# Taxes: a map of institutions, regimes and manoeuvres

> One map for private capital taxation: institutions (wealth tax, inheritance, exit tax, VAT), special regimes for new residents, country profiles and mitigation mechanics — art, venture, philanthropy.

Author: Алёна Дунаева — юрист, Family Office (https://wiki.private.law/authors/dunaeva)
Last modified: 2026-08-03T16:25:00.000Z
Canonical: https://wiki.private.law/en/taxes
Topics: investments
Jurisdictions: global
Semantic tags: tax-regime, wealth-planning
Article type: hub

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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](https://wiki.private.law/uk-tax-residence-worldwide-taxation), [the US](https://wiki.private.law/us-tax-residency), [Singapore](/singapore-hub), [Hong Kong](https://wiki.private.law/hong-kong-tax-residence), [the UAE](https://wiki.private.law/uae-tax-residency) and [Russia](https://wiki.private.law/russia-hub).

Southern Europe, where our clients look most often:

**Spain** — [the general regime](https://wiki.private.law/spain-tax-residency) · [wealth tax: IP and ITSGF](https://wiki.private.law/spain-wealth-tax) · [Beckham](https://wiki.private.law/beckham-law) · [the cluster map](https://wiki.private.law/spain-hub)

**Italy** — [flat tax €300k](https://wiki.private.law/italy-flat-tax) · [property](https://wiki.private.law/italy-property-purchase) · [succession](https://wiki.private.law/italy-intestate-succession)

**Portugal** — [IFICI](https://wiki.private.law/portugal-ifici) · [Golden Visa](https://wiki.private.law/portugal-golden-visa) · [property](https://wiki.private.law/portugal-property-purchase)

**Greece** — [non-dom €100k](https://wiki.private.law/greece-non-dom) · [property and ENFIA](https://wiki.private.law/greece-property-purchase) · [Golden Visa](https://wiki.private.law/greece-golden-visa)

**Cyprus** — [non-dom and the 60-day rule](https://wiki.private.law/cyprus-non-dom) · [the holding company after the 2026 reform](https://wiki.private.law/company-cyprus) · [property](https://wiki.private.law/cyprus-property-purchase)

**Malta** — [GRP](https://wiki.private.law/global-residence-program) · [the 6/7 holding company](https://wiki.private.law/company-malta)

**Monaco and Andorra** — [Monaco's tax regime](https://wiki.private.law/monaco-tax) · [the residence card](https://wiki.private.law/monaco-residence-permit) · [Andorra's tax system](https://wiki.private.law/andorra-tax)

A separate shelf holds destinations with strong demand and important caveats worth knowing before the move: [Turkey](https://wiki.private.law/turkey-tax-holiday) (inflation, bank compliance), [Thailand](https://wiki.private.law/thailand-foreign-income-tax) (remittance rules changing for the second year running), [Georgia](https://wiki.private.law/georgia-territorial-tax) (banks and the political backdrop), [Serbia](https://wiki.private.law/serbia-tax), [Mauritius](https://wiki.private.law/mauritius-residence). 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](https://wiki.private.law/special-tax-regimes). From there, into the specifics:

> 🔗 **The regimes**
> [UK FIG](https://wiki.private.law/uk-fig-regime) · [Cyprus non-dom](https://wiki.private.law/cyprus-non-dom) · [Greece](https://wiki.private.law/greece-non-dom) · [Malta GRP](https://wiki.private.law/global-residence-program) · [Italy €300k](https://wiki.private.law/italy-flat-tax) · [Swiss lump sum](https://wiki.private.law/switzerland-flat-tax) · [Beckham](https://wiki.private.law/beckham-law) · [Portugal IFICI](https://wiki.private.law/portugal-ifici) · [Turkey: 20 years](https://wiki.private.law/turkey-tax-holiday) · [Israel: 10 years](https://wiki.private.law/israel-10-year-exemption) · [Georgia](https://wiki.private.law/georgia-territorial-tax) · [UAE](https://wiki.private.law/uae-tax-residency) · [Monaco](https://wiki.private.law/monaco-tax)

## How each tax works

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

Income and growth: [capital gains and the buy-borrow-die strategy](https://wiki.private.law/capital-gains-tax), [crypto by country](https://wiki.private.law/crypto-tax-by-country), [IP box](https://wiki.private.law/ip-box) and the inconspicuous [withholding tax](https://wiki.private.law/withholding-tax), which the investor pays before ever seeing the money. Leaving: [exit tax](https://wiki.private.law/exit-taxes-overview) — 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](https://wiki.private.law/art-tax-planning) — FMV donations, dation en paiement, Acceptance in Lieu and freeports; [venture tax reliefs](https://wiki.private.law/venture-tax-benefits) — tiered QSBS after OBBBA, EIS/SEIS and Opportunity Zones 2.0; [the mechanics of the charitable deduction](https://wiki.private.law/charitable-deduction) — appreciated stock, CRT/CLT and DAF after the 2026 reform.

Alongside them, the permanent shelf: [PPLI](https://wiki.private.law/ppli), [Lombard lending instead of selling](https://wiki.private.law/lombard-lending), [upstream step-up](https://wiki.private.law/upstream-basis-step-up), [pensions on relocation](https://wiki.private.law/pensions-relocation), [QSBS §1202](https://wiki.private.law/qsbs-section-1202), [carried interest](https://wiki.private.law/carried-interest-2026), [stock options](https://wiki.private.law/esop), [art: title and lending](https://wiki.private.law/art-title-and-lending), [philanthropy in the family office](https://wiki.private.law/philanthropy-family-office).

The economics of a large purchase are set by VAT and transaction taxes: [the private jet](https://wiki.private.law/private-jet), [the yacht](https://wiki.private.law/yacht-ownership), [freeports and storage](https://wiki.private.law/precious-metals-vaults), [property across 11 countries](https://wiki.private.law/foreign-real-estate-purchase).

## Who sees all of this

The transparency and anti-avoidance layer reads every scheme before you do. The foundation: [tax residency](https://wiki.private.law/tax-residency-basics) and the [tie-breaker](https://wiki.private.law/tax-residency-tiebreaker). Then automatic exchange — [CRS](https://wiki.private.law/crs-overview) and [CARF](https://wiki.private.law/carf-practice); the anti-avoidance doctrines — [GAAR and PPT](https://wiki.private.law/gaar-ppt), [MLI](https://wiki.private.law/mli-treaty-shopping), [DAC6](https://wiki.private.law/dac6-hallmarks), the [substance](https://wiki.private.law/economic-substance) requirements; the controlled-company rules — [Russian CFC (KIK)](https://wiki.private.law/kik), [US CFC](https://wiki.private.law/us-cfc), [UK CFC](https://wiki.private.law/uk-cfc), [ATAD](https://wiki.private.law/eu-atad-cfc) — and the global minimum, [Pillar Two](https://wiki.private.law/pillar-two). What is durable is what survives this layer without cosmetics.

## 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](https://wiki.private.law/perpetual-traveler) and [residency basics](https://wiki.private.law/tax-residency-basics).

**A certificate without a life.** Resident status bought while real life continues in the old country. The ending: the treaty [tie-breaker](https://wiki.private.law/tax-residency-tiebreaker) returns you home together with the reassessments, and in a dispute [substance](https://wiki.private.law/economic-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](https://wiki.private.law/kik) and [foreign-account reporting](https://wiki.private.law/russia-foreign-account-reporting) running in parallel with the new status. The order is fixed: first [close the exit](https://wiki.private.law/russia-tax-residency-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](https://wiki.private.law/gaar-ppt); the everyday one — in penalties for unfiled forms like [Form 3520](https://wiki.private.law/us-foreign-trusts-form-3520).

> 🍓 The entry point depends on the question. "How much will I pay" — the countries. "How do I pay less" — the regimes. "How is it built" — the taxes themselves. "How is it done" — the techniques. This is a living page: new breakdowns appear here as they are released.

## 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](https://wiki.private.law/special-tax-regimes) and the [exit tax article](https://wiki.private.law/exit-taxes-overview).

### 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

- [OECD — BEPS, Pillar Two and information exchange](https://www.oecd.org/tax/beps/)
- [GOV.UK — tax on foreign income](https://www.gov.uk/tax-foreign-income)
- [Agencia Tributaria — the ITSGF solidarity tax](https://sede.agenciatributaria.gob.es/Sede/en_gb/declaraciones-informativas-otros-impuestos-tasas/impuesto-temporal-solidaridad-grandes-fortunas.html)
- [Regjeringen.no — Norway's exit tax rules](https://www.regjeringen.no/en/whats-new/the-national-budget-2025-closing-tax-loopholes-by-amending-the-exit-tax-rules/id3055749/)

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## 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".

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## Factual claims

- Italy — flat tax €300k · property · succession
- 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
- Every tax has its own political logic and its own lawful weak points.
- 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.
