Europe’s high‑tax environment has prompted several countries to create special tax regimes that cap, flatten, or even eliminate tax on foreign‑source income for qualifying residents. Seven jurisdictions now offer such programmes, each with its own cost, duration, and eligibility rules.
How the regimes work
- Remittance basis – Foreign income is taxed only when it is physically transferred into the country of residence. Income kept offshore remains untaxed.
- Fixed‑annual lump‑sum – A set fee is paid each year regardless of the amount earned abroad. The fee may be lower than the tax that would otherwise be due on high foreign earnings.
The choice between these models depends on the size of foreign income, family composition, and the length of stay.
Switzerland – Forfait fiscal (expenditure‑based)
- Tax base – Calculated as the highest of: 7 × annual rent, 3 × hotel costs, or a federal minimum of roughly €460 000.
- Minimum annual tax – €250 000 – CHF 1 000 000 (varies by canton).
- Effective rate – Can fall into single‑digit percentages for multi‑million‑euro foreign earnings.
- Duration – No time limit.
- Geographic limitation – Six of the 26 cantons have abolished the regime, restricting where it can be applied.
- Key drawback – The cost floor is the highest among the seven programmes; in popular cantons (e.g., Geneva, Vaud) the practical minimum is considerably higher.
Poland – Lump‑sum regime
| Item | Amount (approx.) |
|---|---|
| Annual lump‑sum (primary applicant) | 200 000 PLN ≈ €47 000 |
| Spouse / dependent child | 100 000 PLN each |
| Mandatory contribution to public projects | 100 000 PLN (science, education, culture, sport) |
- Eligibility – Must hold a tax‑residency certificate from a non‑Polish country covering at least five of the previous six years.
- Standard tax – Progressive rates of 12 % and 32 % plus a 4 % solidarity surcharge above 1 million PLN.
- Benefit – For seven‑figure foreign income, the lump‑sum payment is a small fraction of what ordinary rates would generate.
- Drawbacks – Limited track record and fewer advisory firms specialize in Polish structuring; lifestyle appeal is lower than Mediterranean alternatives.
Italy – Flat‑tax regime
- Fee evolution – €100 000 (2017) → €200 000 (2024) → €300 000 (2026) for new applicants.
- Family surcharge – Additional €50 000 per member.
- Effective tax rate – Roughly 15 %–20 % for a household earning €2 million in foreign income (vs. 43 %+ surcharges under the standard system).
- Benefits – Exemption from Italian wealth tax on foreign assets, no foreign‑asset reporting, and no inheritance/gift tax on offshore holdings.
- Duration – Up to 15 years; earlier entrants are grandfathered at lower fees.
- Additional options – 7 % flat tax for retirees in designated southern municipalities; 50 % income‑tax exemption for qualifying foreign professionals.
Greece – Two non‑dom regimes
| Regime | Investment / Fee | Annual tax | Duration | Family add‑on |
|---|---|---|---|---|
| Investor | Minimum €500 000 in Greek assets (real estate, business, or securities) | €100 000 | 15 years | €20 000 per member |
| Retiree | – | 7 % flat rate on foreign pension, dividends, interest, capital gains | 15 years | – |
- Investor regime – Capital is locked into a tangible asset in a strong tourism market while granting a flat tax on all foreign income.
- Retiree regime – One of the EU’s lowest dedicated pension tax rates; the €100 000 annual fee has remained unchanged since launch.
Ireland – Pure remittance‑based non‑dom
- Taxation – Irish tax only on income earned in Ireland and on foreign income that is physically brought into the country.
- Key features
- No time limit – status continues indefinitely as long as the permanent home remains outside Ireland.
- No annual charge – no fixed fee for non‑dom status.
- No formal application – eligibility is factual, not granted by a government process.
- Domestic rates – Income tax up to 40 %, capital gains tax 33 %, plus USC and PRSI.
- Limitation – The regime is valuable only if foreign income can be kept offshore. The investor immigration programme closed in 2023; EU/EEA/UK citizens can still relocate freely.
Malta – Remittance‑based non‑dom
- Minimum tax – €5 000 per year, applicable only when foreign income exceeds €35 000.
- No domicile rule, sunset clause, or duration limit – Non‑dom status can be held indefinitely.
- Capital gains – Fully exempt from Maltese tax, regardless of domicile, even if remitted.
- Permanent residence for non‑EU nationals
- Administration fee: €60 000
- Government contribution: €37 000
- Property purchase: €375 000 (or annual rent €14 000)
- Practical considerations – Small island size, rising real‑estate prices, and limited health‑care capacity.
Cyprus – Non‑dom with SDC exemption
- Special Defence Contribution (SDC) – Zero SDC on dividends, interest, and capital gains (both Cyprus‑sourced and foreign). From Jan 2026, rental income is also exempt.
- SDC exemption period – 17 years, extendable up to a total of 27 years by paying €250 000 per additional five‑year block.
- Residency test – Minimum 60 days per year in Cyprus, no more than 183 days in any other single country, maintain a permanent residence, and conduct business or hold office in a Cyprus‑resident company.
- Personal income tax – 0 % up to €22 000; 35 % top rate above €72 001.
- Employment income exemption – 50 % exemption on earnings above €55 000 for up to 17 years.
- Permanent residency for non‑EU nationals – €300 000 property investment; citizenship possible after seven years of continuous physical presence.
- Corporate tax – Increased from 12.5 % to 15 % in 2026 to meet the OECD global minimum; individual non‑dom benefits remain unchanged.
Quick comparison
| Country | Model | Minimum annual cost | Max duration | Key advantage |
|---|---|---|---|---|
| Cyprus | Remittance (SDC exemption) | €0 (if foreign income ≤ €22 k) | 17 yr (extendable to 27 yr) | Zero tax on dividends, interest, capital gains, and (from 2026) rental income |
| Malta | Remittance | €5 000 (if foreign income > €35 k) | Unlimited | No tax on foreign capital gains; low entry cost |
| Ireland | Remittance | €0 | Unlimited | No annual fee; tax only on remitted income |
| Greece | Lump‑sum (investor) | €100 000 | 15 yr | Flat tax on all foreign income; investment requirement creates tangible asset |
| Poland | Lump‑sum | 200 000 PLN (~€47 k) | Indefinite | Simple flat fee; mandatory contribution to public projects |
| Italy | Lump‑sum (flat tax) | €300 000 (new applicants) | 15 yr | Exemption from wealth, inheritance, and reporting taxes |
| Switzerland | Expenditure‑based forfait | €250 000 (minimum) | Unlimited | Low effective rate for very high foreign earners; flexible family inclusion |
These seven programmes represent the most established options for high‑net‑worth individuals seeking to minimise tax on foreign income while residing in a high‑tax European country. Eligibility criteria, costs, and the length of the tax benefit vary widely, so prospective applicants should engage qualified tax and immigration advisors to assess which regime aligns best with their financial profile and lifestyle goals.
