Video Briefing

Offshore Citizen: Tax Expert Reacts: International Tax Competitiveness Index

Nov 5, 2022Video Briefing11:21Watch on YouTube

The 2022 International Tax Competitiveness Index (ITCI) ranks 38 jurisdictions on a range of tax‑related criteria, offering a snapshot of how attractive each country is for corporate and personal tax planning. While the index provides a useful starting point, its methodology and coverage leave out many jurisdictions that are widely regarded as tax‑efficient, and the rankings can be misleading for both newcomers and established residents.

How the index is built

  • Overall score – aggregates performance across all categories.
  • Corporate tax rank – focuses on statutory rates, effective rates, and incentives.
  • Individual tax rank – looks at personal income‑tax rates, allowances, and residency rules.
  • Consumption tax rank – evaluates VAT/GST rates.
  • Property tax rank – assesses taxes on real‑estate holdings.
  • Cross‑border tax rank – measures the ease of moving income and assets across jurisdictions.

Research cited in the discussion suggests that, for relocation decisions, corporate tax matters most, followed by personal tax, while consumption and property taxes have comparatively little impact.

Ranking highlights

Position Country Score
1 Estonia 100
2 Latvia 89.9
3 New Zealand
4 Switzerland
5 Czech Republic
33 France lowest
34 Italy second‑lowest
35 Portugal third‑lowest
36 Ireland fourth‑lowest
37 Spain fifth‑lowest
38 Denmark sixth‑lowest

Key observations

  • Estonia tops the list and is praised for a straightforward corporate tax regime.
  • Latvia, despite a similar tax structure, is deemed less favorable due to administrative quirks.
  • Many jurisdictions traditionally viewed as tax‑friendly—Singapore, Hong Kong, Malaysia, United Arab Emirates—are absent from the list, which can inflate the relative standing of the included countries.
  • The bottom‑ranked European nations (France, Italy, Portugal, Ireland, Spain, Denmark) are flagged as high‑tax environments, though each offers specific incentives that can alter the picture for certain residents.

Why the list can be misleading

  1. Exclusion of zero‑tax havens – Caribbean jurisdictions with no corporate or personal taxes are omitted, skewing the comparative landscape.
  2. Newcomer vs. existing resident effects – Countries like Portugal and Italy provide substantial tax breaks (e.g., Portugal’s Non‑Habitual Resident regime, Italy’s reduced rates for pensioners and newcomers) that are not reflected in the generic scores.
  3. Policy volatility – Recent tax law changes can quickly shift a country’s competitiveness, making static rankings outdated.

Recent tax‑policy updates affecting the rankings

  • Czech Republic – Personal income‑tax top rate rose from 15 % to 27 %, lowering its competitiveness.
  • France – Corporate income‑tax rate fell from 28.41 % to 25.83 % after a multi‑year reduction program, though the overall tax system remains complex.
  • Ireland – Interest‑deduction limit introduced (30 % of earnings before interest, depreciation, amortisation) with an exemption for borrowing under €3 million, reducing its attractiveness.
  • Italy – Patent‑box regime repealed; replaced by a 110 % super‑deduction for R&D spending.
  • New Zealand – Top personal tax rate increased from 33 % to 39 %, diminishing its appeal despite a four‑year foreign‑income exemption for newcomers.
  • Turkey – Corporate tax rate cut from 25 % to 23 %; however, the jurisdiction is rarely chosen for company formation.
  • United Kingdom – Temporary 130 % super‑deduction for plant and equipment introduced; corporate tax rate has been rising, and stamp‑duty reforms add cost considerations.

Practical guidance for tax‑optimization decisions

  • Prioritize corporate‑tax environments when relocating a business; Estonia and the United Kingdom (subject to specific circumstances) remain among the more competitive options in the list.
  • Assess residency incentives – Portugal’s NHR, Italy’s reduced rates for pensioners, and Ireland’s non‑dom regime can dramatically alter personal tax exposure.
  • Monitor policy changes – Recent rate hikes in New Zealand and the Czech Republic illustrate how quickly a jurisdiction can become less attractive.
  • Look beyond the index – Jurisdictions not covered (e.g., Singapore, Hong Kong, UAE) often provide superior tax regimes and should be evaluated alongside the ITCI results.
  • Consider the full tax picture – Consumption and property taxes have limited influence on relocation decisions, but cross‑border rules and the ability to repatriate profits can be decisive for multinational operations.

In summary, the 2022 International Tax Competitiveness Index offers a structured view of tax environments but should be used with caution. Decision‑makers need to factor in specific residency programs, recent legislative shifts, and the omission of several low‑tax jurisdictions before drawing conclusions about where to locate a business or personal residence.