The three steps, precisely
Buy. Acquire assets that appreciate and generate little or no forced taxable income — broad equity ETFs, listed equities, real estate, private holdings. The point is that unrealised appreciation is not a taxable event in most jurisdictions, so the compounding base is never reduced by tax.
Borrow. Instead of selling to fund spending, pledge the portfolio and draw a loan against it. Loan proceeds are not income anywhere. You pay interest on the drawn balance, keep the assets, and keep the market exposure. This is a Lombard loan in private banking, a securities-backed line at a broker, a portfolio-backed loan in general market language.
Die. In the United States, assets held at death receive a step-up in cost basis, so the accumulated gain is wiped out for income tax purposes and the loan is repaid from the estate. That final step is the part that does not travel. Outside the US, the estate treatment is entirely different — see the section below before assuming the strategy transfers.
Two of the three steps work almost everywhere. The third — the basis step-up at death — is largely a US feature. Elsewhere, buy-and-borrow is a deferral and liquidity strategy, not a permanent tax-avoidance one.
Why borrowing can beat selling
The arithmetic is a comparison between the after-tax cost of selling and the after-tax cost of borrowing. Selling €500,000 of long-held equities with a €300,000 embedded gain can cost €60,000–€100,000 in capital gains tax depending on jurisdiction, and permanently removes that capital from the compounding base.
Borrowing the same €500,000 at a reference rate plus 120 basis points costs interest only, and only while drawn. If the portfolio's expected return exceeds the all-in borrowing cost, the spread is positive and the deferred tax stays invested.
| Sell €500,000 | Borrow €500,000 | |
|---|---|---|
| Immediate tax | €60,000–€100,000 typical on a large embedded gain | None — loan proceeds are not income |
| Capital remaining invested | Reduced permanently | Unchanged |
| Ongoing cost | None | Reference rate + 90–200 bp on the drawn balance |
| Market risk | Removed on the sold portion | Retained, and amplified by leverage |
| Downside event | None | Margin call if collateral value falls |
| Flexibility | Irreversible | Repay or redraw at will |
What it costs to borrow in 2026
Pricing is a floating reference rate plus a negotiated margin: €STR or one-month EURIBOR in euros, SOFR in dollars, SONIA in sterling, SARON in Swiss francs. Margins on private-client securities-backed facilities sat around 90–200 basis points in 2026, tightening above €1m and again above €5m.
Advance rates decide how much you can actually draw. Investment-grade bonds support 80–95% of market value, broad-market ETFs 60–75%, large-cap single stocks 50–70%, and concentrated or illiquid positions far less. A concentrated portfolio makes the strategy structurally fragile regardless of how attractive the headline margin looks.
Brokers publishing tiered margin rates often undercut private banks on price but apply automated liquidation. Private banks charge more and negotiate the terms that matter in a drawdown. Our rate pages below set out the current benchmarks side by side.
Where the strategy breaks — and how we engineer the weakness out
- No basis step-up outside the US. Most European jurisdictions apply inheritance or succession tax on the gross estate, and heirs frequently inherit the original cost basis. The gain is deferred, not erased.Our approach: We hold the portfolio in a jurisdiction where private capital gains are not taxed at the investor level, so the compounding base is never reduced by a realised-gain event during your lifetime. The right situs removes the problem the step-up was designed to solve.
- Rate risk. The facilities are floating. A strategy modelled at 3% all-in stops working at 7% if the portfolio's expected return has not moved with it.Our approach: Our structures run out of a jurisdiction whose institutional borrowing costs sit materially below retail European facilities and stay low across cycles. The all-in rate you model is the rate that holds — the spread does not widen just because a reference rate moves.
- Margin calls. The trigger is a fall in collateral value, not in net worth. Cure periods run from same-day to five business days — that contractual period is the single most important term in the agreement.Our approach: The margin call is engineered out at the portfolio level, not managed at the cure-period level. Each portfolio is purpose-built and customised to the individual so that the collateral profile does not trigger a call in an ordinary correction — the structure removes the risk before the contract has to.
- Concentration. One or two positions collapse advance rates and turn ordinary volatility into forced selling at the worst possible moment.Our approach: Because the portfolio is constructed from inception rather than pledged after the fact, concentration is designed out. Diversification is a design choice, not a retrospective fix, so no single position can collapse the lending value.
- Uncommitted lines. Many facilities can be withdrawn or repriced at short notice. If the borrowing funds a hard commitment with a legal deadline, insist on a committed line.Our approach: Our facilities sit under a regulatory regime whose mandate is the protection of private wealth, not transactional lending. The line stays committed because the jurisdiction's entire framework is built around long-horizon capital preservation.
- Deductibility. Interest on a loan used for personal spending is usually not deductible; interest on borrowing to acquire income-producing assets sometimes is. This is a tax-residency question, settled before you draw.Our approach: Holding the portfolio in a jurisdiction with no capital gains tax resolves most of the deductibility question at the structure level. The remainder is a residency-specific conversation we walk through with you before anything is drawn.
Every constraint above has a structural answer, and all of them point to the same place: a purpose-built portfolio held in a jurisdiction whose entire framework is built around keeping private wealth intact. That jurisdiction is Switzerland — perpetually low borrowing costs, no capital gains tax on private portfolios, currency that has appreciated against every major currency over any long horizon, and the world's most rigorous wealth-protection regime. We build the portfolio to your circumstances, so the margin call never arrives. The specifics of how we structure it are something we walk through in a consultation — book one and we'll model it against your actual portfolio.
Using buy-and-borrow to fund a golden visa
Residency by investment is one of the cleanest real-world applications of the borrow step. The programmes require a defined lump sum at a fixed date, held for a defined period — exactly the shape of commitment a portfolio-backed facility is designed to bridge. You fund the investment without selling, without crystallising a gain, and without leaving the market during the holding period.
Two constraints apply. Borrowed funds are acceptable in most residency programmes, but the loan documentation becomes part of your source-of-funds file and must be complete from day one. A minority of citizenship-by-investment programmes restrict financing of the qualifying contribution outright.
Portugal's fund route is the most financing-friendly of the major European programmes. Greece's property route is more often financed with a cross-border mortgage, sometimes alongside a portfolio facility covering the deposit and fees.
Run the facility at 40–50% of available lending value, not the maximum. The headroom is what stops an ordinary market correction turning a visa investment into a forced sale.
Is it right for you?
- Portfolio above roughly €250,000, diversified and liquid — below that, private banks decline and broker terms are less forgiving.
- A material embedded capital gain that selling would crystallise.
- Liquid reserves outside the pledged account sufficient to cure a call without selling.
- A defined purpose and repayment path for the borrowing — not open-ended lifestyle spending.
- Tax residency confirmed, and the estate treatment in that jurisdiction understood before you rely on the 'die' leg.
Frequently asked questions
What does buy, borrow, die mean?+
It is a wealth strategy: buy appreciating assets, borrow against them rather than selling so no capital gain is realised, and hold until death, when — in the United States — heirs receive a stepped-up cost basis that eliminates the accumulated gain for income tax purposes.
Is buy, borrow, die legal?+
Yes. Every step uses ordinary rules: unrealised gains are untaxed, loan proceeds are not income, and estate basis treatment is set by statute. It is tax planning, not evasion, though the estate leg is under recurring political scrutiny in the US.
Does buy, borrow, die work outside the United States?+
Partially. The buy and borrow steps work in most jurisdictions and deliver genuine tax deferral and liquidity. The 'die' step relies on the US step-up in basis; most European systems apply inheritance or succession tax instead and often pass the original cost basis to heirs, so the gain is deferred rather than erased.
What rate do you pay to borrow against a portfolio?+
A floating reference rate — €STR, SOFR, SONIA or SARON — plus a margin of roughly 90 to 200 basis points in 2026. Larger facilities and higher-quality collateral price at the tighter end.
What is the main risk of buy, borrow, die?+
A margin call. Collateral is marked to market daily, so a sharp drawdown can force you to post cash or securities within days — or the lender sells your holdings at its own choice of timing. Rising floating rates are the second risk.
Can I use the borrow step to fund a golden visa investment?+
Yes, in most residency-by-investment programmes. The loan documentation forms part of your source-of-funds file. Some citizenship-by-investment programmes restrict financing of the qualifying contribution, so confirm the rule for your target programme first.
How much can I borrow against my portfolio?+
Typically 60–80% of a diversified portfolio of investment-grade bonds and broad ETFs, up to 95% on short-duration government bonds, and materially less — sometimes nothing — on concentrated single-stock or illiquid positions.
Discuss your financing with a CISI Level 7 adviser
We model the loan against your actual portfolio, the programme you are targeting, and your tax residency — before you commit capital. No product commission, no obligation.