Low-tax residency for high earners (2026): 14 regimes compared

Tax & Residency
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The lowest-tax residency for a high earner depends on where the income comes from. If most of it is foreign investment income, lump-sum regimes (Italy €300,000 a year for new arrivals, Greece €100,000, Switzerland on a deemed base of at least CHF 435,000 for 2026) or zero-tax countries (UAE, Bahamas) work. If you earn from active work, the UAE, Andorra (10% top rate) or Puerto Rico’s 4% export services rate fit better. US citizens are taxed on worldwide income wherever they live, so for them most of this list does little, with Puerto Rico the main exception.

Last checked: October 2026

In short:

  • Lump-sum regimes tax foreign income at a fixed amount: Italy €300,000 a year for those moving from 1 January 2026 (up from €200,000), Greece €100,000 plus a €500,000 investment, Switzerland on a deemed living-cost base of at least CHF 435,000 at federal level for 2026.
  • Zero or near-zero systems: UAE and Bahamas (no personal income tax), Panama and Paraguay (territorial), Andorra (10% top rate), Puerto Rico (0% on passive income for decrees applied for by 31 December 2026, then 4% for later applicants).
  • Time-limited regimes for newcomers: UK FIG (4 years), Portugal IFICI (10 years at 20% on qualifying work income), Uruguay (1+10 years), Cyprus non-dom (17 years, extendable for €250,000 per five years).

The comparison table

Figures come from tax authorities, official legislation summaries, Big 4 firms or law firms, checked October 2026 (see Sources). “Minimum stay” means the rule for the regime or for tax residence where we could confirm it. Each row links to our full guide.

Country Regime Headline tax Cost / investment Minimum stay Duration Best for
Italy (Italy flat tax for new residents (2026): lump-sum regime, cost, who it suits) Lump-sum for new residents €300,000 a year on all foreign income (moved from 2026); €50,000 per family member The tax itself; 9 of prior 10 years non-resident Must become Italian tax resident Up to 15 years Very large foreign investment income, EU lifestyle
Greece (Greece non-dom regime (2026): €100,000 flat tax, investment and how to apply) Non-dom lump sum €100,000 a year on foreign income; €20,000 per family member €500,000 investment in property, business or securities; 7 of prior 8 years non-resident Must become Greek tax resident Up to 15 years Large foreign income, cheaper than Italy
Switzerland (Switzerland lump-sum taxation (2026): forfait fiscal, minimums and cantons) Expenditure-based (lump-sum) Normal rates on a deemed base: at least CHF 435,000 federal for 2026 (indexed; cantons set their own minimums), or 7x rent if higher No Swiss work allowed; foreign nationals only Swiss residence While conditions are met Wealthy, not working, want Swiss stability
Puerto Rico (Puerto Rico Act 60 (2026): 0% capital gains, 4% business tax and the catches) Act 60 0% on dividends, interest, post-move gains (decrees by 31 Dec 2026, to 2035); 4% for later applicants (to 2055); 4% on export services $10,000 a year to approved non-profits; buy a home within 2 years 183 days (IRS presence test) To 2035 or 2055 US citizens; traders and service businesses
UK (Leaving the UK (2026): Statutory Residence Test, split year and FIG regime) 4-year FIG regime 0% UK tax on claimed foreign income and gains (not foreign employment income) None; you lose personal allowance and CGT exemption UK resident under the SRT 4 years Returners and newcomers after 10 years away
Andorra (Andorra residency (2026): passive vs active, 10% tax and the new €1m rule) Standard system 10% top rate; first €24,000 exempt Passive residence (Law 2/2026): €1 million invested, or €400,000 to the national Housing Fund, plus a €50,000 non-refundable payment 90 days a year (passive); tax residence over 183 days Ongoing Europeans wanting low flat tax
Bahamas (Bahamas residency (2026): permits, $1M permanent route, BEATS and tax) Standard system No personal income tax Permanent residence (economic route): at least $1.0 million in real estate or Central Bank bonds; annual permits and BEATS cost far less Not confirmed Ongoing Americas time zone, property buyers
Panama (Panama residency (2026): Friendly Nations, Qualified Investor, Pensionado) Territorial system Foreign-source income untaxed; local income up to 25% Qualified Investor: $300,000 new-build property, $500,000 resale or securities Not confirmed Ongoing Location-independent business owners
UAE (UAE Golden Visa (2026): categories, AED 2M property rule, costs and tax) Standard system 0% personal income tax Golden Visa via property of at least AED 2 million (other routes exist) Tax residence: 183 days, or 90 days with conditions Golden Visa 10 years, renewable Active founders and high earners
Malta (Malta residency (2026): nomad permit vs GRP vs MPRP compared) Global Residence Programme 15% on foreign income remitted; minimum €15,000 a year Property €275,000 (€220,000 south Malta or Gozo) or rent €9,600 (€8,750); non-EU nationals Not over 183 days in any other country Applications by 31 Dec 2026 keep these rules to 2031; replaced from 2027 by the Individual Tax Programme (€35,000 minimum tax) Non-EU nationals with income that can stay offshore
Portugal (NHR Portugal is closed: what IFICI (NHR 2.0) offers instead (2026)) IFICI (“NHR 2.0”) 20% on qualifying employment and professional income; most foreign income exempt (not pensions or blacklisted sources) Must work in eligible activities; 5 prior years non-resident Must become Portuguese tax resident 10 years Tech, research and qualifying professionals
Cyprus (Cyprus company formation (2026): the 15% tax, non-dom and setup steps) Non-dom Dividends and most interest tax-free; income tax up to 35% None; optional €250,000 per 5 years to extend after 17 years 60 days (with conditions) or 183 days 17 years, plus up to 10 Investors and company owners in the EU
Paraguay (Paraguay residency in 2026: temporary, permanent and investor routes) Territorial system Tax on Paraguayan-source income; personal rates 8% to 10% See our guide Not confirmed Ongoing Low-cost base, foreign income
Uruguay (Uruguay residency (2026): nomad ID, permanent route and tax holiday) New-resident tax holiday Foreign capital income taxed as a non-resident would be for 1+10 years (subject to conditions); normal capital rate 12% Conditions apply; one route is property over about USD 2 million Must become Uruguayan tax resident 11 years, then options Investors wanting a stable Latin American base

Two rows changed in 2026. Italy’s Budget Law (Law 199 of 2025) raised the lump sum from €200,000 to €300,000 and the family amount from €25,000 to €50,000 for people moving after 31 December 2025; earlier arrivals keep €100,000 or €200,000. Puerto Rico’s Act 38-2026, signed 12 March 2026, keeps 0% until 2035 for decrees applied for by 31 December 2026 and sets 4% until 2055 for later applicants. Malta’s GRP closes next: from 1 January 2027 the Individual Tax Programme (Legal Notice 195 of 2026) keeps 15% but needs a €35,000 minimum tax and €700,000 property or €14,000 rent, per BDO.

How to choose

1. Start with where your income comes from

  • Foreign investment income (dividends, interest, gains) in the millions: fixed lump sums win once your foreign income is large enough. Italy at €300,000 needs a very large income to beat a normal rate; Greece’s €100,000 breaks even sooner.
  • Active business or salary: lump sums often do not cover local work. Switzerland bars gainful activity in Switzerland. The UK FIG regime excludes foreign employment income. Zero-tax and territorial countries (UAE, Bahamas, Panama, Paraguay), Andorra and Puerto Rico’s 4% export services rate suit people who work.
  • Mostly local work in a high-skill field: Portugal’s IFICI caps qualifying income at 20%.
  • Capital you can leave offshore: Malta’s GRP only taxes foreign income you remit, at 15%, with a €15,000 minimum; unremitted foreign income and capital gains are not taxed.

2. US citizens: most of this table does not apply

The IRS says US citizens abroad are “subject to tax on worldwide income from all sources.” Moving to the UAE or Italy does not switch off US tax; at best you use the foreign earned income exclusion or foreign tax credits. Puerto Rico is different because it is a US territory: bona fide residents who meet the 183-day presence, tax home and closer connection tests generally exclude Puerto Rico-source income from US federal tax. See US expat taxes (2026): filing, FEIE, FBAR and catching up and US dual citizenship (2026): what the US allows, taxes and renunciation. Renouncing is the only full exit, which leads to the next point.

3. Check the exit tax before you leave

Some countries tax you on leaving. For the US, you are a “covered expatriate” if your net worth is $2 million or more, your average annual net income tax for the prior five years exceeds $211,000 (2026 figure; $206,000 for 2025), or you cannot certify five years of compliance. Covered expatriates are taxed as if they sold everything, with a 2026 exclusion of $910,000 ($890,000 for 2025). Several European countries have their own exit taxes. Read Exit tax explained: which countries charge it when you leave.

4. Your company has to move too

A low-tax personal residence does not help if your company stays taxed elsewhere. If you run a company from your new home, that country may treat it as resident there, and EU countries must apply controlled foreign company (CFC) rules to residents who control more than 50% of a low-taxed foreign company. The reverse also matters: a company run from your old high-tax country can stay taxable there. Plan the company location with Best country to incorporate as a digital nomad (2026): 15 options compared.

The tax residency certificate problem in zero-tax places

Moving somewhere with no income tax creates a paperwork problem. Your old country, your bank and treaty partners will ask you to prove you are tax resident somewhere else. A tax residency certificate (TRC) is the usual proof, and zero-tax countries do not always have a tax return to base it on.

  • UAE: the Federal Tax Authority issues TRCs to individuals. You need an Emirates ID and passport with an official entry and exit report showing 183 days, or 90 to 182 days plus UAE work, business or a permanent home, or proof that your main residence and centre of interests are in the UAE. Fees: AED 50 to apply, AED 1,000 for the electronic certificate, AED 250 per hard copy. Each certificate covers up to 12 months, not future periods.
  • Bahamas: there is no personal income tax and no personal tax return. Confirm with a local adviser what evidence your previous country and your banks will accept before you rely on it.
  • Territorial systems (Panama, Paraguay): you are tax resident, but with little or no local tax to pay. Ask early what certificate the authority will issue to someone with only foreign income.

Without a certificate, your former country may argue you never left. That is the real risk for nomads who leave a high-tax country without settling anywhere: see Tax residency explained: why the 183-day rule is a myth for most countries.

Mistakes we see most

  • Comparing headline rates, not your bill. A €100,000 lump sum is expensive for someone with €200,000 of income.
  • Assuming the regime covers work income. Several do not, or bar local work entirely.
  • Missing the application window. Portugal’s IFICI must be claimed by 15 January after the year you become resident; Greece’s non-dom application is due by 30 September (you must be resident by 2 July to start in the same year); Cyprus’s extension window for those deemed domiciled during 2024–2026 closed on 30 June 2026.
  • Forgetting the old country. Residence tie-breakers, exit taxes and CFC rules follow you.

Related guides: Tax-free countries (2026): no income tax countries you can actually live in · Territorial tax countries compared: where foreign income isn’t taxed · Tax residency explained: why the 183-day rule is a myth for most countries · Exit tax explained: which countries charge it when you leave · Best country to incorporate as a digital nomad (2026): 15 options compared

Quick answers

Q: Which country has the lowest tax for high earners in 2026?
The UAE and the Bahamas have no personal income tax. Panama and Paraguay tax only local income. For very large foreign investment income, Greece’s €100,000 and Italy’s €300,000 lump sums cap the bill. The right answer depends on where your income comes from and whether you work locally.

Q: Did Italy’s flat tax go up in 2026?
Yes. The 2026 Budget Law raised the annual lump sum on foreign income from €200,000 to €300,000, and the family member amount from €25,000 to €50,000, for people who move their residence to Italy after 31 December 2025. People who opted in earlier keep €100,000 or €200,000.

Q: Can a US citizen use these regimes to pay no tax?
Mostly no. The IRS taxes US citizens on worldwide income wherever they live. Puerto Rico is the main exception: bona fide residents generally exclude Puerto Rico-source income from US tax, and Act 60 decrees cut local tax on qualifying income. Renouncing citizenship may trigger the US exit tax.

Sources

This is general information from the Nomad Forums team, not legal, tax or financial advice. Rules change; check the official source or a qualified adviser before acting.

Over to you: Which of these regimes have you actually used, and did the real cost (advisers, housing, time on the ground) match the headline? If you moved somewhere with no income tax, how did you prove to your old country and your banks that you had left?

Cross-border tax advisers (2026): types, typical costs and how to vet them