wiki / Taxes: a map of institutions, regimes and manoeuvres

Taxes: a map of institutions, regimes and manoeuvres

Every tax answers four questions: who pays, on what base, at what moment and at what rate. Everything else is the combinatorics of those answers across countries and wrappers. This page gathers the wiki's tax materials into a single picture and leads from question to breakdown: how much will I pay — start with the countries; how to pay less — with the regimes; how a specific tax works — with the section on the taxes themselves; how it is done in practice — with the techniques.

What is changing right now

Tax competition for private capital has shifted from corporate rates to personal regimes. The 15% global minimum closed the old race for large groups — and almost at once the offering for mobile individuals grew: Italy sells its flat tax at €300,000 a year, Turkey has issued a twenty-year holiday, the Emirates hold at zero. In parallel, the surveillance infrastructure keeps being completed: CRS has reached crypto assets through CARF, beneficial-ownership registers have survived the courts, DAC6 demands that a scheme be disclosed while it is still on the drawing board. The bottom line for 2026 planning: reliefs have become more accessible, shelters more expensive.

The second front line is "unproductive" wealth. France has rebuilt the IFI into a tax on fortune improductive, Spain keeps extending its "temporary" solidarity tax, and Swiss voters rejected a 50% levy on large inheritances at referendum — though the campaign itself had already set capital in motion. The practical conclusion: durable planning rests on structures with a clear political logic for their existence — territorial systems, participation exemptions, insurance wrappers, philanthropy.

How much will I pay: countries

Every calculation starts with the country profile. The deepest coverage is of the UK, the US, Singapore, Hong Kong, the UAE and Russia.

Southern Europe, where our clients look most often:

Spainthe general regime · wealth tax: IP and ITSGF · Beckham · the cluster map

Italyflat tax €300k · property · succession

PortugalIFICI · Golden Visa · property

Greecenon-dom €100k · property and ENFIA · Golden Visa

Cyprusnon-dom and the 60-day rule · the holding company after the 2026 reform · property

MaltaGRP · the 6/7 holding company

Monaco and AndorraMonaco's tax regime · the residence card · Andorra's tax system

A separate shelf holds destinations with strong demand and important caveats worth knowing before the move: Turkey (inflation, bank compliance), Thailand (remittance rules changing for the second year running), Georgia (banks and the political backdrop), Serbia, Mauritius. Next in the queue: Germany, France, Switzerland, the Netherlands, the general profiles of Italy and Portugal, and the basic trio of Russian taxes — personal income tax (NDFL) at 13–22%, corporate profits tax at 25%, VAT at 22%.

How to pay less: regimes for new residents

Almost every country that wants your capital is prepared to switch off part of its taxes for a while. Five constructions actually work: non-dom, the lump-sum payment, the inbound-employee regime, the territorial system and the tax holiday. How they are built, how to choose between them and when they get repealed — in the special regimes breakdown. From there, into the specifics:

How each tax works

Every tax has its own political logic and its own lawful weak points. Passing assets on: inheritance tax by country, lifetime gifting and trust taxation. Holding: wealth tax — a map from Spain to Norway — and luxury taxes with their never-ending repeals.

Income and growth: capital gains and the buy-borrow-die strategy, crypto by country, IP box and the inconspicuous withholding tax, which the investor pays before ever seeing the money. Leaving: exit tax — the price of the departure itself. The concepts of VAT/GST, social security contributions, and personal and corporate income tax will follow: this is a living page.

How it is done in practice

Practice lives at the junction of several taxes at once. Three fresh breakdowns: art as a tax instrument — FMV donations, dation en paiement, Acceptance in Lieu and freeports; venture tax reliefs — tiered QSBS after OBBBA, EIS/SEIS and Opportunity Zones 2.0; the mechanics of the charitable deduction — appreciated stock, CRT/CLT and DAF after the 2026 reform.

Alongside them, the permanent shelf: PPLI, Lombard lending instead of selling, upstream step-up, pensions on relocation, QSBS §1202, carried interest, stock options, art: title and lending, philanthropy in the family office.

The economics of a large purchase are set by VAT and transaction taxes: the private jet, the yacht, freeports and storage, property across 11 countries.

Who sees all of this

The transparency and anti-avoidance layer reads every scheme before you do. The foundation: tax residency and the tie-breaker. Then automatic exchange — CRS and CARF; the anti-avoidance doctrines — GAAR and PPT, MLI, DAC6, the substance requirements; the controlled-company rules — Russian CFC (KIK), US CFC, UK CFC, ATAD — and the global minimum, Pillar Two. What is durable is what survives this layer without cosmetics.

Techniques sold on every corner, and their standard endings.

"Resident nowhere." The perpetual traveler theory promises a life with no tax anchor. The ending: everyone has a centre of vital interests — a home, family, accounts — and the country where it stayed will assert its claims retroactively, with penalty interest. The breakdown: perpetual traveler and residency basics.

A certificate without a life. Resident status bought while real life continues in the old country. The ending: the treaty tie-breaker returns you home together with the reassessments, and in a dispute substance decides everything.

A regime with the exit left open. Beckham or a flat tax switched on, the old residency abandoned without being formally closed. In the Russian case that means live obligations under the CFC (KIK) rules and foreign-account reporting running in parallel with the new status. The order is fixed: first close the exit, then switch on the regime.

Layers of paper against automatic exchange. Nominee chains and "wallet foundations" in the CRS/CARF era live until the first exchange. The legal ending is written up in the Danish beneficial owner cases; the everyday one — in penalties for unfiled forms like Form 3520.

FAQ

The move is already decided — where do I start?

Country → regime → exit. First the country profile and the full tax picture of the place, then the special regime with its entry price and its term, then a careful closing of the old residency: exit tax, CFC (KIK), tie-breaker. The sequence is worked through in detail in the special regimes overview and the exit tax article.

Can you legally get to a stable zero?

Yes — with the right income structure and a willingness to actually live in the chosen jurisdiction: territorial and zero-tax systems give zero on foreign income without any special schemes. The price is substance, indirect taxes and the cost of living; the calculation is always run from the specific income structure, because a zero-tax shopfront without presence collapses at the first tie-breaker.

The techniques are described in public — why do they keep working?

White techniques are put into the law deliberately: QSBS, the charitable deduction and the freeport VAT deferral exist because the state uses them to buy behaviour it wants — investment, giving, logistics. They die through repeal of the statute, and that is visible in advance. Grey techniques die quietly and retroactively; on this page they have a section of their own — "popular — and how it ends".

Sources

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