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Portugal: A Race Towards Tax Competitiveness – The Non-Habitual Tax Resident Regime

As part of our series addressing favorable tax rules for non-domiciled resident individuals in various countries, Alexandra Courela and Susana A. Duarte of Abreu Advogados in Lisbon explain the Portuguese approach in extending tax benefits to new arrivals holding “Golden Visas” or who otherwise qualify for work-related visas for the performance of designated high value activities. Employment income from services performed in Portugal is taxed at a low rate and foreign source service income may be exempt from tax if certain conditions apply. Foreign-source plain vanilla investment income and gains may be exempt, too.

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What is the Future for New Immigrant Benefits?

Continuing our series on favorable tax rules for non-domiciled resident individuals, Guy Katz and Danielle Halimi of Herzog Fox and Neeman in Tel Aviv explain the Israeli tax benefits for those individuals who are categorized as “New Immigrants.” Benefits begin with a ten-year exemption for foreign-source income and gains – the exemption applies to both tax and information reporting. Regular returning residents receive generous but scaled back benefits. Remittances from abroad are not penalized with tax.

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Spanish Tax Regime for Incoming Professionals

Heard of the “Beckham Law” that limits income tax in Spain for certain non-domiciled individuals? Think of European football (soccer) players. Pablo Alarcón Espinosa of Alarcón-Espinosa, Abogados in Madrid explains how persons migrating to Spain for work purposes can avail themselves of a reduced tax regime for domestic income and an exemption for foreign income and gains. Like Switzerland, remittances from abroad are not penalized with tax.

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The Forfait Tax Regime in Switzerland – A Venerable Alternative

The Swiss forfait tax regime is discussed by Michael Fischer of Froriep in Zurich. The forfait is battle-tested and has beaten back a referendum in 2014 that would have repealed the benefit. Beware – the forfait is not available in all cantons and the minimum tax rate varies widely. In comparison to the U.K. and Ireland, remittances from abroad are not penalized with tax.

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Non-Dom Taxation: Ireland as an Alternative to the U.K.

The benefits and possible pitfall of Ireland’s non-domiciled taxation rules are explained by Lisa Cantillon and Jane Florides of Kennelly Tax Advisers in Dublin. Remittance based taxation remains strong in Ireland, but planning is required to steer clear of deemed remittance traps and to minimize inheritance tax exposure.

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