# Residence Total Cost Matrix: Five Years of Status in Twelve Jurisdictions

> Five-year cost of residence in 12 jurisdictions for one family: state charges, locked capital, housing rules, tax on €300k passive income, PR horizon.

Author: Dana Berzeg — Attorney-at-law, Family Office (https://wiki.private.law/en/authors/berzegova)
Last modified: 2026-09-26T21:23:00.000Z
Canonical: https://wiki.private.law/en/residence-total-cost-matrix
Publisher: wiki.private.law (https://wiki.private.law)
Version: 7497d33ad53aa0e21249cc1ad04e1c2b73b7b238becd65badc9b031701c03e08
Cite as: Residence Total Cost Matrix: Five Years of Status in Twelve Jurisdictions. wiki.private.law. https://wiki.private.law/en/residence-total-cost-matrix. Version 7497d33ad53aa0e21249cc1ad04e1c2b73b7b238becd65badc9b031701c03e08.
Topics: migration
Jurisdictions: global, portugal, spain, italy, greece, cyprus, malta, switzerland, monaco, andorra, uae, turkey, thailand
Product tags: residence-permit, permanent-residence, relocation, tax-regime, wealth-planning
Semantic tags: residence-permit, permanent-residence, relocation, tax-regime, wealth-planning

---

## Concept

A residence status is priced in marketing by one number — the investment threshold — and paid for over years in four currencies at once. The first is sunk money: government charges, non-refundable contributions, transfer taxes on a qualifying asset and the premiums of a mandatory health policy. The second is locked money: fund units, bonds, property or a deposit that come back, but only on the asset's own terms. The third is recurring tax, which starts the day the family actually becomes resident and does not stop until it leaves. The fourth is time: how many years the status needs before it turns into permanent residence or a passport.

The four are almost never shown together, because each has its own owner. Entry models and their mark-ups sit in [investment migration models](https://wiki.private.law/en/investment-migration-models); preferential regimes in [special tax regimes](https://wiki.private.law/en/special-tax-regimes); annual taxes on capital in the [wealth tax map](https://wiki.private.law/en/wealth-tax-map); naturalisation clocks in [EU citizenship routes](https://wiki.private.law/en/eu-citizenship-routes). This page puts them on one grid for twelve jurisdictions and one family, so that the question "what does five years of this status cost" gets a number rather than a threshold.

The result is counter-intuitive in one respect and predictable in another. Predictably, zero-tax jurisdictions are cheap on the tax line and expensive in capital, presence or both. Counter-intuitively, for a family living on passive income the largest item in a southern European status is neither the investment nor the fees but ordinary income tax — and two European jurisdictions come out cheaper on their ordinary rules than on their famous special regimes.

## The family on which everything is counted

The comparison is only meaningful on one fixed profile. Every number below uses the same one:

- two adults and two children aged 10 and 14, no local employment or business in the destination;
- €300,000 a year of foreign-source passive income — €200,000 of dividends and €100,000 of interest — received by one spouse;
- a liquid portfolio of €5,000,000 net, no other assets in the destination beyond what the route itself requires;
- a five-year horizon, with the family genuinely resident for tax purposes — present enough days and with its centre of life in the destination.
The last assumption is the one most often skipped. A card does not create tax residence ([tax residency basics](https://wiki.private.law/en/tax-residency-basics)): a family that holds a Greek or Portuguese permit but lives elsewhere pays the tax of the country where it actually lives, and the tax column below then belongs to that country instead. The matrix therefore answers the question of a family that moves, not of one that buys a backup card.

## Who the matrix does not fit

Three profiles need a different calculation. A family with employment or business income in the destination falls under regimes built for workers — Spain's Beckham law, Portugal's IFICI, Italy's impatriate relief — which the matrix does not model. A US citizen is taxed by citizenship wherever the family lives, so the tax column adds to, rather than replaces, the American bill. And a family whose income is an order of magnitude larger — €2 million and above — crosses the break-even points of the fixed-sum regimes discussed below; for it the ranking changes.

## The matrix: entry and holding

Twelve routes, one per jurisdiction, chosen as the route a financially independent family would actually use. State charges are the published schedules; a dash means no published figure.

| Jurisdiction and route | Capital condition | State charges and sunk entry costs | Housing as a condition | Health cover in the file | PR and passport horizon |
| --- | --- | --- | --- | --- | --- |
| Portugal — [ARI fund route](https://wiki.private.law/en/portugal-golden-visa) | €500,000 in a qualifying fund | [AIMA 2026 tariff](https://aima.gov.pt/media/pages/documents/dc677d0005-1772305205/tabela-de-taxas-e-demais-encargos-a-cobrar-pelos-procedimentos-administrativos.pdf), standard / reduced column: analysis on each grant or renewal €842.80 / €632.10; issue €8,418.90 / €6,314.20; renewal €4,210.30 / €3,157.80. Five-year four-person illustration: €58,104.40–77,471.60, subject to the 25% reduction and card chronology described below | none | — | PR at 5 years; passport at 10 from the card (7 for EU and CPLP nationals) |
| Spain — non-lucrative residence | none; income test instead | — | none | DGSFP-licensed policy, no co-payment, no waiting period | PR at 5 years; passport at 10 |
| Italy — investor visa, government bonds | €2,000,000 in Italian government bonds | — | none | — | EU long-term status at 5 years; passport at 10 |
| Greece — [golden visa](https://wiki.private.law/en/greece-golden-visa), property | €400,000 property outside the premium zones (€800,000 inside) | [Transfer tax](https://aade.gr/en/greeks-abroad-non-residents/property-taxation/real-estate-transfer-tax) where applicable: 3% of taxable value plus a municipal levy equal to 3% of that tax, together 3.09%; notary, registration and other acquisition costs are additional | one property of at least 120 m², no short lets | policy valid in Greece | passport after 7 years of residence, Greek at B1 |
| Cyprus — permanent residence, Category 6(2) | €300,000 plus VAT, new build from a developer or other qualifying asset | VAT on the purchase | the qualifying property itself | — | PR at once; passport at 7 of the last 10 years |
| Malta — [Global Residence Programme](https://wiki.private.law/en/global-residence-program) | none | €6,000 application fee; €5,500 if qualifying property in southern Malta is already owned at application | [Property thresholds](https://mtca.gov.mt/docs/default-source/documents/personal-tax/individual/special-schemes/the-global-residence-programme/guidelines-grp.pdf): purchase €275,000 / annual rent €9,600; southern Malta or Gozo €220,000 / €8,750 | full health insurance valid in the EU | tax status; no automatic citizenship entitlement |
| Switzerland — [expenditure-based taxation](https://wiki.private.law/en/switzerland-flat-tax) | none | — | Rent is a minimum-base factor: [federal](https://www.estv.admin.ch/dam/de/sd-web/pl0PXAcAAxJq/dbst-ks-2018-1-044-d-de.pdf) floor 7× annual rent; [Thurgau §17a](https://www.rechtsbuch.tg.ch/api/de/versions/2929/pdf_file) cantonal floor 10×. Actual living expenditure and the control calculation can produce a higher bill | basic health insurance is compulsory for residents | C permit; [naturalisation after 10 years](https://www.sem.admin.ch/sem/en/home/integration-einbuergerung/schweizer-werden.html) |
| Monaco — residence card | No statutory fixed investment amount; €500,000 bank balance is this model's assumption, not a confirmed universal bank minimum | [Cards from age 16](https://monservicepublic.gouv.mc/en/themes/nationality-and-residency/residency/residents/the-residence-permit): temporary card €80, annual renewal €40; ordinary card after three years' residence €100, valid three years, renewal €50 | owned or registered rented home | — | privileged card at 10 years; naturalisation discretionary |
| Andorra — [residence without work](https://wiki.private.law/en/andorra-residence-permit) | €1,000,000 in Andorran assets | non-refundable AFA payment €50,000 plus €12,000 per dependant — €86,000 for four ([Law 2/2026](https://bopadocuments.blob.core.windows.net/bopa-documents/038015/pdf/CGL_2026_02_12_10_11_12.pdf)) | housing evidenced in the file | health cover evidenced in the file | ten-year permits after seven years as holder |
| UAE — golden visa, property | property from AED 2,000,000 | — | the qualifying property | mandatory in all emirates since 1 January 2025 | no PR; naturalisation by nomination only |
| Türkiye — residence permit, property | property from USD 200,000 | — | the qualifying property, outside closed districts | checked at filing | long-term permit at 8 years; passport at 5 years or by USD 400,000 investment |
| Thailand — LTR, Wealthy Global Citizen | USD 1,000,000 of assets and USD 500,000 invested in Thailand | [visa fee](https://ltr.boi.go.th/) THB 50,000 per person for ten years | none | USD 50,000 of cover (USD 25,000 per dependant) or a deposit instead | LTR 5 + 5 years; PR by separate procedure |

## The matrix: tax on the family's income

The same twelve on the tax line. The regime shown is the cheapest one the family can actually enter on this profile; where a famous special regime exists but costs more, the reason is in the second column.

| Jurisdiction | Regime applied to the profile | Dividends / interest | Tax on capital | Tax a year | Five years |
| --- | --- | --- | --- | --- | --- |
| Portugal | ordinary residence; [IFICI](https://wiki.private.law/en/portugal-ifici) is closed to passive income | 28% / 28% ([art. 72 CIRS](https://info.portaldasfinancas.gov.pt/pt/informacao_fiscal/codigos_tributarios/cirs_rep/Pages/irs72.aspx)) | none | €84,000 | €420,000 |
| Spain (Madrid) | ordinary; Beckham requires a Spanish job | savings scale 19–30% ([arts. 66 and 76 LIRPF](https://www.boe.es/buscar/act.php?id=BOE-A-2006-20764)) | [wealth tax](https://wiki.private.law/en/spain-wealth-tax) at the ITSGF level: 1.7% on net wealth above €3,000,000 after €700,000 | €71,880 + €22,100 = €93,980 | €469,900 |
| Italy | ordinary; the [24-bis flat tax](https://wiki.private.law/en/italy-flat-tax) is €300,000 for the sole income owner, or €450,000 if the option is extended to all three relatives (€300,000 plus €50,000 per family member, carried into [art. 246 of the consolidated income-tax code](https://www.normattiva.it/eli/id/2026/07/03/26G00131/ORIGINAL)) | 26% / 26% | IVAFE 0.2% on foreign financial assets | €78,000 + €10,000 = €88,000 | €440,000 |
| Greece | ordinary; the [€100,000 non-dom](https://wiki.private.law/en/greece-non-dom) costs four times more | [5% / 15%](https://www.aade.gr/en/greeks-abroad-non-residents/income-taxation/income-categories-and-income-taxation-greece) | none on a portfolio | €25,000 | €125,000 |
| Cyprus | [non-dom](https://wiki.private.law/en/cyprus-non-dom), 17 years | 0% defence contribution; [GeSY 2.65%](https://www.gesy.org.cy/sites/Sites?d=Desktop&locale=en_US&lookuphost=%2Fen-us%2F&lookuppage=hiofinancing) on relevant income, capped at €180,000 per individual per year | none | €4,770 | €23,850 |
| Malta | GRP, remittance basis | 15% on foreign-source income received in Malta; €15,000 annual minimum for the beneficiary, spouse and minor children. Other chargeable income: 35% | none | €15,000 if foreign income received in Malta is at most €100,000 and there is no other chargeable income | €75,000 |
| Switzerland | expenditure basis | not taxed as such; the base is living expenditure | cantonal wealth tax on a deemed base | Thurgau: at least CHF 150,000 cantonal/municipal tax plus federal tax | Thurgau: at least CHF 750,000 plus five years of federal tax |
| Monaco | [no personal income tax](https://wiki.private.law/en/monaco-tax) for non-French residents | 0 / 0 | none | 0 | 0 |
| Andorra | IRPF | [10% after the €3,000 savings-base allowance](https://www.govern.ad/documents/d/guest/guia_irpf) per taxpayer, before any foreign-tax credit | none | €29,700 | €148,500 |
| UAE | no personal income tax; [residence proved by certificate](https://wiki.private.law/en/uae-tax-residency) | 0 / 0 | none | 0 | 0 |
| Türkiye | [article 20/D](https://wiki.private.law/en/turkey-tax-holiday), new residents from 2026, 20 years | 0 on foreign-source income | [1% on qualifying inheritance transfers](https://cdn.tbmm.gov.tr/KKBSPublicFile/D28/Y4/KanunMetni/4b916eb3-fb9a-4f40-aea8-3c044342be21.htm) during the exemption; the new rule does not extend that rate to gifts | 0 | 0 |
| Thailand | LTR | [overseas income exempt](https://wiki.private.law/en/thailand-foreign-income-tax) | none | 0 | 0 |

### What the two tables show

The tax line is the budget. In Portugal, Spain and Italy the family pays €420,000–470,000 over five years on ordinary rules — several times the modelled Portuguese AIMA charges of €58,104.40–77,471.60 for four files. A route chosen by comparing thresholds is a route chosen on the smaller number: the fund in Portugal and the bonds in Italy come back, the tax does not.

Two European jurisdictions are cheaper on ordinary rules for the original €300,000-income profile. Greece's €25,000 annual calculation is below the €100,000 charge for a qualifying non-dom participant. Italy's ordinary €88,000 calculation is below the €300,000 fixed charge for the sole income owner; €450,000 applies only if the option is extended to the spouse and both children. The comparison must use the same people, income and covered assets in each regime. At €2 million of income, use the separate scenario below instead of treating all relatives as automatic additional taxpayers.

Cyprus is the cheapest EU address on the tax line, and the reason is structural: a resident without Cypriot domicile pays no defence contribution on dividends and interest for seventeen years, and the only charge left is the 2.65% health contribution capped at €180,000 of income per individual. Malta's GRP is a special tax status: the €15,000 minimum covers the beneficiary, spouse and minor children where foreign income received in Malta is at most €100,000 and no other chargeable income arises. Immigration residence permission is a separate requirement.

The zero-tax group moves the cost into other lines. The UAE and Türkiye ask for property; Thailand asks for USD 500,000 invested locally on top of USD 1 million of assets; Monaco requires suitable housing and sufficient resources; the €500,000 bank balance used here is a modelling assumption to be replaced by the chosen bank's written terms. A low destination rate does not establish that residence in the departure state has ended. Check the actual residence tests, any exit-charge event and applicable deferral conditions separately. CFC liability depends on the relevant taxpayer's continuing tax connection and the domestic control and charging rules; it does not automatically follow every emigrating family. Prior-period filings can remain due ([exit tax](https://wiki.private.law/en/exit-taxes-overview); [HMRC's example of residence, control and charging conditions](https://www.gov.uk/hmrc-internal-manuals/international-manual/intm191100)).

## Worked example: the five-year bill

The Portuguese fee illustration counts four separate grant applications and two renewals per person over five years from initial issue: [the initial term is two years and ARI renewals are two years](https://www.pgdlisboa.pt/leis/lei_print_articulado.php?artigo_id=&nid=920&nversao=&tabela=leis). At unchanged 2026 tariffs, the standard calculation is 4 × \[€842.80 + €8,418.90 + 2 × (€842.80 + €4,210.30)\] = €77,471.60. If all charges qualify for the tariff's 25% reduction, the published reduced amounts give €58,104.40. Check the processing channel and each family member's actual card dates; future tariff increases, fund charges and legal costs are excluded.

The family's five-year cost of status, on published figures, with living costs left out on purpose — they would be spent anywhere. Locked capital is shown separately because it returns, subject to the asset. Private health cover is excluded from the totals. For a separate sensitivity test, assume USD 3,000–8,000 per adult annually and half that per child: the arithmetic gives USD 45,000–120,000 for this family over five years. These are model inputs, not current insurer quotations or a claim that cover costs the same in every country; replace them with quotes reflecting ages, territory, exclusions and deductibles ([international health insurance](https://wiki.private.law/en/international-health-insurance)).

| Jurisdiction | State and entry charges | Tax, five years | Sunk total | Capital locked, returns |
| --- | --- | --- | --- | --- |
| Cyprus | VAT on the purchase | €23,850 | €23,850 plus VAT | €300,000 property |
| Malta | €6,000 fee + €48,000 minimum rent | €75,000 | €129,000 | none (renting) |
| Greece | €12,360 transfer tax if taxable value is €400,000, plus actual other acquisition costs | €125,000 | €137,360 plus other acquisition costs | €400,000 property |
| Andorra | €86,000 AFA payments | €148,500 | €234,500 | €1,000,000 Andorran assets |
| Italy | — | €440,000 | €440,000 | €2,000,000 bonds |
| Spain (Madrid) | — | €469,900 | €469,900 | none |
| Portugal | €58,104.40–77,471.60 AIMA charges under the stated fee-channel assumptions | €420,000 | €478,104.40–497,471.60 | €500,000 fund |
| Switzerland | — | Thurgau: at least CHF 750,000 plus federal tax for five years | Thurgau: at least CHF 750,000 plus federal tax for five years | none |
| Monaco | Card issue and renewal charges; initially two adults, with the older child needing a card on reaching 16 | 0 | card fees plus housing | €500,000 bank-balance assumption; availability and restrictions depend on the bank's terms |
| UAE | property acquisition costs | 0 | acquisition costs | AED 2,000,000 property |
| Türkiye | property acquisition costs | 0 | acquisition costs | USD 200,000 property |
| Thailand | THB 200,000 visa fees | 0 | THB 200,000 | USD 500,000 invested |

Three readings follow. The stated tax and fee subtotal is about €24,000 plus property VAT in Cyprus, about €470,000 in Spain and €478,000–497,000 in Portugal. These are not complete relocation bills: the table excludes or separately identifies material property, housing and service costs. Andorra's €86,000 is the largest non-refundable state payment in the set since Law 2/2026 turned what used to be a refundable deposit into a final payment; the older "refundable deposit" figure in circulation now belongs to other permit categories. Switzerland's Thurgau example requires at least CHF 150,000 a year in cantonal and municipal income/wealth tax, with federal tax additional. Its cantonal base is at least ten times annual rent, and actual expenditure or the control calculation can increase liability; the figure is not a fixed all-in Swiss tax quote.

> 🍓 For this passive-income family, annual tax is a major part of the cost of residence. The five-year subtotal is about €24,000 plus property VAT in Cyprus, €470,000 in Spain and €478,000–497,000 in Portugal, before the stated exclusions. Greece and Italy remain cheaper on the model's ordinary rates than on their fixed-sum regimes; the result depends on the income mix and actual tax residence.

## Second scenario: €10 million of assets and €2 million of annual income

This is a separate comparison, alongside the original €300,000-income family. Keep the same two adults, children aged 10 and 14 and five-year horizon. One spouse owns a €10 million net foreign portfolio and receives all €2 million of annual income: two-thirds dividends and one-third interest. Hold those inputs constant for the illustration; this is not a forecast of investment returns. There is no local employment, no realised capital gains and no income from jurisdictions subject to special punitive rates.

The following figures show the destination's charge on that income, before source-country withholding and foreign-tax credits. They do not include migration charges, housing, asset taxes unless expressly stated, succession or departure tax. Add the entry costs from the first matrix only where the same route remains eligible.

| Jurisdiction | Annual / five-year income-related charge | What changes or needs a separate calculation |
| --- | --- | --- |
| Portugal | €560,000 / €2,800,000 at the [ordinary 28% rate](https://info.portaldasfinancas.gov.pt/pt/informacao_fiscal/codigos_tributarios/cirs_rep/Pages/irs72.aspx) | Assumes no aggregation election or special-source rate; add the modelled AIMA fees for the same ARI route |
| Spain | No all-in figure calculated here | Recalculate the savings-income bands and wealth/solidarity taxes on the actual ownership and region; doubling the old wealth-tax number is not a valid calculation |
| Italy | [Flat-tax option](https://www.gazzettaufficiale.it/atto/serie_generale/caricaArticoloDefault/originario?atto.codiceRedazionale=26A00149&atto.dataPubblicazioneGazzetta=2026-01-21&atto.tipoProvvedimento=LEGGE): €300,000 / €1,500,000 for the income owner; €450,000 / €2,250,000 only if extended to all three relatives | New-2026-arrival rate, subject to eligibility. Family residence alone does not require four tax elections; ordinary taxation and any excluded income/assets need comparison |
| Greece | Ordinary rates: about €166,667 / €833,333; qualifying [article 5A](https://www.aade.gr/sites/default/files/2025-11/forologika_kinitra_ENG.pdf): €100,000 / €500,000 for the income owner | Extension costs €20,000 per relative annually; prior-residence, investment and application conditions still apply |
| Cyprus | €4,770 / €23,850 GeSY under the non-dom assumptions above | The contribution is already capped for this one income owner; splitting assets and income between spouses changes the per-person calculation |
| Malta | GRP: €15,000 / €75,000 if at most €100,000 of foreign income is received in Malta annually; €300,000 / €1,500,000 if the full €2 million is received there | These are two distinct remittance assumptions, with no other chargeable income; living costs and funding flows must support the chosen assumption |
| Switzerland | No all-in figure calculated here | Obtain a cantonal calculation including federal tax, actual expenditure and control calculations; €10 million of wealth does not simply double the Thurgau floor |
| Monaco | [0 / 0 income tax](https://monservicepublic.gouv.mc/en/themes/tax/information/general-information/tax-in-monaco) for the qualifying non-French resident | Actual residence, housing and the banking arrangement remain separate costs |
| Andorra | €199,700 / €998,500 before foreign-tax credits | 10% × (€2,000,000 − €3,000 savings allowance), all income held by one taxpayer |
| UAE | [0 / 0 on personal investment income](https://tax.gov.ae/en/faq.aspx?keyword=Will%20an%20individual%20be%20subject%20to%20UAE%20CT%20on%20investment%20returns%3F) | Keep personal portfolio activity separate from a taxable business; residence and source-country tax still matter |
| Türkiye | [0 / 0 under article 20/D](https://cdn.tbmm.gov.tr/KKBSPublicFile/D28/Y4/KanunMetni/4b916eb3-fb9a-4f40-aea8-3c044342be21.htm) if its conditions are met | Check the preceding three calendar years and the foreign-source character; this is not a zero-rate assumption for every new resident |
| Thailand | [0 on income qualifying under section 5](https://ltr.boi.go.th/documents/royal-decree-743.pdf); no unconditional five-year total | The Wealthy Global Citizen LTR category, income/remittance timing and continuing eligibility must satisfy the decree |

### Inheritance of the €10 million portfolio

An income-tax exemption does not establish an inheritance-tax exemption. Before a death or gift, identify the legal owner, each asset's situs, each beneficiary's relationship and residence, prior gifts, liabilities and the applicable succession treaty. The €10 million balance alone cannot produce a family inheritance bill.

[Greece's article 5A guidance](https://www.aade.gr/sites/default/files/2025-11/forologika_kinitra_ENG.pdf) expressly covers qualifying foreign movable property passing to or from the participant on death or gift. Monaco's rule instead looks to [assets situated or taxable there](https://monservicepublic.gouv.mc/en/themes/tax/information/general-information/tax-in-monaco). A foreign connection can remain decisive: [France](https://www.impots.gouv.fr/international-particulier/taxable-assets) can tax foreign assets inherited by an heir resident in France at the transfer who meets the six-of-ten-year history test. For a non-US decedent, [shares in US corporations](https://www.irs.gov/individuals/international-taxpayers/some-nonresidents-with-us-assets-must-file-estate-tax-returns) are generally US-situs assets; the $60,000 figure is a filing threshold, not a promise of a tax-free worldwide estate. Applicable treaties can change these results.

### Exit tax: before the move and after year five

Calculate departure exposure separately from annual destination tax. Required inputs are the country being left, residence history, asset type, market value, tax acquisition cost, ownership percentage, destination and any deferral conditions. Unrealised gains cannot be inferred from €10 million of wealth or €2 million of annual income.

For example, [France's exit-tax test](https://www.impots.gouv.fr/international-particulier/questions/i-am-leaving-france-do-i-have-pay-exit-tax) includes six years of residence out of ten and specified securities of at least €800,000 or a holding carrying at least 50% of corporate profits. [Spain's article 95 bis](https://sede.agenciatributaria.gob.es/Sede/Ayuda/25Presentacion/100/7_6_6_4.html) uses ten resident tax periods out of fifteen and shares worth over €4 million, or a holding above 25% worth over €1 million. A family with only the five Spanish resident years in this scenario and no earlier Spanish years does not meet that history test; a returning resident may. Deferral and relief need their own review. Keep the departure calculation, the five-year residence budget and the inheritance calculation as three separate amounts.

## Choosing by profile

| Profile | Where to look first | What decides |
| --- | --- | --- |
| Passive income up to a few hundred thousand, wants an EU base and low tax | Cyprus non-dom; Greece on ordinary rates | the income mix — dividends and interest, not wages — and genuine residence |
| Passive income of €2 million and more, wants an EU base | Italy's flat tax, Greek non-dom | the break-even of the fixed charge against the ordinary rate on the actual mix |
| Zero tax, ready to live there and prove it | UAE, Monaco, Türkiye under 20/D, Thailand LTR | presence, housing and the exit rules of the state being left |
| A passport within ten years matters most | Greece (7), Cyprus (7 of 10), Portugal (10 from the card), Türkiye | the naturalisation clock and language, not the entry price |
| A Schengen card without moving the tax base | Greece or Portugal as a permit only | staying non-resident there; the tax column then belongs to the country actually lived in |
| Predictability over the lowest figure | Switzerland's expenditure basis, Malta's GRP minimum | a known annual amount against a higher average |

## Typical mistakes

- Comparing thresholds. The fund, the bonds and the property return; the tax does not, and on an ordinary EU regime it is several times the whole migration budget.
- Taking a special regime by default. Compare the ordinary calculation with the fixed charge for the people actually opting in; residence of four family members does not itself mean four tax elections.
- Forgetting the tax on capital. Spain's regional wealth tax is trimmed to the level of the federal backstop in Madrid, not removed; Italy charges 0.2% a year on foreign financial assets.
- Counting only one application fee or renewal. Portugal's ARI analysis charge applies at both grant and renewal, alongside each person's card charge; the applicable tariff column and renewal dates change the bill. Andorra charges per dependant.
- Treating the card as tax residence. Every tax figure in the matrix assumes the family has really moved; with a permit alone the tax line belongs to the country where it lives.
- Leaving out the departure analysis. Price any exit charge triggered by the move, including deferral and later-payment conditions. Test CFC exposure only where the relevant tax connection, control and charging conditions remain; check outstanding filings for earlier periods separately.
## Q/A

### **Which of the twelve is cheapest for this family over five years?**

Among the EU addresses, Cyprus: about €24,000 of health contribution over five years, plus VAT on the qualifying property, because a non-domiciled resident pays no defence contribution on dividends and interest. The zero-tax addresses — Monaco, the UAE, Türkiye under article 20/D and Thailand's LTR — cost less on the tax line but lock capital, require housing or both, and depend on proving that the family has really left its previous country.

### **Why is Greece cheaper on its ordinary rules than on its non-dom regime?**

Because the ordinary rules tax dividends at 5% and interest at 15%, which on €200,000 of dividends and €100,000 of interest comes to €25,000 a year, while the non-dom regime charges a fixed €100,000. The fixed charge pays off only from about €1.2 million a year of such income, or much earlier where the income is business or employment income taxed on the progressive scale of up to 44%.

### **Is the investment itself a cost?**

Only its sunk part is. Fund units, government bonds and property come back subject to the asset's own terms, but the transaction costs of buying them, the fund's fees and non-refundable payments do not. Andorra's €86,000 for a family of four and Portugal's modelled €58,104.40–77,471.60 of AIMA charges are sunk; the €500,000 fund and the €1,000,000 Andorran investment are locked.

### **How does the ranking change at €2 million of income?**

Use the separate €10 million / €2 million scenario above. The sole income owner's qualifying Italian flat charge is €300,000 annually for a new 2026 arrival; €450,000 assumes extension to three relatives. Greece's ordinary dividend/interest calculation is about €166,667 versus €100,000 under a qualifying article 5A election. Malta depends on how much foreign income is received there; Spain and Switzerland need a fresh asset and household calculation rather than a linear scaling of the first matrix.

### **Does a golden visa by itself change the tax column?**

No. A permit does not create tax residence; days of presence, a permanent home and the centre of interests do. A family holding a Greek or Portuguese card while living elsewhere pays the tax of the country where it lives, and the Greek or Portuguese line in the matrix does not apply to it.

### **What does the matrix leave out?**

Living costs, which would be spent anywhere; market rents except where a statute sets a minimum, as Malta does; fund and broker fees; currency movements on non-euro assets; and departure-side charges or CFC obligations where their legal conditions apply, plus filings for earlier periods, discussed in [exit tax](https://wiki.private.law/en/exit-taxes-overview). The regional comparisons of entry routes are in [investor routes in Europe](https://wiki.private.law/en/investor-routes-europe) and [the Gulf and Asia](https://wiki.private.law/en/investor-routes-gulf-asia).

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## Factual claims

- Two European jurisdictions are cheaper on ordinary rules for the original €300,000-income profile.
- This is a separate comparison, alongside the original €300,000-income family.
- Greece's article 5A guidance expressly covers qualifying foreign movable property passing to or from the participant on death or gift.
- For example, France's exit-tax test includes six years of residence out of ten and specified securities of at least €800,000 or a holding carrying at least 50% of corporate profits.

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