29 terms you meet when you change countries, in plain words, with the numbers that apply in 2026.
Act 60 (Puerto Rico) · Beckham law (Spain) · Capital gains tax · Category 2 status (Gibraltar) · Citizenship by investment · Cyprus non-dom · Deemed disposal · Double tax treaty · Effective tax rate · Exit tax · FIG regime (UK) · Golden visa (residence by investment) · Greece non-dom flat tax · High Value Residency (Jersey) · HNWI and UHNWI · IFICI (Portugal) · Impatriate regime (France) · Inheritance and estate tax · Italy flat tax (Article 24-bis) · Lump sum taxation (Switzerland) · Malta Global Residence Program · Millionaire migration · Non-dom (UK) · Remittance basis · Spain solidarity tax · Tax residence · Territorial taxation · US expatriation tax · Wealth tax
Source: the Patrician.ch board, an original ranking of 100 residence addresses across 48 countries and territories. Tax rates, thresholds and routes are sourced. Cost, safety, schools, sun and beauty are Patrician.ch editorial indices. Figures current to September 2026. Updated . Cite as: Patrician.ch, Relocation tax glossary 2026: exit tax, non-dom, lump sum, patrician.ch/glossary/, September 2026.
Puerto Rico's incentive code for bona fide residents: 4% on export services income, and 0% on Puerto Rico sourced interest, dividends and post-move gains for a decree applied for by 31 December 2026. A US citizen resident in Puerto Rico owes no federal income tax on Puerto Rico source income.
San Juan for a high earner · Where a US citizen pays the least tax
Spain's regime for inbound hires and remote workers: 24% flat on Spanish employment income up to €600,000, for 6 years. It does not switch off the wealth tax.
Tax on the profit when you sell an asset for more than you paid. It matters most before a liquidity event, since the country you are resident in on the day of the sale usually taxes it. 36 of the 100 addresses on the board levy none on a resident's listed securities.
Countries with no capital gains tax · Where to live before an exit
Gibraltar charges tax on the first £118,000 of income only, so the bill is capped at about £44,740 a year whatever you earn, with a floor of about £37,000.
A passport, not only residence, in exchange for an investment or donation. St Kitts and Nevis has run the oldest program since 1984, Antigua and Barbuda since 2013. Malta's was struck down by the EU Court of Justice in April 2025.
Status for new residents of Cyprus that lasts 17 years: no tax on dividends and interest, no capital gains tax except on Cyprus property, and a 50% exemption on employment income above €55,000. Tax residence can start from 60 days a year.
The legal fiction behind most exit taxes. On the day you leave, you are treated as having sold your assets at market value, and the gain is taxed as if you had.
An agreement between 2 countries that decides which one taxes each kind of income, and gives credit where both do. Its tie-breaker clause settles residence when both claim you.
The share of your whole income that goes in tax, as opposed to the top marginal rate. London's top bracket is 45%, but $1,000,000 earned there works out at an effective 43% on the Patrician.ch model. Every rate on the board is effective, computed on the income entered.
A tax charged when you give up residence, on gains that built up while you lived there but were never sold. Canada, France, Israel, Australia, Germany, the Netherlands, Norway and South Africa all charge one on departure, with deferral rules that differ.
The UK's 4 year relief for new arrivals on foreign income and gains, open to anyone who has not been UK resident in the previous 10 years. It replaced the non-dom remittance basis from 6 April 2025.
Residence granted in exchange for a qualifying investment, usually property, a fund or a business. Several have closed: Spain in April 2025, the Netherlands and Australia in 2024. Monaco, the Cayman Islands and the UAE grant residence against capital without a program by that name.
Golden visas still open in Europe · Residence by investment routes
A flat €100,000 a year on all foreign income for 15 years for new residents of Greece, with a separate 7% flat rate for foreign pensioners.
Jersey's route for wealthy arrivals: 20% on the first £1.25M of worldwide income and 1% on everything above, a minimum tax of £250,000 a year, and a home bought above £3.5M.
A high net worth individual holds at least $1 million in liquid investable assets, not counting a main home. An ultra high net worth individual usually holds $30 million or more. Henley & Partners counts millionaires on the first definition.
The successor to Portugal's NHR regime. Qualifying new residents pay a 20% flat rate for 10 years. NHR itself closed to new applicants from 2024.
France exempts 30% of employment income for up to 8 years for people hired from abroad. France's wealth tax reaches property only, above €1.3M.
Tax on what passes at death. An estate tax charges the estate as a whole, as the US does. An inheritance tax charges each heir on their share, usually at a lower rate for a spouse and children. 28 of the 48 countries and territories on the board levy none.
A fixed annual tax on all foreign income for new residents of Italy, whatever its size: €300,000 a year for anyone who becomes resident from 1 January 2026, plus €50,000 per family member, for up to 15 years. Earlier entrants keep the €100,000 or €200,000 rate they joined on.
Swiss tax on a deemed spending base instead of income, for foreigners who live in Switzerland but do not work there. The base is at least 7 times the rent or rental value of the home, with a federal floor around CHF 435,000 for 2026 and cantonal minimums on top. Zurich no longer offers it.
Swiss lump sum vs Italy's flat tax · Switzerland for high earners
Malta taxes non-domiciled residents only on income they bring into Malta, at 15% under the Global Residence Program.
Henley & Partners' estimate of how many millionaires move in or out of each country in a year, net. It is a country figure, never a city one. In 2025 the UAE drew the largest net inflow on the board, +9,800, and the UK saw the largest outflow, −16,500.
The UK status that let residents with a foreign domicile keep foreign income and gains out of UK tax unless they brought the money in. It ended on 6 April 2025. Its replacement is residence based: new arrivals get 4 years of relief on foreign income and gains, and UK inheritance tax now follows 10 years of residence.
Where UK non-doms are moving · Non-dom regimes in Europe, compared
Taxing foreign income only when it is brought into the country. Malta and Mauritius work this way. Thailand has taxed foreign income remitted by residents of 180 days or more since 1 January 2024.
Spain's national tax on net wealth above €3M, at 1.7%, 2.1%, and 3.5% above €10.7M. It credits the regional wealth tax paid, so it bites hardest where the region waives its own, as Madrid and Andalusia do.
The country entitled to tax you on your worldwide income. Most countries treat you as resident once you spend 183 days there in a tax year, and many also weigh where your home, family and business interests sit. Where 2 countries both claim you, the tie-breaker clause of the tax treaty between them usually decides.
A system that taxes only income earned inside the country, so foreign income goes untaxed. Panama and the Dominican Republic work this way, and Uruguay offers it to new residents for 11 years by election.
Panama City for a high earner · Punta del Este for a high earner
Leaving the US changes nothing for a citizen, since the US taxes citizens wherever they live. Renouncing citizenship, or giving up a long term green card, triggers a deemed sale of everything at 23.8% on gains above the annual exclusion.
An annual tax on net assets, charged whether or not they produce income. 24 of the 100 addresses on the board carry one, the Swiss cantons and Spain among them. Swiss rates are low, Zug about 0.22% at the top. Spain's reach 3.5%.
The engine takes what you earn and what you hold, then orders every address on the board against it.
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The general case, ranked: Where should high earners live in 2026 · Best country to live in if you are rich · Best countries for high earners after tax · Europe · United States
Tax figures use a simplified marginal model with indicative 2026 brackets for a non-US single filer, ignore social contributions, most deductions, wealth taxes, and treaties, and are not advice. Residence rules change often. Verify before acting.