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Tax Residency
Italy's flat tax, Greece's non-dom regime, Portugal's IFICI, Malta, Cyprus, Monaco and Spain's Beckham law, in plain English. Not advice. Checked 31 October 2026.
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Home›Live›Tax Residency Regimes
Italy's flat tax, Greece's non-dom regime, Portugal's IFICI, Malta, Cyprus, Monaco and Spain's Beckham law, in plain English. Not advice. Checked 31 October 2026.
Tax residency
Not advice. This is a plain summary of public rules, checked 31 October 2026. It is not tax, legal, financial or immigration advice. Rules change often, and several changed in 2025 and 2026. Confirm every point with qualified tax and immigration advisers in the United States and in the country concerned before acting.
Several Mediterranean countries offer special tax regimes to wealthy new residents: a fixed annual sum in place of tax on foreign income in Italy and Greece, low flat rates for pensioners, capped tax in Gibraltar, and no income tax at all in Monaco. Each regime is a tax status, not a visa: the right to live in the country comes separately, through the routes on residency and golden visas.
For American families one point overrides the rest: the United States taxes its citizens wherever they live. Read the US tax note before comparing regimes.
Side by side
Scroll sideways on a phone to see every column.
| Country | Regime | Tax | How long | Who qualifies and what changed |
|---|---|---|---|---|
| Italy | Flat tax for new residents (art. 24-bis TUIR) | €300,000 a year on all foreign income, plus €50,000 for each family member | Up to 15 years | Non-resident in Italy for 9 of the last 10 years. Raised from €200,000 for those moving from 1 January 2026; earlier entrants keep their amount. |
| Italy | 7% regime for foreign pensioners (art. 24-ter TUIR) | 7% on all foreign income | 10 tax years | Move to a town of up to 30,000 people in the South (Sicily, Sardinia, Calabria, Campania, Basilicata, Abruzzo, Molise or Puglia); limit raised from 20,000 on 7 April 2026. |
| Portugal | IFICI ("NHR 2.0") | 20% on qualifying Portuguese work income; most foreign income exempt (not pensions) | 10 years | For qualifying research, technology, innovation and highly qualified roles. The old NHR closed to new entrants on 1 January 2024. |
| Spain | Beckham regime (art. 93 LIRPF) | 24% on Spanish work income up to €600,000, 47% above; most foreign income outside Spanish tax | Year of arrival plus 5 years | For those moving to Spain for a job, a directorship, remote work or a qualifying enterprise; not Spanish tax resident in the previous five years. |
| Greece | Non-dom flat tax (art. 5A) | €100,000 a year on all foreign income, plus €20,000 per family member | 15 years | Invest €500,000 in Greece within three years (Golden Visa holders exempt); not Greek resident for 7 of the previous 8 years. |
| Greece | Foreign pensioners (art. 5B) | 7% on all foreign income | 15 years | For those receiving a foreign pension who move their tax residence to Greece. |
| Malta | Global Residence Programme | 15% on foreign income remitted to Malta; minimum tax €15,000 | Until 31 December 2031 for those who apply in time | Open to new applicants only until 31 December 2026. Buy from €275,000 (€220,000 in the South or Gozo) or rent from €9,600 a year. |
| Malta | Global Resident Status (from 1 January 2027) | Minimum tax €35,000 a year | 5 years, renewable | Replaces the Global Residence Programme: buy from €700,000 or rent from €14,000 a year; application fee €8,500. |
| Cyprus | Non-dom status | No Special Defence Contribution on worldwide dividends and interest | 17 of 20 years, extendable | From 1 January 2026, may be extended by up to two further five-year periods for €250,000 each. The 60-day residence rule remains. |
| Monaco | Residence (carte de séjour) | No personal income tax for residents (French nationals excepted) | Cards of 1, 3 or 10 years | Requires a Monaco home and proof of means. Americans first need a French long-stay visa. Monaco has no US tax treaty. |
| Gibraltar | Category 2 (high net worth) | Tax only on the first £118,000 of income: minimum £37,000, maximum £42,380 a year | Indefinite, while conditions are met | Net assets of £5 million for new applicants from 18 June 2026, and an approved home in Gibraltar. |
| France | Impatriate regime (art. 155 B CGI) | Impatriation bonus exempt; 50% exemption on certain foreign passive income | To 31 December of the 8th year after arrival | For employees and directors recruited from abroad who were not French tax resident in the previous five years. |
| Israel | New immigrants (olim) | Foreign income exempt for 10 years | 10 years | Through the Law of Return only. Those becoming resident from 1 January 2026 must now report their worldwide income and assets. |
Spain's Golden Visa closed on 3 April 2025 and Portugal's no longer accepts property; neither affects the tax regimes above. A residence permit alone makes you an ordinary tax resident, usually taxed on worldwide income.
Country by country
The flat tax of €300,000 a year replaces Italian tax on all foreign income, with €50,000 more for each family member who joins; it can last up to 15 years. Italian income is taxed normally. Whether the United States allows a foreign tax credit against the flat sum is a technical question for your adviser. Italy buying guide
IFICI suits those taking up qualifying professional roles rather than retirees; the usual retiree route is the D7 passive-income visa, taxed under ordinary rules. Portugal buying guide
The Beckham regime is for those moving to work. A non-lucrative visa holder becomes an ordinary Spanish tax resident, taxed on worldwide income and liable to regional wealth tax. Spain buying guide
The €100,000 lump sum lasts 15 years and Golden Visa holders are exempt from its separate €500,000 investment test. Greece buying guide
Time-sensitive: the Global Residence Programme closes to new applicants on 31 December 2026; from 1 January 2027 Global Resident Status requires a €700,000 purchase and a €35,000 minimum tax. Malta buying guide
Non-dom status removes the Special Defence Contribution on dividends and interest for 17 of 20 years, now extendable for €250,000 per five-year period. Cyprus buying guide
Residence follows from a Monaco home and proof of means, usually through a Monaco bank. There is no personal income tax, but Americans living in Monaco remain fully taxable in the United States, and there is no US–Monaco tax treaty. Monaco buying guide
Category 2 caps tax at £42,380 a year for those with £5 million of net assets; HEPSS caps tax at about £39,940 for senior executives earning over £160,000. Gibraltar is outside the EU. Gibraltar buying guide
No regime for passive newcomers; the impatriate regime suits executives hired from abroad. French property worth more than €1.3 million is subject to the IFI wealth tax. France buying guide
New immigrants keep a ten-year exemption on foreign income, now with reporting for those arriving from 1 January 2026. Israel buying guide
For Americans
Citizenship-based taxation. US citizens and green-card holders are taxed by the United States on worldwide income wherever they live. A foreign residence permit or flat-tax regime does not end US filing or US tax; only giving up US citizenship does, and that carries its own exit-tax rules.
Foreign tax credit. Foreign income tax can generally be credited against US tax on the same income. A low-tax regime abroad therefore saves less for an American than for others, because income taxed lightly abroad may be topped up to the US rate.
Foreign earned income exclusion. Up to US$132,900 of foreign earned income for tax year 2026, plus a housing deduction (IRS Notice 2026-25). It does not cover pensions, dividends, interest or capital gains.
Reporting. An FBAR for foreign accounts above the threshold and Form 8938 for specified foreign financial assets.
Treaties. The United States has income tax treaties with Portugal, Spain, France, Italy, Malta, Greece, Cyprus, Israel and others, but not with Monaco, and the US–UK treaty is not confirmed to cover Gibraltar. Treaties generally preserve the US right to tax its own citizens.
Sources: IRS, US citizens abroad · IRS, tax treaties A to Z
Before you act
Speak to a US tax adviser and to a tax lawyer in the country you are considering, ideally before you buy a home or move. Timing matters: several regimes depend on years of non-residence before arrival, and Malta's changes on 1 January 2027.
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