Portugal IFICI (NHR 2.0): New Tax Regime Replacing Non-Habitual Resident
How IFICI works—the successor to NHR in Portugal: 20% on professional income, foreign income exemption, who qualifies, and how it differs from the old regime.
Tax regimes, investment transactions, CFC, ESOPs, secondaries and private capital.
First identify tax residence and the applicable regime, then compare the instrument, ownership structure and timing of income recognition. The section separates general models, country rules and practical private-capital scenarios.
The section does not reduce a decision to expected return. A useful comparison also covers legal wrapper, liquidity, currency, tax timing, reporting, control and transferability. Keep the instrument, the jurisdiction and the owner-specific scenario separate: the same investment can produce a different outcome under another residence, ownership route or funding source. Collect those factors first, then move to calculations and professional verification.
Use the topic as a reading route. Open an overview hub, then two or three closely relevant articles and compare them against one consistent set of criteria. On every page, check the modification date, scope and links to primary sources because rules, pricing and administrative practice change. If the research supports a decision about a specific person, company or asset, turn the shortlisted options into questions and confirm the current conditions before acting.
The catalogue is generated from the current Published corpus. A page appears here only when its public snapshot matches the active index revision; archived and quarantined material is excluded. This is a research map, not individual legal, tax or investment advice.
How IFICI works—the successor to NHR in Portugal: 20% on professional income, foreign income exemption, who qualifies, and how it differs from the old regime.
Residence by investment in the Cayman Islands and Bahamas: KYD and USD thresholds, zero income tax, and why a certificate from a zero-tax jurisdiction doesn't always sever prior residency.
How to obtain Uruguay tax residency after the 2026 reform (Law 20.446): new investment threshold around 2 million USD, 11-year tax holidays, and 12% rate on foreign income.
When you cease to be a Russian tax resident, how it changes personal income tax (30% vs. 13–22%), what happens with real estate sales, and why remote work for a Russian employer is an exception.
Who remains a Russian currency resident, how to notify the tax authority about foreign accounts, what ODDS is, who is exempt after 183+ days abroad, and penalties under Article 15.25.
Citizenship, tax residency, assets, business and where you live across jurisdictions: how the Five Flags Theory works today — adjusted for CRS, FATCA and Pillar Two.
Blocked Russian securities at Euroclear and Clearstream: how the individual licence regimes of Belgium, Luxembourg and OFAC work, what the review actually turns on, and how long it takes.
Act 60 (Individual Resident Investor): 0% on capital gains, dividends, and interest for bona fide residents; 4% from 2027; 183-day test, $10k contribution. Tool for US persons.
Lock-up period after IPO: what it is, standard 90–180 day terms, underwriter's right to early release, and why the restriction is doubly critical for SPV and secondary market investors.
Greek non-dom (Art. 5A): €100k/year on foreign income, 15 years, €500k investment; 7% for pensioners (5B); 50% relief for relocating workers (5C).
Thailand taxes remitted foreign income from 2024 (Por 161/162); proposed 2026 exemption; LTR visas (10 years, tax relief) and DTV visas (5 years) for remote workers.
Georgia does not tax foreign-source income of individuals (territorial principle); residency via 183 days or HNWI status; 1% tax for sole proprietors; residence permits.
Italy's neo-residenti regime (Art. 24-bis TUIR): fixed tax on foreign income €100k→€200k→€300k from 2026, 15 years, 9/10 year condition, investor and elective visa options.
Cyprus non-dom status: 0% tax on dividends and interest for up to 17 years (SDC exemption), 60-day tax residency rule, GeSY contribution, residence permits and permanent residency.
Varlık Barışı 2026: which foreign and undeclared assets can be declared by July 31, 2027, rates 0-5%, deadlines and AML risks under Turkish law № 7582.
Turkish residence permit (ikamet) types, property-based residence from USD 200,000, digital nomad visa, citizenship from USD 400,000, and how immigration status relates to tax residency.
Turkey's new non-dom regime: 20 years tax-free on foreign income for new residents, 3-year non-residency requirement, 1% inheritance tax, and compliance risks.
British CFC rules: TIOPA 2010 Part 9A, gateway tests, charge calculation and interaction with Transfer of Assets Abroad and the FIG regime.
CFC rules under EU ATAD I (Articles 7–8): two approaches to income attribution and implementation across EU Member States for holding structures.
UAE tax residency (Cabinet Decision 85/2022): 183/90-day tests, 0% personal income tax, Golden Visa, TRC, DMTT 15% for large groups from 2025.
Singapore's Variable Capital Company (2020) for investment funds: one legal entity holding multiple sub-funds with segregated assets — structure and use cases.
Venture Capital Fund Manager (VCFM) — a simplified MAS licensing regime in Singapore for VC fund managers. Eligibility, faster authorisation and fit for family offices.
How IRC §1202 excludes up to 100% of QSBS gain, what OBBBA 2025 changed (50/75/100% tiers, $15M cap, $75M asset test), stacking through non-grantor trusts, §1045, and why timing is everything for the American living abroad.
How to buy pre-IPO unicorn shares on the secondary market: deals between existing shareholders. Access, structures and minimums for private-capital investors.
Removing OFAC sanctions and unblocking assets: how the U.S. Treasury process works, delisting petitions and what UHNW clients must document to release frozen funds.
From January 1, 2025, Hong Kong applies OECD Pillar 2 at 15% for MNE groups above EUR750M revenue. Impact on private holdings.
Side letters in private funds: bilateral agreements granting an LP terms beyond the standard subscription docs. What they cover, MFN clauses and how LPs negotiate them.
Tax planning strategy combining Spanish Beckham Law residency with a Hong Kong company: offshore income, PE risks, dividends, expenses, and compliance controls.