Tax regimes for new residents
Lump-sum regimes, inbound workers, non-domiciled residents, retirees, nomads: the special, temporary or conditional regimes open to people who move in. Each has its own conditions and duration.
Based on the tax regime summaries of the country guides. Figures and their official sources are on each country page.
34 countries
Andorra
Residence without gainful activity (passive residence)Special regime
- Who for?
- People who settle in Andorra without carrying out a gainful activity there: retirees and people living on their assets.
- Which income?
- No tax advantage of its own: it is a residence permit; taxation falls under the IRPF as soon as tax residence is acquired.
- Duration
- Renewable permit, subject to maintaining the investment and the presence.
Residence and self-employment (active residence through foreign investment)Special regime
- Who for?
- Foreigners who set up or take over an Andorran company and are in effective charge of its management.
- Which income?
- No tax advantage of its own: residence and work permit; income is taxed under the IRPF, and company profits under corporate income tax.
- Duration
- Permit renewable as long as the activity is maintained.
Belize
Qualified Retirement Program (QRP)Special regime
- Who for?
- Persons who have reached the programme's minimum age and receive foreign-source pension or investment income, together with their spouse and dependent minor children; no nationality requirement.
- Which income?
- All taxes and levies on foreign-source income, whether earned or passive, remitted or not (section 4(4) of the Retired Persons (Incentives) Act); the Belize Tourism Board adds capital gains tax and inheritance duties. Customs duty exemption on personal effects, one vehicle, one boat and one light aircraft.
- Duration
- Card renewable each year; benefits are lost immediately if a condition ceases to be met (section 3(2)).
Bulgaria
Exemption for disposals of financial instrumentsSpecial regime
- Who for?
- Individuals disposing of financial instruments within the meaning of the law.
- Which income?
- Gains on disposals of financial instruments covered by Article 13 and the definition in the supplementary provisions (notably securities traded on a regulated market).
- Duration
- No time limit.
Colombia
Occasional gainsSpecial regime
- Who for?
- Resident individuals.
- Which income?
- Capital gains on the disposal of assets held beyond the statutory minimum period, inheritances, gifts, bequests, lotteries.
- Duration
- Permanent regime.
Visa for digital nomads and remote workersSpecial regime
- Who for?
- Foreign nationals working remotely for foreign employers or clients, or digital entrepreneurs.
- Which income?
- No tax advantage: beyond the presence threshold, the holder becomes a resident and is taxable on worldwide income, including income paid by a foreign employer.
- Duration
- Maximum duration set by the visa regulations.
Costa Rica
Temporary residence for retirees (pensionado)Special regime
- Who for?
- Foreign nationals receiving a permanent, stable pension from abroad.
- Which income?
- No specific tax advantage: the foreign pension is not taxed because of territoriality.
- Duration
- Renewable temporary residence, subsequently opening the way to permanent residence.
Temporary residence for persons of independent means (rentista)Special regime
- Who for?
- Foreign nationals with a permanent, stable income, from abroad or from banks of the national banking system.
- Which income?
- No specific tax advantage: foreign-source income remains outside the scope of tax; income paid by a Costa Rican bank may be of local source.
- Duration
- Renewable temporary residence.
Investor residence and benefits under Law 9996Temporary
- Who for?
- Foreign investors (real estate, securities, productive project), and by extension rentistas and pensionados covered by Law 9996 of 2021.
- Which income?
- Customs exemptions on personal effects and vehicles and other temporary benefits; no specific income tax exemption.
- Duration
- Renewable permit; customs benefits limited in time.
Remote workers and service providers (Law 10008, “digital nomads”)Special regime
- Who for?
- Employees or self-employed persons working remotely for foreign employers or clients, who can show a minimum income, together with their family.
- Which income?
- Income received from abroad for remote work: full exemption from income tax on profits and confirmation that this income is not of Costa Rican source.
- Duration
- Short-term permit, extendable only once for an equal period; extension conditional on sufficient presence during the first year.
Croatia
Temporary stay for digital nomads and exemption of their remunerationTemporary
- Who for?
- Third-country nationals holding the temporary digital nomad stay permit, working remotely for an employer not registered in Croatia or for their own business.
- Which income?
- Remuneration for employment or activity carried out for an employer not registered in Croatia: it is not considered taxable income.
- Duration
- Duration of the authorised stay, with no extension under the same status.
Flat-rate taxation of small self-employed activitiesConditional
- Who for?
- Self-employed individuals not subject to VAT, including in a joint venture (supoduzetništvo).
- Which income?
- Annual self-employment income, replaced by a flat-rate income set by decision of the tax administration office according to receipts.
- Duration
- As long as receipts remain below the threshold.
Cyprus
Non-dom status: exemption from the special defence contributionSpecial regime
- Who for?
- Tax residents of Cyprus who do not have their domicile of origin there, as long as they are not deemed domiciled because of the length of their tax residence.
- Which income?
- Dividends, interest and rents: exemption from SDC; the contribution to the General Healthcare System remains due on this passive income.
- Duration
- Until the end of the period of residence resulting in deemed domicile, then optional extension by periods.
Deduction for a first employment in CyprusConditional
- Who for?
- Persons who were not resident before their first employment in the Republic and who take up employment there with annual remuneration exceeding the statutory threshold.
- Which income?
- Employment remuneration: deduction of a fraction of taxable income.
- Duration
- Limited duration set by law; not quantified here.
Foreign-source pensions: option for flat-rate taxation (article 20)Special regime
- Who for?
- Tax residents of Cyprus receiving a foreign-source pension.
- Which income?
- Foreign pension: annual allowance, then a flat rate on the excess, instead of the progressive scale.
- Duration
- Annual option, renewable.
Estonia
Digital nomad visaSpecial regime
- Who for?
- Third-country nationals working remotely for a foreign employer or foreign clients; not applicable to a French citizen.
- Which income?
- No tax advantage of its own: it is a visa.
- Duration
- Visa of limited duration.
Georgia
Tax resident status for high-net-worth individualsConditional
- Who for?
- Wealthy individuals who do not meet the presence condition.
- Which income?
- Grants Georgian tax residence and the corresponding certificate; does not create any exemption separate from that for foreign income.
- Duration
- Status to be confirmed for each tax year.
Small business status (sole proprietor)Special regime
- Who for?
- Registered sole proprietors who have obtained the status, excluding excluded activities (notably certain regulated professions and consulting activities).
- Which income?
- Turnover of the activity, not profit.
- Duration
- As long as the status is retained; rules on loss of status not verified.
Greece
Article 5Α ΚΦΕ: flat tax for high-net-worth investorsSpecial regime
- Who for?
- Individuals who transfer their tax residence to Greece without having been resident there during almost all of the reference years, and who invest in Greece (real estate, businesses, securities or company shares) at least the amount required by law; possible extension to family members.
- Which income?
- All foreign-source income, covered by a flat annual tax regardless of its amount; Greek-source income remains subject to the general regime. Exemption from inheritance and gift tax on assets located abroad.
- Duration
- Maximum duration counted from the year the application is filed.
Article 5Β ΚΦΕ: retirees coming from abroadSpecial regime
- Who for?
- Holders of foreign pensions who transfer their tax residence to Greece from a State linked to Greece by an agreement on administrative cooperation in tax matters, without having been resident there during most of the reference years.
- Which income?
- All foreign-source income, at a flat annual rate; Greek-source income remains subject to the general regime.
- Duration
- Maximum duration in tax years.
Article 5Γ ΚΦΕ: employees and self-employed people settling in GreeceSpecial regime
- Who for?
- Individuals who transfer their tax residence to Greece to take up salaried employment or a self-employed activity there, without having been resident there during most of the reference years.
- Which income?
- Income from salaries and from self-employed activity carried out in Greece: exemption of part of the taxable income.
- Duration
- Limited number of tax years starting from the year of the transfer.
Hong Kong
New Capital Investment Entrant Scheme (New CIES)Special regime
- Who for?
- Foreign investors with sufficient net assets, and their families.
- Which income?
- No tax benefit of its own: a residence permit, unrelated to taxation.
- Duration
- Initial permit renewable; permanent residence possible after a period of continuous residence.
Hungary
Long-term investment account (tartós befektetési számla, TBSZ)Conditional
- Who for?
- Individuals who open this account with an investment services provider.
- Which income?
- Gains realised on the investments held in the account.
- Duration
- Lock-in period counted in calendar years after the year of collection.
Flat-rate tax for small taxpayers (kisadózó vállalkozók tételes adója, KATA)Special regime
- Who for?
- Sole proprietors carrying on this activity as their main occupation, who opt in with the tax authority; the act excludes in particular certain employees and holders of an old-age pension.
- Which income?
- Receipts of the sole proprietorship.
- Duration
- As long as the option is maintained and the conditions are met.
Guest investor residence permit (Guest Investor Program)Conditional
- Who for?
- Third-country nationals.
- Which income?
- Not applicable: residence permit, with no tax effect of its own.
- Duration
- Maximum duration of the permit, renewable once.
White Card (digital nomads)Conditional
- Who for?
- Third-country nationals working for a foreign employer or running their own foreign company.
- Which income?
- Not applicable: residence permit. The tax treatment of the holder's income is governed by the general residence rules.
- Duration
- Short-term permit, renewable only once.
Indonesia (Bali)
Territorial taxation of qualified foreigners who have become residentsTemporary
- Who for?
- Foreign nationals who have become Indonesian tax residents and hold specified expertise: employees in certain positions defined by regulation, and foreign researchers.
- Which income?
- All income: only income received or earned in Indonesia is taxed.
- Duration
- A limited number of tax years, counted from the acquisition of tax residence.
Final tax on the turnover of sole proprietors (UMKM)Conditional
- Who for?
- Individuals carrying on a commercial or professional activity whose annual turnover remains below the statutory ceiling.
- Which income?
- Gross turnover of the business, taxed by a final withholding tax instead of the progressive scale; an initial annual portion of turnover is not taxed.
- Duration
- No time limit for individuals as long as the criteria are met, under Regulation PP 20/2026; taxpayers already under the regime before this regulation keep their current period.
Second Home Visa (second residence visa)Special regime
- Who for?
- Foreigners with substantial financial means, and their families.
- Which income?
- No tax benefit of its own: it is a residence permit. According to the Directorate General of Taxes, holding it makes the holder an Indonesian tax resident, the visa's period of validity establishing the intention to reside.
- Duration
- Two possible lengths of stay.
Ireland
Remittance basis for non-domiciled residentsSpecial regime
- Who for?
- Person who is tax resident in Ireland but not domiciled in Ireland within the meaning of general law (domicile of origin or of choice located abroad).
- Which income?
- Foreign-source income and gains on foreign assets; excluded: income from a foreign employment for the part of the duties performed in Ireland, and gains on specified Irish assets (land, buildings, mineral rights located in Ireland).
- Duration
- For as long as the person remains non-domiciled; no maximum period set by the text read.
Ordinarily resident, not residentConditional
- Who for?
- Person who leaves Ireland after having been ordinarily resident there.
- Which income?
- Worldwide income taxed as for a resident, except income from an employment exercised entirely outside Ireland and other foreign income below the annual threshold; worldwide capital gains for as long as ordinary residence lasts.
- Duration
- Until the series of years of non-residence is completed.
Special Assignee Relief Programme (SARP)Special regime
- Who for?
- Employee seconded to Ireland by their employer or an associated company, after a period of employment abroad within the group, and not Irish resident during the required prior period.
- Which income?
- Employment income: a portion of income between a minimum threshold and a ceiling is exempt from income tax; the effect on the USC and PRSI has not been verified.
- Duration
- Consecutive years from the first year of eligibility, up to the maximum duration.
Domicile levyConditional
- Who for?
- Persons domiciled in Ireland, regardless of their residence, who meet all three conditions: worldwide income, Irish property and Irish tax paid.
- Which income?
- Annual flat-rate charge, not a proportional tax.
- Duration
- Each year in which the conditions are met.
Italy
New residents: flat tax on foreign income (article 24-bis TUIR)Special regime
- Who for?
- Individuals who transfer their tax residence to Italy after having been non-resident for almost all of the relevant reference tax periods; may be extended to family members.
- Which income?
- Income produced abroad: annual flat-rate substitute tax, regardless of the amount of that income; Italian-source income remains under the general regime.
- Duration
- Annual election renewed, up to the maximum duration counted from the first tax period.
Foreign retirees in the South: substitute tax (article 24-ter TUIR)Special regime
- Who for?
- Recipients of pensions paid by foreign bodies who transfer their residence to a small municipality in the Mezzogiorno (or certain other municipalities covered by the law), after a period of non-residence in Italy.
- Which income?
- Any category of income produced abroad, subject to a substitute tax in lieu of IRPEF.
- Duration
- The period of the transfer and the following tax periods covered by the election.
Impatriate workers: regime reformed in 2024 (article 5 of Legislative Decree no. 209/2023)Special regime
- Who for?
- Employees, assimilated workers and self-employed individuals who transfer their tax residence to Italy, demonstrate high qualifications or specialisation and were not resident in Italy during the required preceding tax periods (a longer period applies if they stay with the same employer or group).
- Which income?
- Employment and business income produced in Italy: only a fraction enters the IRPEF tax base, a fraction that is reduced where there is a minor child or a birth during the regime, subject to an annual ceiling.
- Duration
- The period of the transfer and the following tax periods, within the limit of the cited figure.
Malaysia
Exemption of foreign-source income of individualsTemporary
- Who for?
- Resident individuals.
- Which income?
- Foreign-source income received in Malaysia, of any kind, except income from an activity carried on through a partnership.
- Duration
- From 1 January 2022 to 31 December 2036.
Malaysia My Second Home (MM2H)Special regime
- Who for?
- Foreign nationals wishing to reside in Malaysia on a long-term basis without working there, and their families; Silver, Gold and Platinum categories.
- Which income?
- No tax advantage of its own: it is a residence permit; taxation is governed by the ordinary regimes.
- Duration
- Validity of the permit depends on the category; renewable.
Mauritius
Premium Visa (remote work and long stay)Special regime
- Who for?
- Non-citizen foreigners who stay in Mauritius while working remotely for foreign clients or employers, or living on foreign income; treatment extended to Golden Visa holders by the Finance Act 2026.
- Which income?
- Employment or business income earned remotely from Mauritius for foreign parties.
- Duration
- Duration of the visa, renewable.
Occupation and residence permits of the Economic Development BoardSpecial regime
- Who for?
- Investors, purchasers of a property under an approved real estate scheme, and non-citizen retirees.
- Which income?
- No tax advantage of its own: these are residence permits; taxation follows the general tax residence rules.
- Duration
- Duration of the permit, renewable; the permit linked to a property purchase lasts for as long as the property is held.
Morocco
Retirees: allowance on pensions and reduction for foreign-source pensionsSpecial regime
- Who for?
- Retirees with their tax domicile in Morocco, in particular foreign retirees receiving a foreign-source pension.
- Which income?
- Retirement pensions and life annuities; pensions from Moroccan basic pension schemes have been exempt since 1 January 2026, which applies neither to supplementary schemes nor to foreign pensions.
- Duration
- Year by year, for as long as transfers are made.
Withholding tax on dividends: rates by financial year (2023-2026 reform)Temporary
- Who for?
- Recipients, resident or not, of income from shares, partnership interests and similar income distributed by Moroccan companies.
- Which income?
- Dividends and similar income; fixed-income investment proceeds are subject to a separate specific rate.
- Duration
- Rates decrease by financial year down to the target rate applicable to profits of financial years opened from 2026; the transitional rates remain applicable to later distributions of profits from 2023 to 2025.
Casablanca Finance City (CFC) status: employeesTemporary
- Who for?
- Employees of companies with CFC status, excluding credit institutions and insurance and reinsurance companies.
- Which income?
- Gross salaries, emoluments and wages.
- Duration
- Maximum period counted from the start of employment.
New Zealand
Transitional resident (temporary exemption of foreign income)Temporary
- Who for?
- New migrants and returning New Zealanders who became tax resident on or after 1 April 2006 and who were not tax resident at any time during the required period before their arrival; exemption granted only once.
- Which income?
- Most foreign-source income: interest, dividends, FIF income, foreign rents; specific rule for lump-sum withdrawals from foreign pension funds. Excluded: employment income and personal services income received from abroad.
- Duration
- From the first day of tax residence until the end of the period counted from the end of the month in which the person meets the presence test or the permanent place of abode test, whichever of the two dates is earlier.
FIF regime for foreign investments and revenue account methodConditional
- Who for?
- Residents (outside the transitional resident period) holding interests in foreign companies or funds above the de minimis threshold; revenue account method reserved for recent migrants and residents returning after a long absence.
- Which income?
- Deemed income equal to a flat fraction of the opening value of the holdings (fair dividend rate method); under the revenue account method, dividends received and gains realised after a discount.
- Duration
- Permanent.
Non-resident visitors (remote work)Conditional
- Who for?
- Visitors arriving on or after 1 April 2026, resident in a country with a comparable income tax system, whose remote work does not require their presence in New Zealand.
- Which income?
- Income from remote work for a foreign employer or foreign clients.
- Duration
- Within the number of days allowed over the reference period.
Active Investor Plus Visa (residence by investment)Conditional
- Who for?
- Investors and their family (partner, dependent children); no connection with tax status.
- Which income?
- Not applicable: a residence route, not a tax regime.
- Duration
- Investment period specific to each category.
Oman
Golden Residency (long-term residency for investors)Special regime
- Who for?
- Foreign investors and their families; separate route for talents.
- Which income?
- No tax benefit of its own: it is a residence permit.
- Duration
- Renewable long-term permit.
Panama
Retired or pensioned resident (pensionado)Special regime
- Who for?
- Retirees and pensioners with a lifetime pension of a minimum monthly amount.
- Which income?
- No income tax exemption specific to the status: a foreign pension is not taxed by virtue of territoriality. The status opens up statutory discounts on services (transport, healthcare, leisure).
- Duration
- Permanent residence.
"Friendly nations" residence (Países Específicos)Special regime
- Who for?
- Nationals of the countries listed by decree that maintain privileged relations with Panama.
- Which income?
- No specific tax advantage: residence permit.
- Duration
- Provisional residence, followed by an application for permanent residence.
Qualified investor residence (Inversionista Calificado)Special regime
- Who for?
- Foreign investors making a significant investment in Panama, together with their family.
- Which income?
- No specific tax advantage: residence permit with fast-track processing.
- Duration
- Permanent residence.
Paraguay
Investor Pass (investor residency)Special regime
- Who for?
- Foreign investors making an investment in Paraguay.
- Which income?
- No tax advantage of its own: accelerated residency procedure.
- Duration
- Depends on the residence permit obtained.
Philippines
Special Resident Retiree’s Visa (SRRV)Special regime
- Who for?
- Foreigners who have reached the programme's minimum age, as well as their spouse and unmarried children within the limits of the programme; Classic option, and Courtesy option for certain groups (notably former Filipinos).
- Which income?
- Permanent residence permit. The Philippine Retirement Authority mentions an exemption from tax on pensions and annuities, a one-time exemption from customs duties on personal effects and an exemption from the travel tax; for other income, the general regime for resident aliens applies.
- Duration
- Stay of indefinite duration, as long as the programme's conditions, including the deposit, are maintained.
Poland
Linear tax (podatek liniowy)Conditional
- Who for?
- Sole proprietors carrying on a business activity, by election.
- Which income?
- Income from the business activity, in place of the tax scale.
- Duration
- For as long as the election is maintained.
Lump-sum tax on recorded revenue (ryczałt od przychodów ewidencjonowanych)Conditional
- Who for?
- Sole proprietors and partners in eligible partnerships, by election.
- Which income?
- Revenue from the activity, with no deduction of expenses.
- Duration
- For as long as the election is maintained and the conditions are met.
Lump-sum tax on foreign income for persons transferring their residence to Poland (art. 30j to 30p)Special regime
- Who for?
- Individual who transfers their tax residence to Poland without having been resident there for most of the reference period; the option is also open to family members.
- Which income?
- All income obtained abroad, except income of controlled foreign companies.
- Duration
- Fixed maximum duration starting from the year of the transfer; renunciation possible (PIT-RPZ); lost in the event of departure, late payment or failure to make the required expenditure.
Ulga na powrót — temporary exemption for persons who (re)settle in PolandTemporary
- Who for?
- Person of Polish nationality, holder of the Karte Polaka, or national of another EU or EEA state or of Switzerland — and therefore a French national — or meeting the alternative condition of prior residence, who becomes a Polish resident.
- Which income?
- Salaries, contracts of mandate with a company, income from business activity, maternity allowance; not business management contracts.
- Duration
- Consecutive tax years starting from the year of the transfer or the following year, at the taxpayer's choice.
Portugal
IFICI: tax incentive for scientific research and innovation (article 58.º-A EBF)Special regime
- Who for?
- Individuals who become tax resident in Portugal without having been so during the required preceding years, and who carry out an activity on the exhaustive list: higher education and research, qualified jobs linked to investments receiving benefits, highly qualified professions, research and development, certified startups, certain activities in the Azores and Madeira. Excludes former NHR beneficiaries and those under the regime of article 12.º-A of the IRS code. Does not target retirees.
- Which income?
- Net income of categories A and B (salaries and self-employment) derived from the eligible activity, at a special rate, with an option to aggregate. Foreign-source income is exempt, except for pensions (category H); income from a preferential-tax jurisdiction is taxed at an increased rate.
- Duration
- Consecutive years starting from the year of registration as a resident.
Singapore
Global Investor Programme (GIP)Special regime
- Who for?
- Entrepreneurs, investors and family office executives with substantial wealth and a substantial business track record.
- Which income?
- No tax advantage of its own: permanent resident status.
- Duration
- Re-entry permit renewable subject to conditions.
Spain
Regime for displaced workers (Article 93 LIRPF, known as the Beckham law)Special regime
- Who for?
- Individuals who acquire Spanish tax residence following a relocation: employees (employment contract, transfer, remote work for a foreign employer), directors of companies other than asset-holding companies, founders of an entrepreneurial activity, highly qualified professionals working for start-ups or in research and innovation; spouse and children under conditions.
- Which income?
- Taxed under the IRNR rules: general base at the regime's rate up to the threshold, then at a higher rate beyond it; dividends, interest and capital gains at the savings base scale. No offsetting between types of income.
- Duration
- Year in which residence is acquired and the following tax periods, within the limit stated.
Thailand
LTR visa: exemption for remitted foreign incomeSpecial regime
- Who for?
- Holders of the Long-Term Resident visa in the Wealthy Global Citizen, Wealthy Pensioner and Work-from-Thailand Professional categories.
- Which income?
- Foreign-source income derived from employment, from an activity carried out abroad or from property located abroad, brought into Thailand.
- Duration
- For the period of validity of the LTR visa, initial permit renewable.
LTR visa: flat rate for highly skilled professionalsSpecial regime
- Who for?
- Holders of the LTR visa in the Highly Skilled Professional category.
- Which income?
- Employment income paid by a company or partnership operating in a targeted industry, subject to withholding at a reduced rate instead of the progressive scale.
- Duration
- For the period of validity of the LTR visa.
Destination Thailand Visa (DTV)Special regime
- Who for?
- Remote workers, freelancers and foreign talents, participants in Thai soft power activities (Muay Thai, cooking, medical treatment), as well as their spouse and children.
- Which income?
- No tax advantage of its own: it is a residence permit. Income follows the general regime, including the remittance rule.
- Duration
- Multi-year validity with multiple entries.
Turkey
Exemption of foreign income for new residents (article mükerrer 20/D)Temporary
- Who for?
- Individuals who become Turkish tax residents from 2026, with no domicile or tax liability in Turkey during the previous three calendar years, in particular with no Turkish salary during that period.
- Which income?
- Foreign-source gains and income; they are not included in the annual return.
- Duration
- Fixed statutory period starting from settlement.
Citizenship by investmentSpecial regime
- Who for?
- Foreign investors and their families.
- Which income?
- No tax advantage of its own: nationality does not amount to tax residence.
- Duration
- Holding commitment for the statutory period; permanent nationality.
United Arab Emirates (Dubai)
Investor Golden Visa (Dubai)Special regime
- Who for?
- Real estate investors, company investors or holders of a bank deposit, and their families.
- Which income?
- No tax advantage of its own: a long-term residence permit, with no automatic effect on tax residence.
- Duration
- Renewable long-term permit.
United Kingdom
Foreign Income and Gains (FIG) regimeSpecial regime
- Who for?
- New UK tax resident arriving after the required period of consecutive tax years of non-residence.
- Which income?
- Foreign income (profits from an activity carried on entirely outside the United Kingdom, foreign property income, dividends from non-resident companies, foreign interest, etc.) and foreign capital gains. Excluded: foreign employment income (covered by Overseas Workday Relief).
- Duration
- Consecutive tax years from the start of residence, up to the maximum duration; years in which no claim is made are lost.
Overseas Workday Relief (OWR)Special regime
- Who for?
- Employee who is a "qualifying new resident": non-resident for the required period of tax years before arrival.
- Which income?
- Employment income corresponding to the days worked outside the United Kingdom.
- Duration
- Tax years of residence, up to the maximum duration of new resident status.
Temporary Repatriation Facility (TRF)Temporary
- Who for?
- Former users of the remittance basis.
- Which income?
- Foreign income and gains arising before 6 April 2025 that have not yet been remitted (qualifying overseas capital), designated in the return.
- Duration
- Three tax years, 2025-26 to 2027-28.
United States
Foreign earned income exclusion (FEIE)Conditional
- Who for?
- US citizens and residents living abroad.
- Which income?
- Earned income (salaries, self-employment income) earned abroad; not investment income.
- Duration
- Annual, with an indexed ceiling.
E-2 treaty investor visaConditional
- Who for?
- Nationals of a country linked to the United States by a treaty providing for the E-2 (including France) who invest in a US business, and certain employees of the same nationality.
- Which income?
- No tax advantage: non-immigrant residence status; tax residence follows the presence tests.
- Duration
- According to the validity of the visa and the admission recorded on Form I-94; renewable as long as the conditions are met.
EB-5: permanent residence by investmentSpecial regime
- Who for?
- Investors of any nationality.
- Which income?
- No tax advantage: the green card makes the holder a tax resident taxed on worldwide income.
- Duration
- Conditional permanent residence, followed by removal of the conditions.
Uruguay
Impatriate regime, residence acquired up to 2025 (article 24 of Title 7): IRNR option or reduced-rate optionTemporary
- Who for?
- Individuals who became tax resident before 2026 and exercised the option no later than 31 December 2025; the option has been closed to new residents since 1 January 2026.
- Which income?
- Foreign-source income from movable capital (item 2 of article 6 of Title 7).
- Duration
- IRNR option: arrival year included, within the statutory limit; reduced-rate option: no end date in the text reviewed.
Impatriate regime, residence acquired since 2026 (article 24-BIS of Title 7): IRNR optionTemporary
- Who for?
- Individuals who acquire tax residence from 1 January 2026 and were not tax resident in the immediately preceding years required.
- Which income?
- Foreign-source income from movable capital and capital gains (item 2 of article 6 of Title 7).
- Duration
- Year of acquisition of residence and following years, within the statutory limit; option not renewable.
After the impatriate regime of article 24-BIS: temporary reduced rate or flat-rate taxConditionalAdopted, applies later
- Who for?
- Impatriates under article 24-BIS (residences acquired since 2026), at the end of the IRNR option period; the text reviewed does not provide for these options for beneficiaries of article 24.
- Which income?
- Foreign-source capital income and capital gains.
- Duration
- Additional period for the reduced rate; annual options for the flat-rate tax, within the statutory limit.
Tax residence by investment with reduced presenceConditional
- Who for?
- Individuals who do not reside in Uruguay for more than half of the year but invest there.
- Which income?
- No tax relief in itself: the route establishes tax residence (economic interests), which is useful in particular for obtaining a residence certificate.
- Duration
- Calendar year by calendar year, as long as the conditions are met.
Vanuatu
Citizenship by contribution: Development Support Program (DSP)Special regime
- Who for?
- Foreign nationals and their families wishing to acquire Vanuatu nationality through a financial contribution, with no residence requirement.
- Which income?
- No tax advantage of its own: it is a naturalisation, not a tax regime.
- Duration
- Nationality acquired permanently, subject to the revocations provided for by the citizenship law.
Key terms
- Tax residence
- the country that taxes a person on their income, according to presence, home or centre-of-interests criteria specific to each country.
- Worldwide income
- a resident is taxed on all income wherever it arises; tax treaties prevent double taxation.
- Territorial taxation
- only locally sourced income is taxed; foreign-source income is not, save for exceptions set by law.
- Remittance basis
- foreign income is taxed only if it is brought into the country.
- Domicile
- a notion distinct from residence in some countries (Malta, Cyprus); a non-domiciled resident may benefit from a special regime there.
An invoice to a foreign client, a payment received on a foreign account and foreign-source income are not the same thing. A company registered abroad does not move the place where the business is carried on, nor the residence of its director.