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 is so far only debating the replacement of the IFI with a tax on fortune improductive: the Senate has voted for it several years running, but it was again left out of the final 2026 budget, and the IFI applies unchanged. Spain keeps extending its "temporary" solidarity tax, and Swiss voters rejected a 50% levy on large inheritances at the referendum of 30 November 2025 (21.7% in favour) — 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. Four of them are taken down to the level of individual rules — which is where the calculation usually breaks:
The UK — the 2025 non-dom reform · remittance basis after 6 April 2025 · split-year treatment in the year of the move
The US — U.S. person status · planning tools for Americans abroad · Puerto Rico: Act 60
Singapore — personal income tax · foreign-sourced income · capital gains versus trading income · the 60-day rule · certificate of residence
Russia — dividends for non-residents · the suspension of tax treaties · the capital amnesty
Southern Europe, where our clients look most often:
Spain — the general regime · wealth tax: IP and ITSGF · Beckham · the cluster map
Italy — flat tax €300k · property · succession
Portugal — IFICI · Golden Visa · property
Greece — non-dom €100k · property and ENFIA · Golden Visa
Cyprus — non-dom and the 60-day rule · the holding company after the 2026 reform · property
Malta — GRP · the 6/7 holding company
Monaco and Andorra — Monaco'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.
One more shelf holds the jurisdictions people move to for zero or for territoriality. Genuine zero on personal income comes from Bermuda with its Economic Investment Residential Certificate and from the Cayman Islands and the Bahamas; the Channel Islands and the Isle of Man sell a cap on the tax bill: Jersey and Guernsey tax at 20%, the Isle of Man at 10% and 21% with a cap of £220,000 per person. The territorial logic is held by Costa Rica and Uruguay, with its eleven-year holidays. New Zealand does without CGT and inheritance tax, but the four-year exemption ends in the FIF trap of year five. Liechtenstein sells a lump-sum regime and no tax on gains, Mexico taxes worldwide income and tests the centre of vital interests, and Argentina under Milei is cutting Bienes Personales and granting citizenship in two years. The shelf has one thing in common: what decides is the presence.
What the map does not have yet: 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%. These are known gaps, and we are not putting dates on them.
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; how it is worn down on the way up is shown by the holding ladder and dividend flows. Crypto is covered more broadly than a single tax: the asset class in full — custody, tax, structures — and the crypto-friendly jurisdictions, from VARA to MiCA. Leaving: exit tax — the price of the departure itself, and for Americans the separate mechanics of expatriation and the covered expatriate, where the passport is handed back together with a tax bill. VAT/GST, social security contributions, and personal and corporate income tax are not on this map — a known gap rather than an announcement.
How it is done in practice
Practice lives at the junction of several taxes at once. Four 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; the aircraft as a tax manoeuvre — 100% bonus depreciation after OBBBA and the §280F, §274, §469 and §183 tests, input VAT recovery under Art. 148 of Directive 2006/112, and the price of a personal flight at SIFL rates. The collectibles corner has two breakdowns of its own: capital gains on collectibles assembles the country map of rates at which art, coins and watches are taxed differently from a securities portfolio, while borrowing against a collection instead of selling carries the buy-borrow-die logic over to illiquid assets, where the price of an exit is the tax plus the auction commission.
Alongside them, the permanent shelf: PPLI, Lombard lending instead of selling, upstream step-up, pensions on relocation, QSBS §1202, carried interest, stock options, art and collectibles as an asset class, art: title and lending, philanthropy in the family office. For Russian capital a sanctions calculation now sits beside the tax one: how that changes the choice of wrapper and bank is in sanctions-resilient structures. For two audiences with special tax mechanics there are separate maps: athletes — from Article 17 and duty days to touring bases, and creators — from platform withholding to DAC7.
The economics of a large purchase are set by VAT and transaction taxes: the private jet, the yacht, freeports and storage, property across 8 countries.
Who sees all of this
The transparency and anti-avoidance layer reads every scheme before you do. How it grew out of Swiss secrecy is in the history of tax havens; its present-day construction in full is in tax transparency. The foundation: tax residency and the tie-breaker. Then automatic exchange — CRS and CARF, and the UBO registers, which moved from public access to "legitimate interest" after the CJEU ruling; 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.
For Americans transparency is packaged as a set of forms, and the penalty there is charged for not filing rather than for not paying: FATCA, FBAR and Form 8938, PFIC and Form 8621, the 8865, 8858 and 926 forms on foreign entities. The worst of it is CFC and PFIC stacked, where one offshore company of a US person with EU residence falls under both regimes at once. If the history has already piled up, there is a single door out — voluntary disclosure and amnesties.
Popular — and how it ends
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, the five flags theory 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".