese resident, the same distribution can be taxed at only 10%, a rate far below the usual 28% on standard financial products.
This regime positions Portuguese funds as a powerful alternative for diversifying a portfolio already structured elsewhere in Europe, by combining:
– exposure to the Portuguese real economy (real estate, infrastructure, SMEs),
– a tax‑efficient holding wrapper,
– access via investment tickets compatible with family office or high‑net‑worth strategies.
Portugal therefore combines a very attractive physical real estate market with a layer of sophisticated investment vehicles, which is particularly well suited for an already well‑equipped investor looking to add a pocket of private equity, infrastructure, or “paper” real estate alongside their SCPIs or Luxembourg funds.
Residence, Mobility, and Schengen: Advantage Portugal
On personal mobility, Portugal has an asset that Cyprus does not yet have: membership in the Schengen Area. A holder of a Portuguese residence permit can travel 90 days out of 180 in other Schengen states without a visa.
The Portuguese “Golden Visa” scheme has evolved:
– no more direct investment in residential property to obtain the visa (since the “Mais Habitação” reform),
– but it is possible to obtain the title through investments in funds (from €500,000), research projects, culture, or job creation.
This Golden Visa remains very flexible in terms of physical presence (about 7 days per year on average) and allows applying for permanent residence and citizenship after 5 years.
In addition, the D2 (entrepreneur), D7 (passive income), and D8 (remote work) visas offer more “100% residence” paths for families who genuinely want to live and work in Portugal. Again, for a family already deeply rooted in the EU, the appeal is as much wealth‑related as lifestyle: schooling, healthcare, infrastructure, legal security.
Comparing Cyprus and Portugal for an Already Structured Portfolio
Once the basic characteristics are laid out, the thinking should be like that of an already well‑established investor: substantial French or German real estate, pockets of international equities, bonds, perhaps some SCPIs, and a start at diversification outside Europe.
Corporate Taxation and Investment Income: Net Advantage for Cyprus
For a holding company, a digital operating company, an IP vehicle, or a structure designed to centralize dividends, the comparison is clear:
| Criteria | Cyprus | Portugal |
|---|---|---|
| Standard CIT | 15% (12.5% before 2026) | 21% + surcharges |
| IP Box | Effective rate ≈ 3% | Much less competitive IP regime |
| Dividends received (Non‑Dom) | 0% SDC (i.e., 0% on dividends) | 28% standard, 0% possible under IFICI for certain foreign dividends |
| Capital gains on securities | Exempt (except local real estate) | 28% standard (with variations) |
| Wealth tax | None | ISF 0.4% to 1% above €600,000 |
To diversify the taxation of a group already taxed in several EU countries, Cyprus perfectly fills the role of a low‑CIT European jurisdiction, secure, open to IP activities, with no tax on dividends or capital gains for Non-Doms, and no wealth tax.
Portugal, on the other hand, is no longer a tax “paradise” for high incomes: standard CIT, high brackets, significant social charges. There are still pockets of competitiveness (Madeira Free Zone, IFICI, funds), but these are niches, not the norm.
Personal Taxation and Inheritance: Two Opposite Philosophies
For a family estate, the comparison must include:
– taxation of current income,
– taxation of capital,
– taxation of inheritances and gifts.
Cyprus is designed for holders of mobile capital
Anonymous source
– Non‑Dom = 0% on worldwide dividends and interest (SDC),
– total absence of wealth tax, inheritance tax, and gift tax,
– progressive PIT but with a relatively high non‑taxable threshold and rates capped at 35%.
Portugal is much less so:
– PIT schedule up to 48%, solidarity surcharge up to 5% more,
– ISF between 0.4% and 1%,
– 0% inheritance tax in the direct line but 10% for other heirs,
– no specific advantage for newcomers on passive income (except IFICI executives under conditions).
For an investor who has already concentrated a significant part of their wealth in countries with heavy inheritance taxes (France, Belgium, Spain), opening a Non‑Dom residence in Cyprus allows:
– relocating the taxation of dividends and interest,
– neutralizing inheritance taxes on assets held in Cypriot structures,
– smoothing the overall family tax burden over several decades.
Portugal allows organizing intra‑family transfers free of inheritance tax on local real estate, but this does not solve the taxation of worldwide financial flows.
Real Estate: Cypriot Yields vs. Portuguese Depth
For a portfolio already heavily exposed to French or German residential real estate, an allocation between Cypriot and Portuguese real estate primarily serves to:
– diversify geographically,
– diversify the drivers of appreciation and yield,
– diversify tax regimes.
We can summarize the profiles:
| Real Estate Aspect | Cyprus | Portugal |
|---|---|---|
| Market size | Small, heavily tourism/expats oriented | Large, diversified (capital, regions, countryside) |
| Recent price growth | 4‑5%/year, 6‑8% on prime areas | 15‑18%/year recently, 2‑7% expected in 2026 |
| Typical gross yields | 5‑6% (up to 7‑9% depending on area) | 3‑4% in centers, 5‑7% in outskirts/Algarve |
| Rental taxation | Progressive PIT, no wealth tax, Non‑Dom exempt from SDC | Progressive PIT, real estate wealth tax, specific non‑resident rate (25%) |
| Acquisition costs | Moderate | 5‑7% (IMT, Selo, notary) |
| Role for a large portfolio | Yield/appreciation pocket, non‑correlated | Long‑term diversification pillar, deep market |
An investor “already well served” in European real estate can use Cyprus as an opportunistic high‑yield pocket (e.g., 5‑6% net in targeted neighborhoods in Limassol or Paphos), with higher risk, but light taxation on holding and disposal.
Portugal, conversely, becomes a core portfolio building block: deep market, stability, strong international demand, sophisticated instruments (funds, real estate private equity). Gross yields will generally be more modest, but the amounts that can be invested are much larger and more easily absorbed.
Mobility, Image, and Political Risk
Finally, wealth diversification is not only about spreadsheet comparisons. It also includes:
When evaluating a country for relocation, one must consider how that country is perceived by other states’ tax authorities, legal and political security, and the ability for family members to live, study, and work there.
On these points:
– Portugal enjoys an extremely positive image: stable rule of law, eurozone and Schengen member, “mainstream” reputation in the eyes of foreign tax administrations. It is an ideal country for hosting the primary or secondary residence of part of the family, schooling children, and anchoring a long‑term strategy.
– Cyprus still carries a more ambivalent image, although it is fading: a financial services hub, a history with Russian capital, the country’s small size. However, it is an EU member and applies the latest tax transparency standards, which limits the risk of outright challenge to properly set‑up structures.
An important point: true geographical diversification requires not just stacking “easy” countries from a tax perspective. It is precisely the balance between a very competitive jurisdiction (Cyprus) and a very conventional one (Portugal) that gives robustness to an international wealth structure.
How to Articulate Cyprus and Portugal in a Global Strategy
For an already structured European portfolio, the question is not necessarily “choose one or the other”, but rather “what role to assign to each.”
A coherent approach could look like this:
Use Cyprus for mobile flows and capital vehicles (international holdings, IP companies, structuring dividends and interest, high‑yield real estate pocket with Non‑Dom status and possibly a Golden Visa as an EU back‑up permanent residence). Meanwhile, use Portugal as a residential and economic base: set up operational activities, hold family real estate assets, invest in Portuguese funds, and offer a primary or secondary residence to part of the family.
Both countries offer, each in their own way, diversification from a portfolio concentrated in France, Germany, or Belgium, heavily exposed to domestic real estate, euro bonds, and high tax brackets.
The key in this construction is: understanding the fundamental elements.
– respect tax treaties and anti‑abuse rules (BEPS, principal purpose test),
– ensure consistency between domicile, real economic substance, and financial flows,
– articulate Cyprus and Portugal with other international components (United States, Asia, emerging markets) to avoid simply shifting risk from one European country to another.
In a context of slowing European growth and concentrated equity markets, diversification between Cyprus and Portugal allows decoupling flows, valuations, and risks, while remaining within the EU regulatory and legal framework.
For an investor already advanced in their structuring, Cyprus is the sharp tool; Portugal, the cornerstone. One without the other can work. Together, well calibrated, they make it possible to design a more resilient, more liquid European portfolio, better equipped to face the next waves of tax and monetary changes.
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Cyril Jarnias is an independent expert in international wealth management with over 20 years of experience. As an expatriate himself, he is dedicated to helping individuals and business leaders build, protect, and pass on their wealth with complete peace of mind.
On his website, cyriljarnias.com, he shares his expertise on international real estate, offshore company formation, and expatriation.
Thanks to his expertise, he offers sound advice to optimize his clients' wealth management. Cyril Jarnias is also recognized for his appearances in many prestigious media outlets such as BFM Business, les Français de l’étranger, Le Figaro, Les Echos, and Mieux vivre votre argent, where he shares his knowledge and know-how in wealth management.
