# Special Tax Regimes for New Residents: A Map of Options > A map of special tax regimes for changing tax residency: non-dom, flat tax, territorial taxation, and tax holidays. How to choose and where the pitfalls lie. Author: Alena Dunaeva — Lawyer, Family Office (https://wiki.private.law/en/authors/dunaeva) Last modified: 2026-08-21T07:42:00.000Z Canonical: https://wiki.private.law/en/special-tax-regimes Topics: investments Jurisdictions: global Product tags: tax-regime, non-dom, flat-tax, relocation Semantic tags: tax-regime, non-dom, flat-tax, relocation --- ## Concept A special tax regime is a deal between the state and a wealthy relocator: you bring capital, consumption, and a tax base, and the state temporarily switches off part of its tax system for you. 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 full exemption on foreign income and gains for those who were not UK residents for the ten years before relocation, and now these funds can be brought into the country freely. The construction itself is alive: Cyprus with the 60-day rule, Greece, Malta, Ireland. [Thailand](https://wiki.private.law/en/thailand-foreign-income-tax) swung in the opposite direction in 2024 and taxed remitted income, and in 2026 is discussing softening — an exemption for amounts brought in within two years; the proposal has not yet been adopted. ### 2. Flat tax — fixed payment You pay a known sum in advance and close the question on all foreign income. In Italy, the entry payment over two years grew from €100,000 to €200,000 for those who relocated after August 2024 and to €300,000 per year for those becoming residents from 2026; those who relocated earlier retain the old rate. Greece maintains €100,000 per year \(Art 5A, up to 15 years, with an investment from €500,000\). Switzerland calculates a lump-sum tax from living expenses by agreement with the canton. Expensive, but predictable and without declaring the structure of your 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 exemption of 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 income from qualified occupations in science, technology, healthcare, and R&D, notably narrower than the previous NHR and without the pension benefit; Puerto Rico Act 60 — 0% on capital gains for new residents while retaining a US passport. ### 4. Territorial systems The country does not tax foreign income in principle — no regime is needed: Georgia, Panama, Paraguay, Costa Rica, Hong Kong, and Singapore \(with caveats on remittance and FSIE\). This is the most stable option: there is nothing to cancel. ### 5. Tax holidays by term Turkey in May 2026 adopted a 20-year exemption on foreign income — dividends, gains, passive income — for those becoming residents from 2026 who were not tax residents for the previous three years; Turkish income is taxed as usual \(15–40%\), and inheritance and gift tax is reduced to 1%. Israel gives repatriates 10 years of exemption, but from 2026 it canceled the accompanying reporting benefit — foreign assets must now be declared. Uruguay offers tax holidays. The clock 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 structure of your income \(salary, dividends, gains, carry\), 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 reversed order, when a country is chosen by climate and schools and taxes are adjusted afterward, usually costs more than ordinary residency. > ⚠️ A special regime does not cancel the exit rules of the old jurisdiction: exit tax, CFC, and the tie-breaker under a tax treaty are resolved before relocation, not after. ## 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 saves you, if it is written in. The second is formal: almost every regime requires an application by a deadline \(Modelo 149 in Spain, the election in the tax return in Italy\) — 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 does not protect you: if the apartment, the accounts, and the children remained in the previous country, it will keep considering you its own through the [tie-breaker under a tax treaty](https://wiki.private.law/en/tax-residency-tiebreaker). Therefore [substance](https://wiki.private.law/en/economic-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 you. > 🧭 Practical test: can you prove to the new country that the center of your life is now with it, and to the previous one that you have really left? The regime works only when both answers are a confident "yes." ## What This Means for a Russian Resident A foreign special regime does not switch off Russian obligations by itself. While you remain a tax resident of the Russian Federation \(the same 183 days\), your worldwide income is declared in Russia, and the [CFC](https://wiki.private.law/en/kik) and currency-residency rules apply regardless of the regime you obtained abroad. So the order is the reverse of the usual: first [Russian residency is carefully terminated](https://wiki.private.law/en/russia-tax-residency-exit), the [exit-tax logic](https://wiki.private.law/en/exit-taxes-overview), CFC, and [currency reporting](https://wiki.private.law/en/russia-foreign-account-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](https://wiki.private.law/en/tax-residency-tiebreaker) 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](https://wiki.private.law/en/uk-non-dom-2025), Portugal [narrowed NHR](https://wiki.private.law/en/portugal-ifici) 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](https://wiki.private.law/en/italy-flat-tax) to €300,000, Turkey issued a [20-year exemption](https://wiki.private.law/en/turkey-tax-holiday). Territorial systems like [Georgia](https://wiki.private.law/en/georgia-territorial-tax) or the [UAE](https://wiki.private.law/en/uae-tax-residency) hold most steadily: there is no benefit that can be canceled. Meanwhile the pressure of transparency only grows — automatic exchange and beneficial-owner disclosure reach those on special regimes too. > 🍓 Real savings are determined by three things: which of your income the regime exempts, how many years the benefit lasts, and how cleanly you exited the previous jurisdiction. 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. ## Questions and Answers ### Can a special regime be combined with remote work for a company from another country? More often than not, yes — this is a typical scenario for the Beckham Law and FIG. But earnings for days physically worked in the regime country are almost always taxed locally, and Spain's Art. 93 LIRPF regime goes further still: under Art. 93.2.b\) the whole of the employment income earned while the regime applies is deemed Spanish-sourced, the foreign employer's payroll included. A permanent workplace can also create a permanent establishment for the employer. ### What happens after the regime ends? You become an ordinary resident with worldwide taxation. That is why the exit strategy \(the next jurisdiction, realizing gains, restructuring the holding\) is laid in at the moment of entry, not six months before the end. ### Does the regime protect against CFC and automatic exchange? No. CRS reporting proceeds on its own, and CFC rules apply in your country of residency — some regimes \(for example, the Italian flat tax\) switch them off explicitly, some do not. This has to be checked separately for each country. --- ## Factual claims - Beckham Law in Spain (Art. --- Source: wiki.private.law — the private.law legal knowledge base. When quoting, cite the canonical page URL. Consultation with a lawyer: https://t.me/private_law_bot