Special Tax Regimes for New Residents: A Map of Options

Concept

A special tax regime is a deal between the state and a wealthy relocator: the relocator brings capital, consumption, and a tax base, and the state temporarily switches off part of its tax system for them. Almost always this concerns foreign income: local earnings are taxed like everyone else's, but dividends from a Dutch holding company or profits from selling US stocks follow special rules or are not taxed at all.

A special regime always has four parameters: what is exempted (foreign income, capital gains, inheritance), for how many years, what the entry cost is (fixed tax, investment, fees), and what happens on exit. Comparing regimes by a single rate is a mistake.

There are dozens of regimes worldwide, but legally there are five constructions. Understanding the construction is more important than a list of countries: countries change parameters every two to three years, constructions — almost never.

Five Constructions

1. Non-⁠dom and remittance basis

The historic British model: foreign income is not taxed until it is brought into the country. UK non-dom itself was replaced from April 2025 by the FIG regime — four years of exemption on foreign income and gains, and these funds can now be brought into the country freely. Eligibility turns on qualifying new resident status: ten consecutive tax years of non-UK residence before the first qualifying year, plus a separate condition on the individual's own age — at least ten years old at the start of the tax year. Finance Act 2026 narrowed the relief so that it is deducted only from the income or gains to which it relates, with effect backdated to 2025-26. The claim is annual, and every year claimed costs the personal allowance and the CGT annual exempt amount.

The construction itself survives elsewhere in Europe. Malta's Global Residence Programme taxes foreign-source income only when it is received in Malta, at 15%, with a minimum tax of €15,000 a year; the Cypriot non-dom status and the figures of its 2026 reform are set out in the Cyprus tax reform.

2. Flat tax — fixed payment

The payment is known in advance and closes the question on all foreign income. Italy's annual payment depends on the date residence under Article 43 of the Civil Code was transferred: €100,000 for transfers on or before 10 August 2024; €200,000 for transfers after 10 August 2024 and before 1 January 2026; €300,000 for transfers from 1 January 2026. Article 2 of Decree-Law 113/2024 expressly uses a date after entry into force, which was 10 August 2024. Article 1(25)–(26) of Law 199/2025 applies the new €300,000 rate and €50,000 family-member payment to transfers from 1 January 2026; the earlier cohorts retain their €100,000 or €200,000 rate and €25,000 per qualifying family member. A main applicant plus three qualifying family members in the new cohort therefore pays €450,000 a year. From 1 January 2027 the regime is restated in Article 246 of Legislative Decree 117/2026. The repeal is made by Article 376(1)(e), which repeals Articles 1–191 of DPR 917/1986, including Article 24-bis, from the date in Article 377. The separate cohort provisions remain applicable. Greece charges a lump sum of €100,000 a year on foreign-source income under Art. 5A of the Income Tax Code, plus €20,000 for each relative included, for up to fifteen tax years and with an investment of at least €500,000 completed within three years of the application (AADE guide). Switzerland calculates tax on living expenses: the base is the highest of actual expenses, seven times the annual rent, the federal minimum (CHF 435,000 for 2026) and the canton's own minimum, and ordinary cantonal and communal rates then apply to it. There is no agreed fixed sum here: the figure in a ruling is the result of that calculation, not a substitute for it. Expensive, but predictable and without declaring the structure of the income.

3. Special regime for employees and entrepreneurs

Beckham Law in Spain (Art. 93 LIRPF) — a flat 24% on employment income up to €600,000 and, because only income obtained in Spain is taxed under Art. 93.2.c), no tax on foreign passive income; the requisite that matters: under Art. 93.2.b) LIRPF all employment income obtained while the regime applies is deemed obtained in Spanish territory, so the 24% reaches the salary paid by a foreign employer too, not just the Spanish portion; Portugal IFICI (NHR 2.0) — 20% on qualifying income from a certified activity for ten years, for someone not resident in Portugal in any of the five preceding years; Greece Art. 5C — half of Greek employment or business income exempt for seven years for someone who was not resident in five of the six preceding years.

4. Territorial systems

The country does not tax foreign income in principle, so no regime is needed; remittance-based systems tax foreign income only when it is brought in. This is the most stable option: there is nothing to cancel. The bases of this kind are listed below with links to their pages.

5. Tax holidays by term

Turkey introduced a 20-year exemption on foreign income — dividends, gains, passive income — for those becoming residents from 2026 who were not tax residents for the three preceding calendar years; Turkish income is taxed as usual, and a 1% rate applies to property passing by inheritance during the exempt period. The requisite matters here: Law No. 7582, Official Gazette of 4 June 2026 No. 33270, the new article mükerrer 20/D of the Income Tax Law. The same law opened a separate asset-amnesty window with declarations due by 31 July 2027, and the two measures are routinely conflated.

Israel's regime for new immigrants and returning residents works on the same logic of a term that starts with arrival; its conditions are covered in the Israeli exemption for new residents.

The clock of a holiday ticks from the moment of relocation, so holidays are planned around a specific event — the sale of a business, vesting, a fund exit.

How to Choose

The sequence is always the same: first the relocator's income structure (salary, dividends, gains, carry), then which of them the regime actually exempts, then the entry price and the presence obligations. And only at the end — climate and schools. The regimes are set side by side on exactly those axes in the matrix below. The reversed order, when a country is chosen by climate and schools and taxes are adjusted afterward, usually costs more than ordinary residency.

Risks

There are three main risks. The first is political: regimes are canceled (UK non-dom, the first version of Portugal's NHR) or tightened, and only grandfathering helps, if it is written in. The second is formal: almost every regime requires an application by a deadline (the opt-in communication within six months of starting work in Spain, the option in Italy exercised by the tax-return deadline after a favourable ruling) — a missed deadline is irreversible. The third is behavioral: a center of vital interests that remains in the old country negates any paper.

Presence Matters More Than the Certificate

Any regime rests on physical presence and real ties. Most countries grant residency for 183 days a year or for transferring the center of vital interests — family, housing, business. A tax residency certificate by itself is no protection: if the apartment, the accounts, and the children remained in the previous country, it will keep treating the taxpayer as its own through the tie-breaker under a tax treaty. Therefore substance — rented or purchased housing, days actually spent in the country, local accounts — is what, in a dispute, decides whether the regime is recognized for the relocator.

What This Means for a Russian Resident

A foreign special regime does not switch off Russian obligations by itself. While the person remains a tax resident of the Russian Federation (the same 183 days), worldwide income is declared in Russia, and the CFC and currency-residency rules apply regardless of the regime obtained abroad. So the order is the reverse of the usual: first Russian residency is carefully terminated, the exit-tax logic, CFC, and currency reporting are closed, and only then is the foreign regime activated. Otherwise it is easy to become a resident of two countries at once and pay twice until the tie-breaker works.

Where Regimes Are Heading

The direction is visible from recent years. Wealthy jurisdictions with their own tax base are rolling back benefits: the United Kingdom canceled non-dom, Portugal narrowed NHR to a handful of professions. Those competing for mobile capital, on the contrary, are raising the entry price and extending the horizon: Italy brought the lump-sum payment to €300,000, Turkey issued a 20-year exemption. Territorial systems like Georgia or the UAE hold most steadily: there is no benefit that can be canceled. Meanwhile the pressure of transparency only grows, and it now carries dates.

The amended CRS applies in the EU and Switzerland from 1 January 2026; the report gained a field on whether a valid self-certification was obtained and a field for the controlling person's role in the structure. Crypto-asset reporting runs in waves: first-wave data collection began on 1 January 2026, with first exchanges, on the Global Forum commitment list in its edition of 14 September 2026, by 46 jurisdictions in 2027, a further 27 by 2028 and four by 2029 — Argentina, Azerbaijan, Mexico and the United States.

The third circuit is advance rulings, and for special regimes it sits closest. Directive (EU) 2023/2226 (DAC8) extended the automatic exchange of advance cross-border rulings to rulings on the tax affairs of individuals, and brought rulings that determine tax residence in the issuing state within the definition. A ruling issued, amended or renewed after 1 January 2026 is exchanged where the transaction amount stated in it exceeds €1,500,000, or where it answers that residence question. For special regimes the second test bites more precisely than the first: a client on a regime usually holds a confirmation of status — an Italian interpello, a Spanish DGT consulta vinculante, a Portuguese informação vinculativa — and residence is exactly what such documents decide.

The provision carries no retroactivity: a 2021 confirmation that simply remains in force is not exchanged. What opens the perimeter is work on the document itself — amendment or renewal after 1 January 2026 brings it wholly into exchange, and from that point the regime is visible to every interested EU administration at once, the country of departure included. Whether a particular national procedure falls inside is settled by national practice: registration acts granting access to a regime — the Portuguese IFICI registration, the Spanish opt-in communication — sit more awkwardly against the definition of an advance ruling than full rulings do. The timetables diverge as well: on 30 January 2026 the Commission opened infringement procedures against twelve Member States for failing to transpose DAC8, Greece, Spain and Portugal among them. The thresholds, the carve-outs and the mechanics of that exchange are covered separately in the exchange of advance rulings on individuals.

Real savings are determined by three things: which income the regime exempts, how many years the benefit lasts, and how cleanly the exit from the previous jurisdiction was executed. This is a time-limited discount with a clear expiration date — it is planned around a specific event and the exit is calculated in advance.

Regimes on Common Axes

The five constructions above are the grammar; the table below is the vocabulary. Ten regimes that a relocating family actually chooses between are set out on the same axes: what is relieved and for how long, what entry costs and how long the person must have been away. Figures are those in force in September 2026; each row links to the article that carries the requisites.

Read across the rows and two patterns appear. The regimes that ask for money at the door — Italy, Greece 5A, Switzerland and Malta's minimum tax — sell certainty on foreign income for a fee. The regimes that cost nothing at entry — Beckham, IFICI, Greece 5C, the UK FIG regime and Turkey's 20/D — pay for that with a narrow door or a clock: an employment or a certified activity, ten years of prior absence, four years of relief.

The second pattern is that the presence test and the prior-absence test are different instruments. Presence is the ordinary tax-residence rule of the arrival state; prior absence is a gate into the regime — 9 of 10 periods in Italy, 7 of 8 years in Greece under 5A, 10 years in the United Kingdom, 5 in Spain and Portugal, 3 calendar years in Turkey. A person can satisfy the first and fail the second: a returning Italian who was resident four years ago is a resident, but not a new resident for Art. 24-bis. Spain adds a third axis — who the regime is closed to: Art. 93 excludes the special employment relationship of professional athletes.

Small and Zero-⁠Tax Bases for Large Capital

A separate class of jurisdictions sells no regime at all: they compete with a low or zero personal tax that applies to everyone, and what is sold is the residence permit. They are compared on different axes — the price of the permit, the presence it demands, the treaty network that decides what foreign withholding can be recovered, and banking access — and each is covered on its own page: Monaco, Andorra, Gibraltar, Jersey and Guernsey, Bermuda, Cayman, Liechtenstein, Saudi Arabia and the UAE. The treaty network is the axis that separates them most: the UAE Ministry of Finance lists 137 concluded double taxation agreements, which lets a UAE resident recover foreign withholding in a way that a base without conventions cannot offer.

Territorial and Remittance Systems

The third family covers countries whose personal tax reaches foreign income only in part — on a territorial basis, on remittance, or with exemptions and holidays for newcomers — each with its own rules, set out on its page: Georgia, Panama, Paraguay, Costa Rica, Malaysia, Thailand, Mauritius, Hong Kong, Singapore and Uruguay. The risk axis here is recharacterisation: work performed from the territory is judged by the place where it is done, however foreign the client, and that is where these systems fail the remote professional who moved for them. In a remittance system the planning object is the bank transfer rather than the contract.

Income Profile → Regime

The matrix answers a different question from the one most relocators ask. It does not rank countries; it says which regime survives a given kind of money. A person paid a salary chooses between the regimes that reduce the local rate — Beckham at 24%, IFICI at 20%, Greece 5C at half — and each of those has its own category test. A person living on capital chooses between paying a fee for certainty (Italy, Greece 5A, Switzerland, Malta's minimum tax) and paying nothing for a clock (the United Kingdom's four years, Turkey's twenty). A person with a disposal ahead is choosing a calendar rather than a country: the gain must fall after the old residence has ended and inside the new relief, and an exit tax at home crystallises on the day of departure whatever the destination offers.

Worked Example: €2,000,000 of Passive Income

A single relocator with a foreign portfolio paying €1,200,000 in dividends, €500,000 in interest and €300,000 in gains a year, no local income, no employment. The figures are the tax due in the new state in the first full year; foreign withholding at source and the departure state's exit rules are the same whichever row is chosen and are left out.

At this income the fee regimes and the zero regimes sit two orders of magnitude apart, and the ranking inverts as the income falls: at €400,000 a year the Italian flat tax is a 75% rate and Greece a 25% one, while the zero regimes stay where they are. What the fee buys is not visible in the column — a statutory term that does not run out after four years and a status that the departure state can check against a statute rather than against a permit.

The perimeter of a special regime is foreign income: local earnings are taxed like everyone else's. There are only five constructions — non-dom, a fixed payment, a regime for employees and entrepreneurs, a territorial system and a tax holiday by term — and the relocator's income structure decides between them. Three things of the same order decide the outcome: the election filed on time, a centre of vital interests that actually moved, and a clean exit from the previous jurisdiction. Transparency is switched off by none of it: CRS, crypto-asset reporting and the exchange of advance rulings run on top of every regime.