Tax Regimes by Jurisdiction
What each jurisdiction's published tax regime looks like on its own terms — headline corporate and personal rates, territorial or exempt treatment, capital-gains and wealth taxes, new-resident regimes, and substance and Pillar Two status.
Short answer
Each jurisdiction publishes its own headline corporate and personal rates, its treatment of capital gains and of wealth or inheritance, any special regime for new residents, and its position on economic substance, Pillar Two, and treaty coverage. This matrix records those published terms per jurisdiction, cited to that jurisdiction's official source, and leaves unconfirmed fields visibly unconfirmed rather than filling them from secondary summaries.
The matrix
| State | Cit Headline | Cit Territorial Or Exempt Regime | Pit Top Rate | Capital Gains Treatment | Wealth Inheritance Tax | New Resident Special Regime | New Resident Regime Threshold Or Fee | Economic Substance Rules | Pillar Two Status | Treaty Network Size | Fatf Oecd Eu Listing |
|---|---|---|---|---|---|---|---|---|---|---|---|
| Cook Islandschecked 2026-09-13 | Resident company: 20%. Non-resident company: 28%. | The International Companies Act 1981-82 s.250 exemption for international companies was REPEALED, and s.249 replaced, by the International Companies (Removal of Tax Exemption) Amendment Act 2019 (No. 12). New s.249(1) bars any Cook Islands enactment (other than a fixed list of Acts) from imposing liability/duty/tax/fine or requiring filings/registration on an international or foreign company; new s.249(2) expressly carves the Income Tax Act 1997 and Value Added Tax Act 1997 (along with the Banking Act 2011, Countering Terrorism and Proliferation of WMD Act 2004, Crimes Act 1969, Criminal Procedure Act 1980-81, Customs Revenue and Border Protection Act 2012, Customs Tariff Act 2012, Departure Tax Act 2012, Extradition Act 2003, Financial Intelligence Unit Act 2015, Financial Supervisory Commission Act 2003, Financial Transactions Reporting Act 2017, Mutual Assistance in Criminal Matters Act 2003, Proceeds of Crime Act 2003, Shipping Act 1998, Trustee Companies Act 2014) OUT of that shield -- meaning the Income Tax Act and VAT Act now DO apply to international/foreign companies. Transitional provision (s.7): immediate effect for companies incorporated/registered on or after the 2019 Act's commencement; for companies incorporated/registered BEFORE commencement, the old ss.243/249/250 continue to apply until the close of 31 December 2021 (a ~2-year grandfather window); from 1 January 2022 the new sections apply to ALL international and foreign companies. This fully confirms and upgrades the prior pass's reconciliation finding, which had been carried at typed_unknown pending independent verification. ADDITIONAL CONTEXT (moderate confidence -- see note): the 2019 Act's own text amends ONLY the International Companies Act 1981-82 (s.3: 'This Act amends the International Companies Act 1981-82 (the principal Act)'); it does not touch the International Trusts Act 1984 or the Limited Liability Companies Act 2008. Direct review of those two Acts found each still contains its own parallel general tax-shield clause -- LLC Act 2008 s.76(1) (First Schedule of Acts-that-apply does NOT include the Income Tax Act 1997) and International Trusts Act 1984 s.27B(1)(a)(ii) -- and neither Act appears to have been amended since 2013 per the Parliament's own current Acts Library, so both appear to retain their exemption, unaffected by the 2019 reform. | 30% (on income over $80,001; tax-free threshold $11,000; intermediate progressive bands), consistent across the guide's tabulated tax years from 2014 through the most recent year shown (2018). | Unverified (no primary source yet) | No wealth tax and no inheritance/estate/gift tax identified. Two primary texts were checked: (1) The Stamp Duties Act [1971-72, No. 7] -- fetched fresh this session directly from the Cook Islands Parliament's own Acts Library and OCR'd in full (26 pages) -- AFFIRMATIVELY EXCLUDES wills and testamentary dispositions from its scope in its own interpretation section, and has zero occurrences of 'death', 'succession', 'probate', 'inherit', 'deceased', or 'gift' anywhere in the text; its few 'estate' occurrences are all in the property-law sense ('estate or interest in land/property'), not a decedent's estate. (2) The consolidated Income Tax Act 1997 (same text/currency caveat as capital_gains_treatment) has zero occurrences of 'inheritance', 'gift duty', 'death duty', 'succession', or 'wealth tax'; its only 'estate'-adjacent provisions (ss.77-79, 'Income Derived by Trustees') tax ordinary INCOME received by/for a deceased person's estate under normal income-tax continuity rules, not the estate's capital value. Separately, the Cook Islands Parliament's own current Acts Library (a full listing of current CI legislation, reviewed for title matches through at least mid-2026) contains no 'Estate Duty Act', 'Death Duty Act', 'Succession Duty Act', or 'Wealth Tax Act' -- its only 'wealth'-titled instrument is the unrelated Cook Islands Sovereign Wealth Fund Act 2026 (a government investment-fund vehicle, not a tax on private wealth). | Unverified (no primary source yet) | Not yet researched | Unverified (no primary source yet) | Unverified (no primary source yet) | Unverified (no primary source yet) | Not listed — absent from both the FATF grey list and black list as of the 19 June 2026 update. Not listed — absent from both Annex I and Annex II per the 17 February 2026 EU Council update. |
| St. Kitts & Nevischecked 2026-09-13 | 33% on resident companies (Income Tax Act, Cap. 20.22, s.32(1)(b): 'corporation tax of 33% in respect of income (i) earned in 2013 and assessed in 2014; and (ii) earned thereafter in subsequent years' -- Substituted by Act 5 of 2013). Confirmed against the Law Commission of Saint Christopher and Nevis's own current consolidated revision (printed revision date 31 Dec 2017). | St Kitts and Nevis operates a worldwide (not territorial) basis of company taxation, not a ring-fenced exempt/offshore regime. Income Tax Act (Cap. 20.22) s.3(1) charges tax on 'the income of any person accruing in or derived from the State or elsewhere and whether received in the State or not.' Section 3(3) (inserted by Act 14 of 1980) removed every person other than a company from this charge, effective 1 May 1980, so in current effect s.3 taxes only companies -- on a worldwide basis -- at the 33% corporation-tax rate (s.32(1)(b), substituted by Act 5 of 2013). Non-resident persons without local presence are reached only through an agency/withholding mechanism on Federation-source income (ss.15, 25), not the full worldwide charge. A historical ring-fenced exempt/offshore regime did exist for Companies Act companies, Nevis Business Corporations, and Nevis LLCs incorporated before the relevant 2018/2019 cut-off dates; the OECD Forum on Harmful Tax Practices' consolidated peer review (update as of July 2026) classifies all three as 'Abolished,' with grandfathering ending 30 June 2021 -- so no exempt/offshore company regime remains available as of this review. Consistent with that, St Kitts and Nevis does not appear on the EU list of non-cooperative jurisdictions (Annex I) or its associated commitments watchlist (Annex II) as of the 17 February 2026 update. | 0% -- St Kitts and Nevis levies no personal income tax. Income Tax Act (Cap. 20.22) s.3(3) (inserted by Act 14 of 1980) provides: 'This section shall not apply to income which accrues on or after 1st May, 1980 to any person (other than a company) liable under this section.' Section 3 ('Charge of income tax') is the Act's sole charging provision, so this carve-out removes all individuals (and other non-company persons) from the income-tax charge entirely, from 1 May 1980 onward. The graduated individual rate schedule still printed at s.32(1)(a) (rates from nil up to 55%, substituted by Act 13 of 1976) predates the 1980 carve-out, is superseded in effect by it, and is not applied in practice -- it survives in the printed consolidation only because s.32(1)(a) itself was never separately repealed/renumbered, not because it is live law. | No general capital gains tax. For individuals, all gains are outside the Income Tax Act's charge in any event, since s.3(3) (Act 14 of 1980) excludes non-company persons from the Act's sole charging section from 1 May 1980 onward (see pit_top_rate). For companies, s.3(2) (inserted by Act 5 of 1972) taxes only a narrow category: a gain 'of a capital nature...' that 'derives from a transaction relating to assets which are disposed of within one year of the date of acquisition of such assets' is taxed at one-half the rate that would otherwise apply, capped at a maximum of 20% -- in practice, half of the 33% corporation-tax rate (16.5%), which is below the 20% cap. Gains on assets a company has held for more than one year before disposal fall outside s.3 altogether and are not taxed. | Not yet researched | None. St Kitts and Nevis has no personal income tax at all: Income Tax Act s.3(3) (inserted by Act 14 of 1980) excludes every person other than a company from the Act's charging section from 1 May 1980 onward (see pit_top_rate). Because there is no general individual income-tax base to begin with, there is no separate preferential income-tax regime for new residents, returning citizens, or Citizenship-by-Investment (CBI) participants layered on top of it. The CBI programme itself is an immigration/investment framework, not a tax regime, and is out of scope for this cell. | Not applicable -- see new_resident_special_regime: there is no distinct new-resident income-tax regime for a threshold or fee to attach to. | St Kitts and Nevis does not maintain a standalone economic-substance/CIGA statute of the BVI or Cayman type. Neither the Income Tax Act (Cap. 20.22, 2017 consolidation) nor the Companies Act (Cap. 21.03, 2020 consolidation, which already incorporates the 2018 and 2019 amending Acts) contains 'economic substance,' 'relevant activities,' or core-income-generating-activity language anywhere in their text (checked in full; the Companies Act's only hit for 'substance' is the unrelated phrase 'substance of the prospectus'). The OECD Forum on Harmful Tax Practices' consolidated peer review of preferential regimes -- the mechanism that otherwise drives economic-substance legislation in no-or-nominal-tax jurisdictions -- lists SKN's three historical offshore-style regimes (Companies Act companies, Nevis Business Corporations, Nevis LLCs) as 'Abolished' rather than 'in place, substance requirements apply,' with grandfathering ending 30 June 2021: since 1 July 2021 these entities are folded into the ordinary 33% worldwide company-tax base (Income Tax Act s.3/s.32(1)(b)) rather than a preferential regime, removing the ring-fenced/zero-tax profit-shifting concern that the OECD/EU substantial-activities framework targets in the first place. Consistent with this, St Kitts and Nevis does not appear on the EU list of non-cooperative jurisdictions (Annex I) or its commitments watchlist (Annex II) as of the 17 February 2026 update, so the EU records no outstanding economic-substance (or other) commitment against this jurisdiction. One narrow exception flagged by secondary sources but NOT independently verified against primary text this pass: SKN's virtual-asset-service-provider (VASP) regulatory framework is reported to carry its own substance-style local-presence conditions -- a niche sectoral rule, not a general economic-substance act. | St Kitts and Nevis is a member of the OECD/G20 Inclusive Framework on BEPS -- listed as '117. Saint Kitts and Nevis' in the OECD's own composition list (updated 5 December 2025) -- and is among the Inclusive Framework members that joined the October 2021 'Statement...on the Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy' -- listed as '109. Saint Kitts and Nevis' in that statement's own member list -- i.e. SKN has politically committed to the Pillar One/Pillar Two framework. No SKN domestic Pillar Two implementing legislation (a Qualified Domestic Minimum Top-up Tax, Income Inclusion Rule, or Undertaxed Profits Rule) was found in the two Federation statutes reviewed in full this pass (Income Tax Act Cap. 20.22, 2017 consolidation; Companies Act Cap. 21.03, 2020 consolidation). This is consistent with Pillar Two's EUR 750m in-scope-group revenue threshold being unlikely to bind any SKN-headquartered multinational group, and with SKN not being among the (mostly larger-IFC) jurisdictions that have adopted a QDMTT. | UNION of two independently-confirmed primary findings, per cell-encoding ruling (c) (both-partial findings unify with both pinpoints): (1) SKN is party to the multilateral CARICOM Agreement for the Avoidance of Double Taxation -- signed 6 July 1994, ratified by St Kitts/Nevis 8 May 1997, in force since 30 November 1994, covering Antigua, Belize, Dominica, Grenada, Guyana, Jamaica, St Kitts/Nevis, Saint Lucia, St Vincent and Trinidad & Tobago (10 member states total, including SKN itself). (2) SKN's Inland Revenue Department 'Tax Treaties' page separately lists at least 10 bilateral double-taxation-relief Orders: Canada, Denmark, Monaco, New Zealand, Norway, San Marino, Sweden, Switzerland, United Kingdom, USA -- each made under the Avoidance of Double Taxation and Prevention of Fiscal Evasion Agreement Act, Chap 25. Total network: 1 multilateral instrument (9 co-signatories) + at least 10 bilateral DTAs, both primary-confirmed. | Not on either FATF list as of the 19 June 2026 list-publication cycle. Not on the EU's non-cooperative jurisdictions list as of the 17 Feb 2026 update (historical note: SKN was briefly added to Annex I on 2018-03-13 and removed 2018-05-25). |
| Liechtensteinchecked 2026-09-13 | Flat 12.5% corporate income tax (Ertragssteuer) on taxable net profit (Art. 61 SteG), plus a minimum income tax (Mindestertragssteuer) of CHF 1,800 owed regardless of profit and fully creditable against the Ertragssteuer (Art. 62(1)-(2) SteG). Small commercially-run enterprises whose average balance-sheet total over the preceding three financial years does not exceed CHF 500,000 are exempt from the minimum tax (Art. 62(3) SteG). | Liechtenstein taxes resident legal entities (seat or place of effective management in Liechtenstein) on worldwide net profit at the flat 12.5% Ertragssteuer (Art. 44, Art. 61 SteG) -- not a broad territorial system. Several exempt/preferential features apply instead: (1) Privatvermögensstrukturen (PVS, private asset-holding structures meeting the passive-holding / no-solicitation / no-control conditions of Art. 64(1)-(3) SteG) are subject exclusively to the CHF 1,800 minimum tax and are not otherwise assessed (Art. 64(8) SteG); (2) a notional interest deduction on modified equity (Eigenkapital-Zinsabzug), computed using the same 4% standardized-yield rate used for the personal wealth-tax base, is deductible against Ertragssteuer (Art. 54 SteG, referencing Art. 5 SteG); (3) qualifying participation dividends and capital gains/liquidation proceeds from shareholdings in other legal entities are tax-exempt for corporate taxpayers, subject to anti-abuse conditions (Art. 48(3)-(6) SteG, cross-referenced at Art. 15(2)(n)-(o) SteG); (4) a former IP-box / licence-box regime (previously Art. 53 SteG) was repealed by LGBl. 2018 Nr. 147 and no longer exists. | The national tax (Landessteuer) on combined wealth-and-acquisitions ('Vermögens- und Erwerbssteuer') is progressive from 1% to a top marginal rate of 8% on taxable acquisitions above CHF 211,401 for a standard taxpayer (Art. 19(1)(a) SteG: '0.08·x - 6,448' for x ≥ CHF 211,401; slightly different brackets/thresholds apply for single parents and jointly-assessed spouses under Art. 19(1)(b)-(c)). Municipalities additionally levy a Gemeindezuschlag (municipal surcharge), set annually by each municipal council as a percentage of the Landessteuer amount, which by law must fall between 150% and 250% of that amount (Art. 75(3) SteG). Combining the two, the top combined marginal rate mechanically ranges from about 20% (8% national x 2.5, lowest-surcharge municipality) to about 28% (8% x 3.5, highest-surcharge municipality) -- this combined range is this session's own arithmetic from the two cited provisions, not itself a single figure stated in the text. | Capital gains from disposal of components of movable and (non-Liechtenstein) immovable PRIVATE assets -- e.g. privately-held shares -- are excluded from taxable 'Erwerb' and so are not taxed (Art. 15(2)(m) SteG covers movable and immovable private assets generally; Art. 15(2)(l) separately excludes capital gains from disposal of FOREIGN real estate). Gains on disposal of Liechtenstein-situated real estate are instead taxed separately under the dedicated Grundstücksgewinnsteuer (real estate capital gains tax, Arts. 35-43 SteG): the Art. 19(a) income-tax tariff is applied to the gain, with a flat 200% municipal surcharge substituted for the ordinary variable 150%-250% Gemeindezuschlag (Art. 42-43 SteG). For business assets (Geschäftsvermögen), gains are generally taxable as ordinary Ertragssteuer business income, though qualifying participation gains benefit from the Art. 48(3)-(6) exemption described under cit_territorial_or_exempt_regime. | Liechtenstein has no standalone annual net-wealth tax bill. Net taxable wealth instead generates a standardized notional yield (Sollertrag) fixed by law at 4% per year (Art. 5(1) SteG), which is added to the taxpayer's taxable 'Erwerb' (via Art. 6(5)(g) / Art. 14(2)(l) SteG) and taxed jointly at the same progressive national tariff (Art. 19 SteG, 1%-8%) plus the municipal surcharge (Art. 75, 150%-250%) described under pit_top_rate -- i.e. wealth is taxed through the income-tax mechanism, not a separate wealth-tax bill. On inheritance/gift tax: Art. 15(2)(c) SteG affirmatively excludes 'einmalige Vermögensanfälle in Form von Erbschaften, Vermächtnissen und Schenkungen' (one-off wealth accruals in the form of inheritances, legacies, and gifts) from taxable Erwerb, and Art. 1 SteG's exhaustive list of taxes levied under this Act (wealth-and-acquisitions tax, lump-sum tax, real estate gains tax, corporate income tax, formation levy/insurance premium duty, plus the reserved GloBE top-up tax) does not include any inheritance or gift tax -- confirming no current Liechtenstein inheritance or gift tax on the recipient. | Pauschalbesteuerung / Besteuerung nach dem Aufwand (expenditure-based lump-sum taxation), codified at Arts. 30-34 SteG. Available on application to a person taking up residence or habitual abode in Liechtenstein for the first time, or after at least 10 years' absence from the country, who does not hold Liechtenstein citizenship, does not engage in gainful employment domestically, and lives from the yield of their own assets or other amounts received from abroad (Art. 30(1) SteG). If granted, this substitutes for the ordinary Vermögens- und Erwerbssteuer; Liechtenstein-situated real property remains subject to the ordinary Vermögenssteuer regardless (Art. 30(3)). The Tax Administration (Steuerverwaltung) reviews and decides each application (Art. 31); the assessment base is the applicant's total annual living expenditure (Art. 32); the tax equals 25% of that expenditure base (Art. 33). | Unverified (no primary source yet) | Unverified (no primary source yet) | Liechtenstein enacted the GloBE-Gesetz (Gesetz vom 10. November 2023 über die Mindestbesteuerung grosser Unternehmensgruppen, LGBl. 2023 Nr. 484, systematic no. 640.2), implementing the OECD/G20 Inclusive Framework's Pillar Two GloBE Model Rules (as of 14 December 2021) via three domestic top-up taxes on Liechtenstein business units: a Qualified Domestic Minimum Top-up Tax (liechtensteinische Ergänzungssteuer / QDMTT), an Income Inclusion Rule top-up tax (IIR-Ergänzungssteuer), and an Undertaxed Payments Rule top-up tax (UTPR-Ergänzungssteuer) (Art. 1). The minimum rate for all three is 15% (Art. 5(3) for the QDMTT; Art. 8(2) for IIR/UTPR). All three apply to constituent entities of MNE groups (or large purely-domestic groups) whose ultimate parent's consolidated-group revenue reached EUR 750 million in at least 2 of the preceding 4 fiscal years (Art. 4(1) for QDMTT; Art. 7(1)-(2) for IIR/UTPR). The Act entered into force 1 January 2024 and applies from fiscal years beginning on or after 1 January 2024 for the QDMTT (Art. 31(1)), though the government may defer first application to 1 January 2025 by ordinance; the UTPR's first-application date is set separately by the government, no earlier than fiscal years beginning on or after 1 January 2025 (Art. 31(2)). A 5-year transitional safe harbour reduces the Liechtenstein and IIR top-up taxes to zero for MNE groups in the first 5 years of their international activity, and for large domestic groups in their first 5 years within scope (Art. 5(4); Art. 8(3)). | Per the Liechtenstein Tax Administration's (Steuerverwaltung) own current double-taxation-agreement overview (dated 21 July 2026): 32 double taxation agreements (DBA) are listed by name, of which 26 are currently IN FORCE (Andorra, Germany, Estonia, Georgia, Guernsey, Hong Kong, Iceland, Jersey, Croatia, Latvia, Lithuania, Luxembourg, Malta, Monaco, Montenegro, Netherlands, Austria, Romania, San Marino, Switzerland, Singapore, Czech Republic, Hungary, Uruguay, UAE, and the United Kingdom); the remaining 6 are signed or initialled but not yet in force (Bahrain and the Philippines and Vietnam -- initialled only; Belgium, Ireland, and Italy -- signed, awaiting entry into force). Separately, the same document lists 37 tax-information-exchange instruments: bilateral Tax Information Exchange Agreements (TIEAs) with roughly 19 jurisdictions (including the US, UK, Germany, France, Japan, Canada, and others), plus multilateral instruments -- the Multilateral Convention on Mutual Administrative Assistance in Tax Matters (MAK), the CRS Multilateral Competent Authority Agreement (automatic exchange of financial-account information), the Country-by-Country Reporting MCAA, the GloBE Information Return MCAA (in force from 1 January 2026), the CARF MCAA (crypto-asset reporting), a FATCA agreement with the United States, and the Liechtenstein-EU automatic-information-exchange agreement. | Not on the EU list of non-cooperative jurisdictions for tax purposes as of the 17 February 2026 update (current Annex I: 10 jurisdictions; current Annex II: 9 jurisdictions; Liechtenstein appears in neither). Liechtenstein DOES appear, historically, in this same compiled document's cumulative record of past updates, including an explicit 'REMOVED FROM ANNEX II: Liechtenstein and Peru' entry from an earlier review cycle -- i.e. Liechtenstein was previously EU-greylisted (Annex II) and was subsequently removed; it is not currently listed. Not found in the FATF increased-monitoring ('grey list') document (13 February 2026 update) at all -- zero mentions. |
| Cypruschecked 2026-09-13 | Corporate income tax (CIT) rate is 15%, increased from 12.5%, applicable for tax/accounting periods commencing on or after 1 January 2026, under the Income Tax Law of 2002 (N.118(I)/2002) as amended by the 2025 reform package. | Not a formal territorial system -- Cyprus tax residents remain taxable in principle on worldwide income -- but two broad Income Tax Law exemptions make the effective base narrow for holding/investment structures: (a) dividend income is generally exempt from Income Tax (Art. 8(20), N.118(I)/2002), denied only to the extent the dividend was tax-deductible for the paying company abroad (anti-hybrid-mismatch carve-out); dividends instead fall only within Special Defence Contribution, from which non-domiciled tax residents and non-residents are exempt (see new_resident_special_regime); (b) profit from disposal of securities (shares, bonds and other titloi) is exempt from Income Tax outright (Art. 8(22)), regardless of trading/capital classification, and separately falls outside the Capital Gains Tax Law's scope unless the securities are themselves Cyprus-immovable-property-rich shares (see capital_gains_treatment). | Top personal income tax marginal rate is 35%, applying to taxable income above EUR 72,000 (widened from EUR 60,000 pre-reform). Full personal income tax band structure for tax year 2026 onward (N.118(I)/2002 as amended): 0% up to EUR 22,000; 20% on EUR 22,000-32,000; 25% on EUR 32,000-42,000; 30% on EUR 42,000-72,000; 35% above EUR 72,000. (Prior structure, tax years 2008-2025: 0% to EUR 19,500; 20% to EUR 28,000; 25% to EUR 36,300; 30% to EUR 60,000; 35% above EUR 60,000 -- the 35% top rate itself is unchanged by the reform; only the band thresholds were widened.) | Capital Gains Tax (CGT) is charged at a flat 20% rate on gains from disposal of 'property' as defined in the Capital Gains Tax Law of 1980 (N.52/1980), Art.4. 'Property' (Art.2) means: Cyprus-situated immovable property; shares in a company that directly holds Cyprus immovable property (any percentage); and shares in a company that indirectly holds Cyprus immovable property (through other companies) where at least 20% of the shares' market value derives from that property -- this indirect-holding threshold was lowered from 50% by the 2026 reform (N.242(I)/2025, effective 1 January 2026); a double-tax-treaty override can still apply a 50% threshold where the relevant treaty allocates Cyprus taxing rights only above that level. Lifetime exemption amounts, revised effective 1 January 2026 (Art.5, with a top-up mechanism for individuals who had already used part of the pre-2026 allowance): general exemption EUR 30,000 (up from EUR 17,086); disposal of agricultural land by a farmer EUR 50,000 (up from EUR 25,629); disposal of a principal private residence (5+ years owner-occupation, land area capped at one and a half donums) EUR 150,000 (up from EUR 85,430, with amounts above the exemption taxed only on the excess). Ordinary securities not deriving value from Cyprus immovable property fall outside CGT's scope entirely and are also exempt from Income Tax on disposal (Income Tax Law Art.8(22)); shares listed on a regulated market of a recognised stock exchange are CGT-exempt without limit, and shares on a non-regulated market of a recognised exchange are CGT-exempt up to cumulative disposals of EUR 50,000 per year. | No wealth tax: Cyprus has never enacted a general net-wealth tax; no such statute appears in the closed set of direct-tax laws cross-referenced by Cyprus's own tax legislation (Income Tax Law, Special Defence Contribution Law, Capital Gains Tax Law, the now-abolished Immovable Property Tax Law, and VAT Law). No estate or inheritance duty: the Property of Deceased Persons (Tax Provisions) Law of 2000 (N.78(I)/2000), which governs the tax treatment of a deceased person's estate for deaths on or after 1 January 2000, exhaustively defines the 'taxes' that bind a deceased's estate and legal representatives as: Income Tax, the (lapsed) temporary Special Contribution, Special Defence Contribution, Immovable Property Tax, Capital Gains Tax, and VAT -- no estate or inheritance duty appears in that list, and the Law itself imposes no separate death-triggered charge; it only continues the deceased's own pre-existing tax liabilities against the estate. (Separately, and not independently re-verified against primary text this pass: Cyprus is also widely reported, via convergent secondary/professional sourcing only, to levy no general gift tax on cash gifts between individuals.) | Non-domiciled ('non-dom') tax-resident regime: an individual who is Cyprus tax resident under the ordinary 183-day or 60-day tests but does not have a Cyprus 'domicile' (broadly: domicile of origin outside Cyprus, or Cyprus domicile of origin displaced by 20+ consecutive years of a foreign domicile of choice, subject to statutory exceptions) is exempt from Special Defence Contribution (SDC) on dividend income, interest income, and (from 1 January 2026, for all persons regardless of domicile) rental income. An individual is deemed to acquire a Cyprus domicile -- and so loses non-dom status -- once Cyprus tax resident for at least 17 of the preceding 20 tax years; that deemed domicile then persists until 20 years (not necessarily consecutive) of subsequent non-residence have accrued. The exemption covers SDC only -- it does not exempt Cyprus income tax on employment/business income, nor Capital Gains Tax on Cyprus immovable property. | Individuals who have acquired a deemed Cyprus domicile solely via the 17-out-of-20-years rule (i.e. not domiciled of origin/choice in Cyprus) may elect, under new Article 3D of the Special Defence Contribution Law (N.117(I)/2002, inserted by the SDC (Amendment)(No.4) Law of 2025, effective 1 January 2026), to extend their SDC exemption on dividend/interest income for up to two further consecutive 5-year periods (maximum 17 + 5 + 5 = 27 years total non-dom protection), by making an irrevocable election and paying a flat EUR 250,000 for each full 5-year period. Procedure: a fresh application must be filed with, and approved by, the Tax Commissioner for each 5-year period, by 30 June of the first year of that period; the EUR 250,000 must then be paid in full by the end of the month following the Commissioner's approval; missing either deadline reverts the individual to ordinary income-based SDC liability for that year, with a fresh application possible the following year. The EUR 250,000 payment: is not credited against other tax liabilities or credit balances; fully discharges all SDC liability on dividends/interest for the 5 tax years it covers; is non-refundable for any reason; and cannot be reduced by any foreign tax credit. | Cyprus has no dedicated, free-standing 'economic substance act'. Substance is addressed through the corporate tax-residency test in Article 2 ('resident of the Republic') of the Income Tax Law (N.118(I)/2002, as amended): a company is Cyprus tax resident if EITHER (i) its management and control is exercised in Cyprus, OR (ii) it is incorporated in Cyprus under the Companies Law -- UNLESS an applicable double tax treaty provides otherwise (a treaty tie-breaker overrides the domestic incorporation limb). A company that transfers its registered office or seat to Cyprus is deemed incorporated in Cyprus for this purpose. In practice, holding companies relying on incorporation alone (without local management/control) that want treaty access, and want to avoid dual-residence or foreign-PE challenges, are expected to maintain genuine Cyprus-based decision-making, Cyprus-resident directors, Cyprus-kept books/records, and a functioning Cyprus bank account. | Cyprus has transposed the EU Pillar Two/Global Minimum Tax Directive (Council Directive (EU) 2022/2523 of 14 December 2022) via the Law on Ensuring a Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups in the Union of 2024 (N.151(I)/2024). Per the Law's own commencement article (Art.61): its provisions (including the Income Inclusion Rule, IIR) are deemed to have entered into force on 31 December 2023 and apply to financial years beginning on or after that date; the provisions needed to comply with Art.12(1) and Articles 13-15 (the Undertaxed Profits Rule, UTPR, mechanics) apply only to financial years beginning on or after 31 December 2024. A Qualified Domestic Minimum Top-up Tax is included within the same Law's general top-up-tax framework. | Cyprus's Ministry of Finance officially lists 72 double tax treaties (numbered 1-72, from Andorra to Viet Nam) on its live treaty table, which is updated well past its nominal 'Posted On 27 June 2024' date -- the table includes entries as recent as Hong Kong (signed 12 June 2026, Gazette 4305/19 June 2026), the Kyrgyz Republic's new agreement (signed 8 June 2026, Gazette 4306/26 June 2026), and Sweden's amending protocol (signed 3 July 2026, Gazette 4307/10 July 2026). At least 2 of the 72 listed agreements show a signature and Gazette-publication date but no separate 'date of entry into force' on the Ministry's own table -- Hong Kong and Viet Nam (signed 15 Dec 2025, Gazette 4302/19 Dec 2025) -- suggesting these are concluded/gazetted but ratification/entry into force was not yet complete as of the table's last update; the remaining approximately 70 show explicit entry-into-force dates already passed. Three treaty relationships continue via predecessor-state succession per the table's own footnotes: the former USSR treaty continues to apply to Azerbaijan, the Kyrgyz Republic (pending its new agreement's entry into force) and Uzbekistan; the former Czechoslovakia treaty continues to apply to Slovakia; and the former Yugoslavia treaty continues to apply to Bosnia, Montenegro, Serbia and Slovenia. | Not on the EU list of non-cooperative jurisdictions for tax purposes (Cyprus is an EU member state, categorically outside the scope of that list; zero mentions of Cyprus anywhere in the reviewed document, current or historical). Not on the FATF increased-monitoring ('grey list') as of the 13 February 2026 update -- zero mentions of Cyprus in that document. |
| Jerseychecked 2026-09-13 | Standard/default company tax rate is 0% (Article 123C(2)) for Jersey-resident companies (and companies with a Jersey permanent establishment) that are not financial-services companies, utility companies, cannabis-industry companies, or a specific fund-related 'registered person' exemption. Financial-services companies (defined in Article 123D(4): banking business, trust company business, fund administrator/custodian/registrar of unclassified or unregulated funds, investment business, certain insurance mediation, and consumer-credit providers) are taxed at 10% (Article 123D(2)). 'Large corporate retailers' (a defined, turnover-tested category) with income/profits/gains over GBP 750,000 for the period are taxed at 20% on the full amount (Article 123I(3)), with marginal relief for amounts between GBP 500,000 and GBP 750,000 (Article 123I(4)-(5)). Utility companies (six specifically named entities/licence-holders listed in Article 123C(3): Jersey New Waterworks Company, Jersey Gas Company, Jersey Electricity Company, and telecoms/postal/port licence-holders) and hydrocarbon-oil importers/suppliers (Article 123CAA) fall outside the 0% default and pay the general 'standard rate' used throughout the Law (the numeric standard rate is set annually by the States' Budget/Finance legislation, not fixed within this consolidated Law itself). | No separate territorial-source exemption or elective 'exempt company'/international-business-company regime exists under the current consolidated Income Tax (Jersey) Law 1961. Company taxation instead operates on the flat, activity-based 0/10/20 system (Article 123C default 0%; Article 123D 10% for financial-services companies; Article 123I 20% for large corporate retailers), applied to Jersey-resident companies (and Jersey permanent establishments) on a worldwide basis regardless of the source of income -- assignment to a rate category depends on business activity, not residence election or income source. A narrow statutory unilateral foreign-tax-credit mechanism exists (Part 14A, Articles 114A-114C) but applies only to a defined 'qualifying company' (a utility company or an Article 123D financial-services company); it credits foreign tax already paid on foreign-source income rather than exempting that income, and does not extend to the general 0%-rate company population under Article 123C. | Standard personal income tax rate of 20%, subject to a marginal-relief mechanism that reduces the effective rate on lower incomes. | Jersey has no capital gains tax. A full-text search of the entire consolidated Income Tax (Jersey) Law 1961 (Jersey's general statute taxing 'all property, profits or gains' under Schedule A and Schedule D per Article 1) returns zero occurrences of 'capital gain' or 'chargeable gain' anywhere in the ~16,700-line text; the only 'capital sum' references concern employment-termination compensation and life-insurance death benefits, not asset disposals. Jersey also has no standalone capital-gains-tax statute -- this is distinct from the Taxation (Land Transactions) (Jersey) Law 2009, which is a stamp-duty-style charge on the transfer of shares conferring a right to occupy land, not a tax on gains. | No wealth tax and no inheritance/estate tax. Revenue Jersey's official guidance on dealing with a deceased person's estate describes no tax charged on the value of an estate or on an inheritance received. The only tax consequences of death are: (a) the deceased's ordinary income tax liability up to the date of death; (b) ongoing 20% income tax on INCOME (not capital) generated by the moveable estate's assets during administration, to the extent attributable to Jersey-resident beneficiaries (or standard-rate income tax on trust income if a testamentary trust is created); and (c) a probate process (with an exemption where the gross moveable estate does not exceed GBP 30,000, or where all assets are held in joint names) that is a legal procedure, not a tax. Corroborated by a full-text search of the Income Tax (Jersey) Law 1961 itself, which contains zero occurrences of 'inheritance tax', 'estate duty', 'wealth tax', or 'net wealth'. | High Value Resident (HVR) status, granted either via a 1(1)(k) housing consent (historic terminology) or Entitled status under Regulation 2(1)(e) of the Control of Housing and Work (Residential and Employment Status) (Jersey) Regulations, codified in the current consolidated Income Tax (Jersey) Law 1961 at Article 135A ('Persons granted 1(1)(k) housing consent or Entitled status under Regulation 2(1)(e)'). | High Value Resident (HVR / 'Regulation 2(1)(e)') status: for grants made on or after 14 July 2023 (the current regime track), Article 135A(3B) of the Income Tax (Jersey) Law 1961 charges a high value resident's income above a 'prescribed limit' at a 'prescribed rate', with the limit and rate delegated to Regulations under Article 135A(12). The Income Tax (Prescribed Limit and Rate) (Jersey) Regulations 2013 (as amended, consolidated text current) fix that prescribed limit at GBP 1,250,000 (Regulation 2(3B)) and the prescribed rate at 1 penny in the pound = 1% (Regulation 3(1)). In practice, per Revenue Jersey's own HVR guidance: income up to GBP 1,250,000 is taxed at Jersey's standard personal rate of 20%, and income above that threshold at 1% (Jersey-source property income is always taxed at 20% regardless). 20% of GBP 1,250,000 = GBP 250,000, which reconciles exactly with Revenue Jersey's stated 'minimum tax contribution of £250,000 under Article 135A' that an applicant's guaranteed annual worldwide earnings (well above GBP 1.25 million, sustained for at least 10 years) must support. No fixed duration/sunset is stated for the status; it continues subject to continued eligibility/compliance. | Jersey maintains dedicated economic-substance legislation: the Taxation (Companies - Economic Substance) (Jersey) Law 2019, in force since 1 January 2019 (enacted in response to EU Code of Conduct Group / OECD pressure on 'geographically mobile' activity in zero/low-tax jurisdictions). It applies to any Jersey tax-resident company (per Article 123 of the 1961 Law) or resident LLC that carries on one or more of 9 defined 'relevant activities' (Article 3(1)): banking business, insurance business, fund management business, finance and leasing business, headquarters business, shipping business, holding company business, intellectual property holding business, and distribution and service centre business. A resident company carrying on a relevant activity must meet a 3-limb economic substance test (Article 5(2)): (a) directed and managed in Jersey for that activity (board meets in Jersey with a physically-present quorum of directors, minutes record strategic decisions, directors have necessary knowledge/expertise, records kept in Jersey -- Article 5(3)); (b) an adequate number of employees, adequate expenditure, and adequate physical assets in Jersey relative to the activity's scale; and (c) all core income-generating activities (CIGA, defined per-activity in Article 4) carried out in Jersey (or monitored/controlled by the company if outsourced). Non-compliance triggers a Comptroller-determined penalty up to a maximum of GBP 10,000 for a first failed financial period (Article 9(2)), with escalation for repeated failure in the following period, plus a right of appeal (Article 12) and potential exchange of information with foreign competent authorities (Article 8), especially for 'high risk IP companies'. | Jersey has implemented OECD Pillar Two via two 2025 laws: the Multinational Corporate Income Tax (Jersey) Law 2025 (a standalone 15% domestic corporate income tax, MCIT -- Revenue Jersey is explicit this is 'not a top-up tax or a Qualified Domestic Minimum Top-up Tax (QDMTT), but a corporate income tax designed in accordance with the Model Rules') and the Multinational Taxation (Global Anti-Base Erosion - IIR Tax) (Jersey) Law 2025 (a Qualified Income Inclusion Rule, IIR, successfully added to the OECD's central record of Qualified IIRs). Both apply for accounting periods beginning on or after 1 January 2025, to Jersey entities that are members of MNE groups reporting consolidated global annual revenue of EUR 750 million or more in at least 2 of the 4 preceding fiscal years. Jersey has NOT enacted an Undertaxed Profits Rule (UTPR). Per Revenue Jersey, over 95% of Jersey companies are unaffected and remain under the existing parallel 0/10 corporate income tax regime. The States Assembly adopted the legislation unanimously on 22 October 2024. | Per Revenue Jersey's own current double-taxation-agreement lists: 16 full double taxation agreements (Bahrain, Cyprus, Estonia, Guernsey, Hong Kong (China), Isle of Man, Liechtenstein, Luxembourg, Malta, Mauritius, Qatar, Rwanda, Seychelles, Singapore, United Arab Emirates, United Kingdom) and 14 partial double taxation agreements limited to individuals and/or shipping-and-aircraft income (Australia, Denmark, Faroes, Finland, France, Germany, Greenland, Iceland, Ireland, Japan, New Zealand, Norway, Poland, Sweden) -- 30 jurisdictions total with some form of DTA with Jersey. This is separate from, and does not include, Jersey's broader Tax Information Exchange Agreement (TIEA) network, which was not counted for this field. | Not on the EU list of non-cooperative jurisdictions for tax purposes as of the current 17 February 2026 update (current Annex I 10-jurisdiction list and Annex II 9-jurisdiction list, both reviewed in full, Jersey absent from both). Jersey's name DOES appear repeatedly (8 occurrences) elsewhere in the same compiled document, but every occurrence located falls within historical/superseded blocks -- an explicit 'REMOVED FROM ANNEX II' historical entry naming Jersey among many jurisdictions, or older cumulative Annex-II membership rosters from past review cycles -- not the document's current, top-of-page listing. Not found in the FATF increased-monitoring ('grey list') document (13 February 2026 update) at all -- zero mentions of Jersey. |
| Switzerlandchecked 2026-09-13 | Federal corporate income tax is a flat 8.5% of net profit (Art. 68 DBG), which equates to approximately 7.83% of pre-tax profit because federal, cantonal and communal taxes are themselves deductible business expenses under Art. 59 Abs. 1 lit. a DBG. Cantons and communes each levy an additional profit tax on top of the federal rate, at rates each of the 26 cantons sets independently, so the combined federal+cantonal+communal effective rate varies materially by canton and commune of registration. ESTV's own tax-burden-comparison publication confirms this variation structurally ('the tax total is made up of factors that are determined not only by the Confederation but also by the cantons and the municipalities, the tax burden varies from place to place and from year to year') but only offers historical (2020/2021) downloadable tables rather than a live current-year table, so a specific current combined percentage or range across the 26 cantons was not independently re-derived this session and has been dropped rather than restated from uncorroborated secondary sources. | No privileged holding/domiciliary/mixed-company tax-status regime exists under current law. The former cantonal privileged-status regimes were repealed by the Federal Act of 28 September 2018 on Tax Reform and AHV Financing (TRAF/STAF), in force since 1 January 2020 -- confirmed by footnote 1 to Art. 2 StHG ('Fassung gemäss Ziff. I 3 des BG vom 28. Sept. 2018 über die Steuerreform und die AHV-Finanzierung, in Kraft seit 1. Jan. 2020') and by the fact that the current text of Art. 28 StHG contains only a generally-available participation relief for qualifying shareholdings (>=10% of capital/profit or >=CHF 1 million market value), open to any company regardless of type -- the old type-based holding/domiciliary/mixed-company provisions are simply absent from the current consolidated text. In their place: (1) a mandatory patent box (Art. 24a/24b StHG) giving qualifying patent/IP net profit up to a 90% reduction in the cantonal taxable base via a nexus-ratio method -- 'mit einer Ermässigung von 90 Prozent... Die Kantone können eine geringere Ermässigung vorsehen' (a canton may set a lower relief, but 90% is the ceiling, and no canton is exempted from offering the regime); and (2) an optional R&D super-deduction (Art. 25a StHG) under which a canton may, on request, allow up to 50% additional deduction over actual qualifying Swiss R&D expense (i.e. up to 150% of actual spend) -- 'Die Kantone können auf Antrag... um höchstens 50 Prozent... zum Abzug zulassen', explicit opt-in language showing this one is cantonal-discretionary, unlike the patent box. | Federal personal income tax is progressive; the top federal marginal rate is 11.5%, reached above CHF 794,000 of taxable income under the basic (single-taxpayer) schedule of Art. 36 Abs. 1 DBG: '...für 794 000 Franken Einkommen 91 310.00 und für je weitere 100 Franken Einkommen 11.50 mehr.' A separate, more generous schedule applies to married couples living in an undivided marriage (Art. 36 Abs. 2 DBG). Cantons and communes each levy an additional, independently-set income tax on top of the federal rate, so combined federal+cantonal+communal top marginal rates vary materially by canton and commune of residence. As with cit_headline, ESTV's cantonal tax-burden-comparison page confirms this variation structurally but only offers historical 2020/2021 downloadable tables, not a live current-year table, so a specific current combined percentage or range across the 26 cantons was not independently re-derived this session. | Capital gains on the disposal of assets held as PRIVATE (non-business) property are tax-exempt at the federal level: Art. 16 Abs. 3 DBG -- 'Die Kapitalgewinne aus der Veräusserung von Privatvermögen sind steuerfrei.' ('Capital gains from the disposal of private assets are tax-exempt.') This is mirrored at the cantonal-harmonization level by Art. 7 Abs. 4 lit. b StHG, which lists 'Kapitalgewinne auf beweglichem Privatvermögen' (capital gains on MOVABLE private assets) among income-tax-exempt items -- the word 'beweglichem' (movable) is significant because that same StHG provision expressly reserves ('vorbehalten bleibt Artikel 12 Absatz 2') real estate from the exemption. Real estate gains, even on private assets, are instead captured by a separate real estate gains tax (Grundstückgewinnsteuer): Art. 12 Abs. 1 StHG -- 'Der Grundstückgewinnsteuer unterliegen Gewinne, die sich bei Veräusserung eines Grundstückes des Privatvermögens... ergeben.' This is a cantonal tax cantons must levy (Art. 2 Abs. 1 lit. d StHG). Separately, exceptions recognized under long-standing ESTV administrative practice and Federal Supreme Court case law (not themselves codified as a DBG/StHG article, so not independently verified against a primary text this session) include: gains realized by a person classified as a professional securities dealer (gewerbsmässiger Wertschriftenhändler), recharacterized as taxable self-employment income; and anti-avoidance recharacterization under the indirect-partial-liquidation/transposition doctrines in specific structured-sale scenarios. | No federal wealth tax exists -- the Direct Federal Tax Act (DBG) taxes only income (natural persons, Titel 2) and profit (legal entities, Titel 3); it contains no wealth-tax chapter (confirmed by full-text review of the fetched DBG document, 843KB / covering the complete statute). Wealth tax on individuals is instead a MANDATORY cantonal tax under federal tax-harmonization law: Art. 2 Abs. 1 lit. a StHG requires every canton to levy 'eine Einkommens- und eine Vermögenssteuer von den natürlichen Personen' (an income tax AND a wealth tax on individuals) -- so all 26 cantons levy a net-wealth tax on worldwide net assets, at rates/brackets each canton sets independently (not independently re-tabulated this session). Inheritance and gift tax is NOT among the taxes Art. 2 StHG requires cantons to levy -- the exhaustive list is: individual income+wealth tax, corporate profit+capital tax, a withholding tax on certain persons, and a real estate gains tax. Because inheritance/gift tax falls outside this federally-harmonized list, it is a matter of full cantonal sovereignty, which is why its rules, exemptions and rates (including whether it is levied at all) differ far more sharply canton-to-canton than the StHG-harmonized taxes do. | Lump-sum taxation ('Besteuerung nach dem Aufwand' / expenditure-based taxation), Art. 14 DBG. Available to individuals who: (a) do not hold Swiss citizenship; (b) are becoming subject to unlimited Swiss tax liability for the first time, or after at least a 10-year interruption; and (c) do not engage in gainful employment in Switzerland (Art. 14 Abs. 1 DBG). Where a married couple lives in a legally and factually undivided marriage, BOTH spouses must independently meet these conditions (Abs. 2). The tax base is the taxpayer's (and dependents') annual cost of living in and outside Switzerland during the assessment period, but not less than the HIGHEST of: (a) CHF 435,000 (federal statutory floor, index-adjusted to consumer prices by the EFD per Abs. 6); (b) 7x the annual rental value of the taxpayer's own Swiss household; (c) 3x the annual boarding cost where the taxpayer lives in a pension/boarding arrangement; or (d) the sum of specified gross Swiss-source income items (Swiss real estate income, movable Swiss capital income, Swiss copyrights/patents, Swiss-source pensions/annuities, and treaty-relief-triggering foreign income) (Art. 14 Abs. 3 DBG). The ordinary progressive federal rate schedule (Art. 36 DBG) is then applied to this deemed base (Abs. 4). This is a FEDERAL regime; whether a given canton offers an equivalent regime for its own cantonal/communal taxes is governed by a parallel StHG provision and was not independently re-surveyed across all 26 cantons this session. | Federal minimum assessment base: CHF 435,000 (tax year 2026), per DBG/LIFD Art. 14 para. 3(a): 'mindestens aber nach dem höchsten der folgenden Beträge... a. 435 000 Franken'. Alternative floors under the same paragraph: 7x annual rent/rental value (taxpayers with own household), or 3x annual pension-price for board/lodging (other taxpayers), or the sum of specified Swiss-source gross income categories (subparagraph d) — whichever is highest applies. Cantons may set higher minimums; duration is indefinite subject to continued eligibility (no fixed sunset). | Switzerland has no standalone, dedicated 'economic substance' statute of the kind found in zero/low-tax offshore jurisdictions responding to EU/OECD FHTP economic-substance criteria. The closest historical federal instrument -- the Federal Council Decree of 14 December 1962 on measures against unjustified use of Switzerland's double taxation agreements ('Missbrauchsbeschluss'/BRB 62, SR 672.202), which had imposed substance-like conditions (real premises, adequate own staff/expenses, no excessive pass-through of income) as a precondition for treaty-based withholding-tax relief -- was REPEALED effective 1 January 2022 by the Federal Council. Currently, substance-type anti-treaty-abuse conditions are addressed through (a) ESTV administrative circulars (Kreisschreiben of 31 December 1962, 17 December 1998 and 1 July 2010, referenced by SIF's current 'Missbrauch' page as continuing explanatory guidance) and (b) general beneficial-ownership / anti-abuse doctrine embedded in Switzerland's own tax treaties (several updated via the OECD BEPS Multilateral Instrument's principal purpose test) plus Federal Supreme Court case law -- rather than a single codified 'substance test' statute. | Qualified Domestic Minimum Top-up Tax (QDMTT, 'nationale Ergänzungssteuer') in force since 1 January 2024, per Federal Council decision of 22 December 2023. Income Inclusion Rule (IIR, 'internationale Ergänzungssteuer') in force since 1 January 2025, per Federal Council decision of 4 September 2024. Undertaxed Profits Rule (UTPR) explicitly NOT yet in force: the EFD's own explainer devotes a dedicated Q&A ('Warum wird die UTPR nicht auf 2025 in Kraft gesetzt?') to the decision not to activate UTPR for 2025, citing (i) materially lower incremental revenue potential versus the IIR, and (ii) ongoing international legal uncertainty/debate over the UTPR's compatibility with international law and tax treaties. Legal basis: an 18 June 2023 popular-vote constitutional amendment (78.5% approval) empowering the Federal Council to implement the minimum-tax regime by ORDINANCE (Verordnung über die Mindestbesteuerung grosser Unternehmensgruppen, MindStV) pending a federal statute that must be submitted to Parliament within 6 years. Applies to MNE groups with annual consolidated worldwide revenue >= EUR 750 million (a few hundred Swiss-headquartered groups and a few thousand foreign-headquartered groups with a Swiss presence; ~99% of companies in Switzerland are unaffected and taxed as before). The top-up tax is legally a federal tax but is assessed by the cantons, as with ordinary direct federal tax. | ESTV's official per-country tax-information index ('List of countries in alphabetical order', estv.admin.ch/en/list-of-countries) lists 98 distinct countries -- after excluding 13 dependent-territory cross-references such as 'Antigua (s. United Kingdom)' or 'Faeroe Islands (s. Denmark)', which are covered under another country's agreement rather than having their own -- with which Switzerland maintains a country-specific double-taxation-agreement information page, as counted directly from the fetched page's full alphabetical listing (111 total listed entries across headers A through V and Z, minus 13 '(s. <country>)' cross-references = 98 direct entries). This is consistent with, and more precise than, the commonly cited 'over 100' figure for Switzerland's double-tax-treaty network; the ESTV list may include a small number of jurisdictions covered by narrower agreements (e.g. exchange-of-information-only) rather than a comprehensive income/capital DTA, so 98 should be read as the count of ESTV's per-country DTA-related information pages, not a certified count of comprehensive-DTA-only treaties. | Not on the EU's list of non-cooperative jurisdictions for tax purposes as of the Council's most recent update in the fetched document (17 February 2026): current Annex I (9 jurisdictions) is Belize, British Virgin Islands, Brunei Darussalam, Eswatini, Greenland, Jordan, Montenegro, Morocco, Türkiye; current Annex II (10 jurisdictions) is American Samoa, Anguilla, Guam, Palau, Panama, Russia, Turks & Caicos Islands, US Virgin Islands, Vanuatu, Viet Nam -- Switzerland appears on neither. (Switzerland did briefly appear on Annex II earlier in the list's history and was removed at the October 2019 Council update, per the same document's historical-evolution pages; it has not reappeared on either annex in any subsequent dated snapshot in the document, through the current 17 February 2026 update.) Not on the FATF's list of High-Risk Jurisdictions subject to a Call for Action or Jurisdictions under Increased Monitoring: Switzerland's dedicated FATF country page carries no such designation and no black/grey-list banner; the page's own navigation cross-references FATF's 'Jurisdictions under Increased Monitoring' listing dated 19 June 2026 as the version current at fetch time. Under the OECD Global Forum's peer review of the Exchange of Information on Request (EOIR) standard, Switzerland was rated 'Largely Compliant' in both its first-round (2016) and second-round (2020) peer reviews -- the most recent rating identifiable this session. The Global Forum's live country-rating pages (both the ratings hub and Switzerland's own oecd.org country page) render the per-country rating client-side via JavaScript; the rating text did not surface in static/rendered markup across 3 fetch attempts this session (direct fetch of the ratings hub, direct fetch of the Switzerland country page [HTTP 403], and a ScraperAPI JS-rendered fetch of the same country page), so this cell relies on the 2020-round publicly reported rating rather than a freshly re-confirmed live rating. |
| Monacochecked 2026-09-13 | Corporate income tax ("Business Profit Tax") is 25% for financial years commencing on or after 1 January 2022, the endpoint of a phased reduction from 33.33%: 33.33% for financial years before 1 January 2019; 31% from 1 January 2019; 28% from 1 January 2020; 26.5% from 1 January 2021; 25% from 1 January 2022 onward. Legal basis cited on the government page: Sovereign Ordinance no. 3.152 of 19 March 1964 instituting a profit tax. | Firms carrying out commercial or industrial activities that generate more than 25% of their turnover outside Monaco are subject to corporate income tax; the legal form of the company is irrelevant, and liability turns on the nature of the activities and location of transactions. Firms that do not cross this 25%-outside-Monaco turnover threshold fall outside the tax's scope entirely -- this threshold functions as Monaco's de facto territorial/exempt regime for domestically-focused business. | 0% -- Monegasque nationals and residents of the Principality are not liable for personal income tax, with the exception of French nationals, who are governed by the 1963 Bilateral Convention between France and Monaco. The absence of income tax for individuals applies only to activities/persons genuinely established in Monaco and does not affect rules applied by other states. | Corporate: capital gains from asset sales as part of business activities fall within the 25% corporate income tax base, but may be exempt under certain conditions if reinvested in the firm. Individual: no separate personal capital gains tax exists, consistent with -- and following directly from -- the general absence of personal income tax for Monaco residents; the government's general tax-summary page, which comprehensively covers individual taxation, does not carve out capital gains as a distinct taxable category for individuals. | No wealth tax, no annual property tax, no council tax. Inheritance and gift tax IS levied, but purely territorially: it applies only to assets situated in (or with situs in) the Principality of Monaco, regardless of the domicile, residence, or nationality of the deceased/donor, subject to the provisions of the Convention between France and Monaco of 1 April 1950. Rate schedule by relationship to the deceased/donor: 0% between parents and children or spouses (direct filiation); 8% between siblings; 10% between uncles/aunts and nephews/nieces; 13% between relatives other than the foregoing; 16% between persons who are not related. | No elective or beneficial new-resident tax regime (of the Swiss Pauschalbesteuerung / Italian Art. 24-bis / Portuguese NHR type) exists. Monaco's 0% personal income tax applies automatically and identically to all resident individuals (Monegasque and foreign nationals alike) from the point of genuine establishment in the Principality -- there is no election, minimum-spend threshold, qualifying period, or fee-based mechanism to opt into. The only distinction drawn among residents runs the opposite direction of a new-resident incentive: French nationals remain subject to French taxation under the 1963 Bilateral Convention between France and Monaco regardless of Monaco residence. | Not applicable -- no elective new-resident tax regime exists for which a threshold or fee could apply (see new_resident_special_regime). | Not yet researched | No OECD Pillar Two / GloBE / QDMTT legislation has been enacted as of the check date. A bill -- Projet de loi n° 1129, "relative à l'imposition minimale des groupes d'entreprises multinationales" -- was received by the Conseil National (Monaco's National Council) on 28 July 2026 and remains under committee review (committee and rapporteur both listed as "À venir" / to be assigned); the Conseil National site categorizes it under "Les projets de loi en cours" (bills currently in progress), confirming it is a pending bill, not enacted law. The bill's own text (dated 14 July 2026 exposition of motives) proposes implementing the OECD/G20 Inclusive Framework's Pilier Deux / GloBE model rules (adopted 14 December 2021): a 15% minimum effective tax rate on multinational enterprise groups with annual consolidated turnover of at least EUR 750 million, via a Qualified Domestic Minimum Top-up Tax (QDMTT). | Monaco has signed 36 bilateral tax agreements (per the government's own summary statement) with 35 partner jurisdictions -- Liechtenstein alone has two separate agreements (a tax-information-exchange agreement and a double-taxation convention). Of the 35 jurisdictions, 12 have an agreement specifically framed (by its own title) as a double-taxation-avoidance/elimination convention: France (1963 -- the most significant, per the source's own framing), Guernsey, Liechtenstein, Luxembourg, Mali, Malta, Mauritius, Montenegro, Qatar, Saint Kitts and Nevis, Seychelles, and the United Arab Emirates (signed 13 November 2021, no ordinance/entry-into-force date yet listed on the page). The remaining 23 jurisdictions -- Andorra, Argentina, Australia, Austria, Bahamas, Belgium, Czech Republic, Denmark, Faroe Islands, Finland, Germany, Greenland, Iceland, India, Italy, Liechtenstein (its second, TIEA agreement), Netherlands, Norway, San Marino, Samoa, South Africa, Sweden, and the United Kingdom -- are framed as tax-information-exchange, mutual-assistance, or (United States) country-by-country-reporting agreements rather than double-taxation conventions. | Monaco is currently under FATF increased monitoring ('grey list') as of the 13 February 2026 update. Per the FATF's own statement: 'Since June 2024, when Monaco made a high-level political commitment to work with the FATF and MONEYVAL to strengthen the effectiveness of its AML/CFT regime, Monaco has taken steps towards improving its AML/CFT regime on many of its action items, including by strengthening the timeliness of STR reporting. Monaco should continue to work on implementing its FATF action plan by: (1) enhancing the application of sanctions for AML/CFT breaches and (2) applying effective, dissuasive and proportionate sanctions for ML.' The FATF notes all deadlines have now expired and work remains. Monaco is NOT on the EU list of non-cooperative jurisdictions for tax purposes (zero mentions in the 17 February 2026 update document, current or historical). |
| Italychecked 2026-09-13 | IRES (corporate income tax): flat 24% on net taxable profit. Confirmed directly on Agenzia delle Entrate's official IRES explainer page: "L'aliquota d'imposta sui redditi delle società (Ires) è pari al 24%." (The 2025 Budget Law -- Art. 1 commi 436-444, Legge 207/2024 -- offers a conditional, temporary reduced 20% rate for the tax period after FY2024 to companies that allocate >=80% of 2024 profit to reserve and reinvest >=30% in qualifying new capital goods; this is a conditional incentive layered on top of, not a change to, the standard 24% rate.) IRAP (regional tax on productive activities): standard rate 3.9% of net production value, confirmed directly from Agenzia delle Entrate's own 'IRAP 2026' return instructions: "ai sensi del comma 1 dell'articolo 16, l'imposta è determinata applicando al valore della produzione netta l'aliquota del 3,9 per cento." Higher sector-specific IRAP rates also confirmed in the same instructions: 4.20% for highway/tunnel motorway concessionaires, 4.65% for banks and other financial intermediaries (soggetti di cui all'art. 6), 5.90% for insurance companies (art. 7). Legge 30 dicembre 2025, n. 199 (the 2026 Budget Law), Art. 1 comma 74, temporarily increases the art. 16 comma 1-bis lett. b) and c) sub-rates by 2 percentage points for the tax period after FY2025 and the following two periods (for entities other than those in art. 6 commi 2/3/4/9), offset by a EUR 90,000 deduction mechanism -- this does not change the 3.9% standard/general IRAP rate itself. | Italy taxes IRES subjects on a worldwide-income basis -- there is no broad territorial system or blanket corporate tax exemption. Instead, Italy operates a participation exemption (PEX) system that functionally shields most intercompany capital gains and dividends from double taxation. TUIR Art. 87 ('Plusvalenze esenti'): capital gains on qualifying shareholdings are 95% exempt from IRES (only 5% of the gain is taxable, i.e. an effective ~1.2% tax on the gain), conditional on (a) uninterrupted holding from the first day of the 12th month preceding disposal, (b) classification as a financial fixed asset in the first balance sheet closed during the holding period, and (c) the investee not being resident/located in a low-tax jurisdiction per the Art. 47-bis blacklist criteria (unless the taxpayer proves via interpello that the investee is not artificially set up to obtain an undue tax advantage). TUIR Art. 89 ('Dividendi ed interessi'): dividends distributed to IRES-subject recipients are likewise 95% excluded from the recipient's taxable income (only 5% taxed). | IRPEF (personal income tax) progressive scale, CURRENT for 2026 (TUIR Art. 11 comma 1, as amended by the 2026 Budget Law): 23% up to EUR 28,000; 33% from EUR 28,001 to EUR 50,000; 43% above EUR 50,000. This corrects the matrix's prior draft, which cited the 2025-vintage middle bracket of 35% -- Legge 30 dicembre 2025, n. 199 (2026 Budget Law), Art. 1 comma 3, amended TUIR art. 11 comma 1 lett. b) by replacing '35 per cento' with '33 per cento', effective for 2026. Regional and municipal surcharges (addizionali regionali/comunali) apply on top and vary by locality; not quantified here. | Flat 26% substitute tax ('imposta sostitutiva') applies to most financial capital gains classified as 'redditi diversi di natura finanziaria' under TUIR Art. 67 comma 1, letters c-bis through c-quinquies (gains on qualifying and non-qualifying shareholdings, other securities, currencies, derivatives, etc.) -- the 26% rate is confirmed by Normattiva's own official amendment annotation to Art. 67, which reproduces the amending law's operative text verbatim: "...redditi diversi di cui all'articolo 67, comma 1, lettere da c-bis) a c-quinquies)... sono stabilite nella misura del 26 per cento." Separately, interest and other yield on Italian government bonds ('titoli di Stato') and similar instruments benefit from a preferential 12.5% substitute tax, confirmed directly from D.Lgs. 239/1996 Art. 2: "Sono soggetti ad imposta sostitutiva delle imposte sui redditi nella misura del 12,50 per cento, gli interessi ed altri proventi delle obbligazioni e titoli similari..." (Convergent secondary sources report the same 12.5% rate also extends to capital gains realized on disposal of those bonds; this pass located a related residual 12.5% substitute-tax provision at D.Lgs. 461/1997 Art. 5 comma 2 but, because that text's cross-references use pre-2003 TUIR article numbering, could not fully pinpoint its exact current scope within the time available -- flagged rather than asserted as fully confirmed.) Crypto-asset gains (TUIR Art. 67 comma 1 lett. c-sexies) are taxed at an ordinary rate of 33% for transactions realized on or after 1 January 2026 (up from 26% through 31 December 2025), with a carve-back to 26% specifically for gains/proceeds from EUR-denominated e-money tokens (per Regulation (EU) 2023/1114) -- both directly confirmed from Legge 199/2025, Art. 1 comma 28 (amending Legge 207/2024 Art. 1 comma 24). | Inheritance/gift tax (imposta sulle successioni e donazioni), confirmed directly from Agenzia delle Entrate's official rates-and-allowances page: 4% for transfers to spouse or direct-line relatives (ascendants/descendants), applied to the net value exceeding EUR 1,000,000 per beneficiary; 6% for transfers to siblings, applied to the value exceeding EUR 100,000 per beneficiary; 6% for transfers to other relatives up to the 4th degree and relatives-in-law up to the 3rd degree, with NO threshold; 8% for transfers to all other beneficiaries, with NO threshold. A EUR 1.5 million threshold applies specifically for beneficiaries with severe disabilities requiring intensive support (Law 104/1992 Art. 3 comma 3). No separate general net-wealth tax on individuals resident in Italy. However, Italy levies two wealth-adjacent taxes on FOREIGN-held assets of Italian tax residents: IVIE on foreign real estate, ordinarily 1.06% of property value since 2024 (was 0.76% through 2023), reduced to 0.4% for a foreign main residence in luxury cadastral categories A/1, A/8 or A/9 (de minimis: not due if the total amount is <= EUR 200); and IVAFE on foreign financial assets, ordinarily 2 per mille (0.2%) of value, rising to 4 per mille (0.4%) for assets held in states/territories with a privileged tax regime (per the 2024 Budget Law, Art. 1 comma 91 lett. b). | Article 24-bis TUIR optional flat substitute-tax ('imposta sostitutiva') regime for individuals transferring their tax residence to Italy, covering foreign-source income. Effects last 15 years ('quindici anni') from the first tax period the option is exercised, after which the regime automatically ceases. May be extended to family members, each of whom separately elects and pays their own substitute tax. | EUR 300,000 per tax year for the primary applicant, applicable to individuals who transfer tax residence to Italy on or after 1 January 2026. This is the THIRD figure in the regime's history: originally EUR 100,000, raised to EUR 200,000 from 2024, and raised again to EUR 300,000 effective 2026 (Legge di Bilancio 2026 / Law No. 199/2025). Family members electing into the regime each pay a separate substitute tax of EUR 50,000 per year (also a 2026 Budget Law change). | Italy has no discrete, freestanding 'economic substance act'. The closest functional analogue is the CFC (Controlled Foreign Companies) regime at TUIR Art. 167, which taxes a non-resident controlled entity's income by transparency in the hands of its Italian controller ONLY when BOTH of two conditions are jointly satisfied (per Art. 167 comma 4's own chapeau: 'si applica se... integrano congiuntamente le seguenti condizioni'): (a) the non-resident entity is subject to an effective tax rate below 15% -- computed as current-plus-deferred tax over pre-tax accounting profit, using audited financial statements, or (if unaudited or inconclusive) tested instead against half of the effective rate that would apply if the entity were Italian-resident; the 15% threshold is explicitly tied to the OECD/EU Pillar Two minimum via comma 4-bis, which folds in the 'imposta minima nazionale equivalente' defined by Italy's own Pillar Two transposition decree; and (b) more than one-third of the entity's income falls into enumerated passive/low-substance categories (interest/financial-asset income; IP royalties; dividends and gains on shareholdings; finance-lease income; banking/insurance/financial-sector income; and low-added-value goods/services transactions with related parties). A foreign subsidiary with genuine active-business income outside those categories falls outside the CFC regime by failing condition (b) alone -- this passive-income test is what functionally substitutes for a dedicated substance test in Italian law. (A separate express 'genuine economic activity' escape-clause may also exist elsewhere in Art. 167's later commi, but was not located within the specific comma range -- 1 through 4-bis -- read this pass.) | Italy has transposed the EU Global Minimum Tax Directive (Council Directive (EU) 2022/2523) via Decreto Legislativo No. 209 of 27 December 2023 ('Attuazione della riforma fiscale in materia di fiscalità internazionale'), published in Gazzetta Ufficiale n.301 of 28 December 2023, in force from 29 December 2023 and applying to fiscal years from 1 January 2024. The decree's Titolo I sets out the Global Minimum Tax framework -- domestic top-up tax ('imposta minima nazionale'), Income Inclusion Rule ('imposta minima integrativa'), and Undertaxed Profits Rule ('imposta minima suppletiva') -- with Art. 10 fixing scope at multinational or purely-domestic groups with consolidated annual revenue of EUR 750 million or more in at least 2 of the preceding 4 fiscal years. This decree's operative status is independently corroborated from within the current, consolidated tax code itself (not merely secondary reporting): TUIR Art. 167 comma 4-bis (Italy's CFC statute, as amended by this same decree) explicitly cross-references 'il decreto di recepimento della direttiva (UE) 2022/2523 del Consiglio, del 15 dicembre 2022' as an existing, operative instrument. | Approximately 100 double-taxation treaties in force, per Agenzia delle Entrate's own official statement: "In Italia sono in vigore circa un centinaio di Trattati (o ‘Convenzioni’) per evitare le doppie imposizioni, generalmente conformi al Modello OCSE di Convenzione, stipulati con tutti gli Stati membri dell'Unione Europea e con altri Stati o territori esteri." The Agency's own summary page gives only this approximate figure ('circa un centinaio' = 'approximately a hundred'), not a precise integer count, and refers readers onward to the Ministry of Economy and Finance's site for the complete itemized list. | Not on the FATF black list ('High-Risk Jurisdictions subject to a Call for Action') or grey list ('Jurisdictions under Increased Monitoring') per the 19 June 2026 FATF update: the black list comprises only the Democratic People's Republic of Korea, Iran and Myanmar; the grey list comprises Angola, Bolivia, Bosnia and Herzegovina, Bulgaria, Cameroon, Cote d'Ivoire, Democratic Republic of Congo, Haiti, Iraq, Kenya, Kuwait, Laos, Lebanon, Monaco, Nepal, Papua New Guinea, South Sudan, Syria, Venezuela, Vietnam, Virgin Islands (UK) and Yemen -- Italy appears on neither. The same FATF page lists Italy by name under 'FATF Member Countries'. Separately, Italy is not on the EU list of non-cooperative jurisdictions for tax purposes as of the 17 February 2026 update (Italy is an EU member state; a prior pass reviewed the full Annex I 10-jurisdiction and Annex II 9-jurisdiction lists and confirmed Italy's absence from both). |
| Greecechecked 2026-09-13 | 22% flat corporate income tax rate on taxable profits for legal persons and legal entities of any bookkeeping category (Law 4172/2013 Income Tax Code, Article 58 para. 1). Two narrower special rates coexist: 10% for agricultural cooperatives/producer groups meeting Article 22 of L.4673/2020 registration (Art. 58 para. 2, as replaced by Art. 22 para. 2 of L.4646/2019, for income from 1.1.2020), and 29% for certain credit institutions electing the Article 27A deferred-tax-asset regime. | No broad territorial or exempt-company regime. Greece taxes companies that are Greek tax residents (incorporated under Greek law, or with registered seat or place of effective management in Greece -- Art. 4 para. 3 ITC) on worldwide income; non-residents are taxed only on Greek-source income (Art. 3 ITC). The only carve-out to the worldwide-income rule is a narrow one for foreign staff of offices installed in Greece under a.n. 89/1967, taxed only on Greek-source income -- not a general territorial system. A standard EU-aligned intra-group dividend participation exemption exists (Art. 48 ITC: inbound dividends exempt if the recipient holds >=10% of the paying EU subsidiary for a continuous 24-month period, plus other conditions), but this is a narrow anti-double-taxation mechanism, not a broad territorial or holding-company exempt regime. | 44% top marginal rate, applying to taxable employment/pension/business income above EUR 60,000 (Income Tax Code Art. 15 para.1, as replaced by Article 3 of Law 5246/2025). Full 2026 scale: 0-10,000 = 9%; 10,000.01-20,000 = 20%; 20,000.01-30,000 = 26%; 30,000.01-40,000 = 34%; 40,000.01-60,000 = 39%; >60,000 = 44%. The second and third brackets are reduced for taxpayers with dependent children (down to 0% for 4+ children in the first two brackets), and there are age-based reliefs for taxpayers under 30. | Two distinct regimes. (1) Securities/capital transfers (shares, partnership interests, government/corporate bonds, derivatives): flat 15% tax on the gain (price paid vs. price received), per Income Tax Code Arts. 42-43 as enacted. (2) Real estate capital gains: a 15% tax exists in statute (Art. 41 ITC) but its application has been under continuous legislative suspension since 2015; the current suspension runs through 31 December 2026 per Article 90 of Law 5162/2024. No further extension beyond 2026 has been enacted as of this check. | No general/recurring net-wealth tax. Death-transfer inheritance tax exists under the Code of Inheritance, Gift, Parental-Grant and Games-of-Chance-Winnings Tax (Law 2961/2001), Art. 29 para.2, with three kinship-based categories, each with its own progressive bracket scale: Category A (spouse/registered partner of >=2yr, children, grandchildren, parents) -- 0% to EUR150,000, 1% on the next EUR150,000 (to 300,000), 5% on the next EUR300,000 (to 600,000), 10% above EUR600,000. Category B (further descendants/ascendants, siblings, in-laws, step-relations) -- 0% to EUR30,000, 5% to 100,000, 10% to 300,000, 20% above. Category C (all other heirs) -- 0% to EUR6,000, 20% to 72,000, 30% to 267,000, 40% above. A spouse (>=5yr married) or registered civil partner (>=5yr cohabiting) additionally receives a total inheritance-tax exemption up to EUR400,000 via a bracket adjustment (Art.25 para.2(g) ITC-equivalent code, cf. ΠΟΛ.1036/2004). Separately, lifetime gifts/parental grants to Category-A recipients get a more generous flat EUR800,000 per-donee tax-free threshold with a flat 10% rate on the excess, effective for transfers from 1 October 2021 (Art.44 of the Code, as amended by Art. 56 of Law 4839/2021); gifts before that date used the old Category-A scale with a EUR150,000 threshold. Category-B/C gift rates track the inheritance scale above (Art.44 in conjunction with Art.29). | Non-domiciled ('non-dom') alternative taxation regime for foreign-source income under Article 5A of the Income Tax Code (Law 4172/2013), for individuals transferring tax residence to Greece. Sibling regimes: Article 5B (foreign pensions, flat 7%) and Article 5C (50% exemption on Greek-source employment/business income for 7 years). 5A and 5B mutually exclusive; either combinable with 5C. | Flat annual tax of EUR 100,000 on all foreign-source income regardless of amount, for 15 tax years from year of application; extending to a family member costs EUR 20,000/person/year, with donee/heir also fully exempt from Greek gift/inheritance tax on foreign-situated assets while enrolled. Investment condition (absent a Golden Visa): minimum EUR 500,000 within 3 years; investments must postdate 2019-12-12. | No standalone economic-substance act. Substance requirements are embedded in the Controlled Foreign Company (CFC) rules at Art. 66 of the Income Tax Code (Law 4172/2013). As enacted, Art.66 para.2 exempts a foreign subsidiary resident in another EU/EEA state from CFC attribution unless 'the establishment or economic activity of the legal person or legal entity constitutes an artificial arrangement created with the essential purpose of avoiding the tax due' -- i.e. a genuine-economic-activity/non-wholly-artificial-arrangement carve-out (Cadbury Schweppes-style test), on top of the base CFC triggers (>50% ownership, low-tax jurisdiction, >30% passive income, non-listed company). Art.66 was subsequently amended by Article 12 of Law 4607/2019 to align with EU ATAD (Directive (EU) 2016/1164); AADE's own current interpretive circular describes the post-amendment exemption as requiring the CFC to demonstrate substantial economic activity 'supported by staff, equipment, assets and facilities' evidenced by actual facts and circumstances. | Adopted. Greece transposed the EU Minimum Tax Directive (Council Directive (EU) 2022/2523 of 14 December 2022) via Law 5100/2024, published in the Government Gazette (ΦΕΚ Α' 49/05.04.2024). The law introduces a Qualified Domestic Minimum Top-up Tax (QDMTT) and Income Inclusion Rule (IIR), applicable to fiscal years starting on/after 31 December 2023 (Art.69 para.2), and an Undertaxed Profits Rule (UTPR, Arts.13-15), applicable to fiscal years starting on/after 31 December 2024 (Art.69 para.3), subject to a one-year-deferral carve-out under Art.50(1) of the Directive. | 58 double tax treaties currently in force, per AADE's own official index. The Sweden treaty (Law 4300/1963) is explicitly noted as terminated (no longer in force from 1 January 2022 for income / 1 January 2023 for capital, following a Swedish unilateral denunciation) and is NOT among the 58 -- it appears only as a historical footnote. France's treaty was fully revised (new treaty, Law 4984/2022, in force from 1 January 2024) and is counted within the 58 as a live, current-generation agreement. | Not listed on any of the three reference lists checked. (1) FATF: Greece is a full FATF member (not merely unlisted) and does not appear on either the 'High-Risk Jurisdictions subject to a Call for Action' (black list: DPRK, Iran, Myanmar) or the 'Jurisdictions under Increased Monitoring' (grey list: 22 jurisdictions including Bulgaria, Kuwait, Monaco, Vietnam, etc.) as of the FATF's 19 June 2026 statements. (2) EU list of non-cooperative jurisdictions for tax purposes: Greece is not listed in Annex I (10 jurisdictions: American Samoa, Anguilla, Guam, Palau, Panama, Russia, Turks and Caicos Islands, US Virgin Islands, Vanuatu, Viet Nam) per the Council's 17 February 2026 update -- structurally, this list covers only non-EU third countries, so an EU member state cannot appear on it. (3) OECD: Greece is one of the OECD's 38 member countries. |
| Uruguaychecked 2026-09-13 | IRAE (Impuesto a las Rentas de las Actividades Económicas) — flat 25% on net fiscal income. Título 4 (IRAE) of Uruguay's consolidated tax code (Texto Ordenado), Capítulo III (Alícuota), Artículo 23: 'La tasa del impuesto será del 25% (veinticinco por ciento) sobre la renta neta fiscal.' | Uruguay's baseline is territorial. IRAE Título 4 Art. 7 (Fuente uruguaya), as substituted by Ley 20.095 (2022-12-07), taxes as Uruguay-source only 'rentas provenientes de actividades desarrolladas, bienes situados o derechos utilizados económicamente en la República' — Uruguay-source income only, regardless of the parties' nationality/domicile/residence. That baseline narrows only for entities belonging to a Multinational Group: Art. 7 numerals 6-7 pull into the Uruguay tax base certain FOREIGN-source passive income (IP/software royalties not meeting the 'ingresos calificados' nexus test of Art. 7 Bis, plus foreign real-estate yields, dividends, interest, other royalties, and related capital gains/patrimony increases) earned by a group entity that is not a 'qualified entity' with adequate economic substance under Art. 7 Ter (see economic_substance_rules). A parallel, narrower carve-in applies on the individual side: IRPF Título 7 Art. 6 (Aspecto espacial) taxes Uruguay-resident individuals not only on Uruguay-source income but also on foreign-source capital yields (dividends/interest) from non-resident entities and related capital gains on those assets (Art. 6 num. 2, most recently amended by Ley 20.446 of 2025-12-16). | IRPF Categoría II (rentas del trabajo) — progressive annual schedule under Título 7 Art. 48: exempt up to 84 BPC; 10% (84-120 BPC); 15% (120-180 BPC); 24% (180-360 BPC); 25% (360-600 BPC); 27% (600-900 BPC); 31% (900-1,380 BPC); top marginal rate 36% above 1,380 BPC of annual computable income (individual filers). A separate, higher-threshold schedule applies to opting family units (núcleos familiares). | IRPF Categoría I (capital income, which by definition includes 'incrementos patrimoniales' / capital gains) is taxed via a schedular rate table at Título 7 Art. 37: the general/residual rate — which covers incrementos patrimoniales/capital gains not otherwise itemized — is 12% ('Restantes Rentas'). Narrow preferential 7% rates apply only to: dividends/utilidades paid by IRAE taxpayers out of IRAE-taxed profit (and fictitious dividends under Art. 19); copyright royalties; and one specific Art. 6 num.2 / Art. 24 cross-referenced category. Interest on qualifying publicly-offered, exchange-listed instruments gets tiered rates from 0.5% to 12% depending on currency and term. For IRAE (corporate) taxpayers, gains are not separately scheduled: Título 4's general renta-bruta principle (Art. 24) folds them into ordinary business income taxed at the flat 25% IRAE rate — this corporate-side characterization rests on the general-principle article's broad wording rather than a dedicated capital-gains article, and a full-text search of Título 4 for a distinct capital-gains carve-out was not exhaustively performed this session. | Impuesto al Patrimonio (net wealth tax) applies to individuals: non-taxable minimum UYU 6,653,000 (individuals/undivided estates) or UYU 13,306,000 (family groups) for 2025. Residents above the minimum: 0.10%. Non-residents (not electing IRNR): progressive 0.70% (UYU 6.653.000-13.306.000) up to 1.50% (above UYU 33.265.000). Uruguay has no separate general inheritance/estate tax. | Election available to individuals acquiring Uruguayan fiscal residency (per the DGI's current published terms, from 2020-01-01 onward) to be taxed, on capital income (interest and dividends) from non-resident entities only, either under IRNR for the year of residency change plus the following 10 fiscal years, or under IRPF at a flat 7% rate with no time limit -- a one-time, mutually exclusive election. | No investment threshold for the base 10-year IRNR election or the uncapped 7% IRPF election. A separate EXTENSION of the IRNR election to a full 10 years (Law 19.937) requires: real-estate investment in Uruguay exceeding UI 3,500,000, AND physical presence of at least 60 calendar days per year. | Uruguay has no freestanding 'economic substance act' of the classic zero-tax-haven type. Substance is embedded directly in the IRAE territorial-source rules: Ley 20.095 (2022-12-07) added Art. 7 Ter to Título 4, defining when a Multinational-Group entity is a 'qualified entity' whose foreign-source passive income (Art. 7 nums. 6-7: IP/software royalties, dividends, interest, real estate yields, related capital gains) stays outside the Uruguay tax base. 'Adequate economic substance' requires meeting, simultaneously: (a) human resources appropriate in number/qualification/pay to manage the investment assets, with adequate facilities, in Uruguay; (b) strategic decisions taken and risk borne in Uruguay; (c) adequate expenses/costs relative to acquisition/holding/disposal. Conditions (a)-(b) can be met via Uruguay-based third-party outsourcing under the entity's supervision; conditions (b)-(c) don't apply to entities whose main activity is holding equity participations or real estate. An annual sworn declaration to DGI is required to substantiate the claim. | Uruguay has enacted a Qualified Domestic Minimum Top-up Tax (QDMTT) — the 'Impuesto Mínimo Complementario Doméstico' (IMCD) — as a new Título 21 of the consolidated tax code, created by Ley 20.446 (Ley de Presupuesto Nacional 2025-2029), promulgated 2025-12-16 (confirmed on the IMPO page itself: 'Promulgación: 16/12/2025'). Art. 1: 'Créase un impuesto anual que gravará las rentas obtenidas por las entidades constitutivas de un grupo multinacional... IMCD.' Art. 2: triggered whenever the group's effective tax rate in Uruguay is below 15%. Art. 3: applies to Uruguay-located constituent entities of a multinational group whose ultimate parent's consolidated annual revenue is >= EUR 750,000,000 in at least 2 of the 4 preceding fiscal years. Mechanics track the OECD GloBE Model Rules closely (substance-based income exclusion Art.16, payroll/tangible-asset carve-outs Arts.17-18, de minimis exclusion Art.23, safe harbors Art.72, explicit Art.74 compatibility clause with 'las Reglas Globales Anti Erosión de las Bases Imponibles del Marco Inclusivo'). No Income Inclusion Rule (IIR) or Undertaxed Profits Rule (UTPR) provisions were found within this consolidated title's 76-article index/body reviewed this session — Título 21 legislates the domestic minimum top-up-tax (QDMTT) layer only, consistent with independent professional reporting (Andersen, RSM, Baker Tilly Uruguay) describing only the IMCD, not an IIR/UTPR, as Uruguay's Pillar Two response. | 25 double tax treaties (Convenios para evitar la Doble Imposición, CDI) currently in force, per DGI's own official CDI-status tracker: Germany (Ley 18.844, in force 2012-01-01), Argentina (Ley 19.032, 2013-02-07), Belgium (Ley 19.403, 2018-01-01), Brazil (Ley 20.009, 2024-01-01), Chile (Ley 19.548, 2019-01-01), South Korea (Ley 19.033, 2014-01-01), Ecuador (Ley 18.932, 2013-01-01), UAE (Ley 19.393, 2017-01-01), Spain (Ley 18.730, 2012-01-01), Finland (Ley 19.035, 2014-01-01), Hungary (Ley 16.366, 1994-01-01), India (Ley 18.972, 2014-01-01), Italy (Ley 19.819, 2021-01-01), Japan (Ley 19.938, 2022-01-01), Liechtenstein (Ley 18.933, 2013-01-01), Luxembourg (Ley 19.354, 2018-01-01), Malta (Ley 19.010, 2013-01-01), Mexico (Ley 18.645, 2011-01-01), Paraguay (Ley 19.697, 2020-01-01), Portugal (Ley 18.934, 2012-09-13), United Kingdom (Ley 19.443, 2017-01-01), Romania (Ley 19.257, 2015-01-01), Singapore (Ley 19.457, 2018-01-01), Switzerland (Ley 18.867, 2012-01-01), Vietnam (Ley 19.404, 2017-01-01). Plus 1 signed but not yet in force: Colombia (signed 2021-11-19, no ratifying law yet). Most treaties are further modified by the OECD Multilateral Instrument (MLI) where the tracker marks 'SI'. | Unverified (no primary source yet) |
| Panamachecked 2026-09-13 | 25% standard corporate rate ('Personas Jurídicas'), in effect from fiscal period 2011 onward per the DGI's own published rate-history table (prior rates: 30% from 2010, 27.5% from 2012, 25% from 2014 onward per a parallel rate schedule referenced on the same page — the two schedules together confirm 25% has been the stable current rate for over a decade). | Panama operates a territorial income tax system, confirmed directly from DGI's own ISR guidance page: taxable income equals total income minus exempt/non-taxable income AND minus foreign-source income ('ingresos de fuente extranjera') -- foreign-source income is excluded from the tax base entirely, not merely exempted after inclusion. Correspondingly, costs/expenses tied to producing foreign-source or exempt income are not deductible against the domestic (Panama-source) taxable base. Distributed profits are subject to a separate dividend/participation-quota tax: 10% when the underlying profits are Panama-source, but a reduced 5% when the distributed profits derive from income that is itself exempt from income tax (Codigo Fiscal Art. 708 literales f) and l)), from foreign-source income, and/or from export income (Art. 106, Decreto Ejecutivo No. 98 of 2010-09-28). | 25% marginal rate on net taxable income exceeding B/.50,000 (progressive: 0% up to B/.11,000; 15% marginal from B/.11,001-B/.50,000; 25% marginal above B/.50,000, i.e. B/.5,850 on the first B/.50,000 plus 25% of the excess). | Unverified (no primary source yet) | none | Not yet researched | Not yet researched | Ley 926 de 2026 (approved on third debate 2026-05-27 as Proyecto 641 de 2026; published Gaceta Oficial Digital No. 30534-B, 2026-05-28) adds a new Capitulo II ('Reglas de Sustancia Economica para Rentas Pasivas de Fuente Extranjera', Arts. 707-A to 707-N over the Gaceta's own lettering) to Titulo I, Libro IV of the Codigo Fiscal. It requires Panama-constituted/domiciled entities that are members of a multinational group ('grupo multinacional') and that receive specified foreign-source passive income -- dividends/profit shares, interest, royalties, capital gains, real-estate capital income, and other movable-capital income (Art. 707-C) -- to demonstrate adequate economic substance in Panama (qualified human resources; Panama-based strategic decision-making; adequate Panama-based operating expenditure) in order for that foreign-source passive income to keep its ordinary territorial-system tax-exempt treatment. Pure passive-holding entities (non-habitual acquisition/disposal of equity participations, no substantial commercial/investment activity) and pure real-estate-holding entities are relieved of the decision-making/opex substance prongs but must still meet the human-resources prong and reporting obligations; outsourcing of substance activities to a Panama-based third-party provider is permitted under conditions. An entity that fails to report or fails to meet the substance conditions ('entidad no calificada') is instead taxed on that foreign-source passive income at a flat, single and definitive 15% rate on net taxable income, plus applicable fines/surcharges/interest, with a foreign-tax credit available for tax already paid abroad on the same income. Regulated financial-sector entities (banks, insurers/reinsurers, securities-market intermediaries, licensed fund/pension managers) are excluded from the substance regime for passive income directly tied to their regulated activity, subject to conditions (duly licensed/supervised; income genuinely tied to the regulated business; effective management retained in Panama; captive insurers/reinsurers within a multinational group are carved OUT of this exclusion). The law also adds paragraph 7 to Art. 710 and amends Art. 762-M (permanent establishment) of the Codigo Fiscal. The Executive Branch must issue implementing regulations within 90 calendar days of enactment (Art. 4). | Not yet researched | 17 double taxation agreements listed under DGI's own 'Convenios de Doble Imposicion' page, naming: Barbados, South Korea, United Arab Emirates, Ireland, Israel, Italy, Luxembourg, Netherlands, Portugal, Qatar, United Kingdom, Czech Republic, Singapore, Spain, France, Mexico, and Vietnam. Each entry links to a signed treaty-text PDF (Spanish, several also in English) hosted in DGI's own /Internacional/CONVENIOS/ directory. This resolves and corrects the prior pass's finding of 'at least 15... 2 further entries truncated/unresolved' -- all entries are now fully named with zero truncation. | Not listed on either the FATF black list or grey list as of the current published list (removed from the grey list October 2023). Currently LISTED on the EU's Annex I (non-cooperative jurisdictions for tax purposes) per the 17 February 2026 Council/Commission update. |
| United Arab Emirates — Mainlandchecked 2026-09-13 | Federal Corporate Tax under Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses (issued 9 December 2022; applies to Tax Periods/financial years beginning on or after 1 June 2023): Article 3(1) sets the rate at 0% on the portion of Taxable Income not exceeding a Cabinet-specified amount, and 9% above it. Cabinet Decision No. 116 of 2022 fixed that amount at AED 375,000, as reported on MOF's own site: '0% rate will apply to taxable income that does not exceed AED375,000... A 9% rate will apply to taxable income exceeding AED 375,000.' | Qualifying Free Zone Person (QFZP) regime: a Free Zone Person meeting registration/activity/transfer-pricing conditions retains a 0% Corporate Tax rate on Qualifying Income (mainland-sourced non-qualifying income taxed at the standard 9% rate above the threshold); a de minimis rule preserves QFZP status if non-qualifying income stays below the lower of 5% of total revenue or AED 5 million. | 0% -- the UAE levies no general personal income tax. Federal Decree-Law No. 47 of 2022, Art. 11(3)(c) and Art. 12(2), makes a natural person a taxable ('Resident') Person -- and taxes them -- only with respect to income from a 'Business or Business Activity' conducted in the UAE, not on wages or passive/investment income generally. Cabinet Decision No. 49 of 2023, Art. 2(2)(a), further confirms that 'Wage' income is excluded from Corporate Tax entirely, 'regardless of the amount of Turnover.' No separate individual/personal income tax statute exists at the federal level: the UAE Legislation portal's complete Tax-sector legislative index (40 currently enacted instruments) lists only Corporate Tax, Tax Procedures, VAT, Excise Tax and Top-up Tax (Pillar Two) legislation and their implementing decisions. | No standalone capital gains tax. (1) Individuals: gains from 'Personal Investment' activity (investment a natural person conducts for their own account, not through a licence and not a commercial business) and from 'Real Estate Investment' (sale/lease/sub-lease/rent of UAE land or property not requiring a licence) are excluded from Corporate Tax outright, 'regardless of the amount of Turnover' -- Cabinet Decision No. 49 of 2023, Art. 1 definitions + Art. 2(2)(b)-(c). (2) Juridical (corporate) persons: gains are ordinarily folded into Taxable Income and taxed at the standard 0%/9% rates, EXCEPT gains on a qualifying 'Participating Interest' (5%+ ownership, held or intended to be held for an uninterrupted 12+ months, in an entity subject to a comparable tax abroad, meeting further conditions in Art. 23(2)), which are exempt under the Article 23 Participation Exemption. | No wealth tax and no inheritance/estate tax at the federal level. The UAE Legislation portal's Tax-sector legislative index -- the government's own authoritative enumeration of all currently enacted Tax-sector legislation (40 instruments: 1 Federal Law, 4 Federal Decree-Laws, 31 Cabinet Resolutions (Regulatory), 3 Cabinet Resolutions (Implementing Regulations), 1 Ministerial Resolution) -- lists only Corporate Tax, Tax Procedures, VAT, Excise Tax, and Top-up Tax (Pillar Two) legislation and their implementing decisions; no wealth, estate, or inheritance tax instrument appears. The sector's own description confirms this scope. Corroborated by MOF's own site taxonomy (Tax menu: VAT / Corporate Tax / Top-up Tax only), reviewed in full across three separately-fetched MOF pages (Corporate Tax overview, ESR, DTAs) this session. Sharia-based succession defaults for Muslim decedents and free-zone wills registries are a distinct civil-succession topic, not a tax, and are not addressed by this cell. | None. The UAE has no personal-income-tax-based 'new resident' regime (of the kind seen in Switzerland's Pauschalbesteuerung, Cyprus non-dom, or Italy's Art. 24-bis), because it levies no general personal income tax to grant relief from in the first place. Cabinet Decision No. 49 of 2023, Art. 2(1)-(2), taxes a natural person's Business/Business Activity Turnover above AED 1,000,000/year the same way regardless of how long that person has been UAE-resident, and Wage/Personal Investment/Real Estate Investment income are excluded outright -- there is no residency-tenure-based threshold, election, or preferential rate for newly-arrived individuals. | Not applicable -- see new_resident_special_regime. The UAE has no residency-tenure-based individual tax regime to which a threshold or fee could attach. | Economic Substance Regulations (ESR) reporting/notification requirements CANCELLED for financial years ending after 2022-12-31, per Cabinet Decision No. (98) of 2024 amending Cabinet Decision No. (57) of 2020 — the Ministry stated this aligns ESR with the new federal corporate tax system; entities remain responsible for prior-year compliance obligations and any pre-existing penalties. | Domestic Minimum Top-up Tax (DMTT) in force for financial years starting on/after 2025-01-01, per Cabinet Decision No. 142 of 2024, closely aligned with OECD GloBE Model Rules (obtained OECD Transitional Qualified Status). Applies to MNE Constituent Entities with consolidated group revenue >= EUR 750 million in at least 2 of the preceding 4 years. UAE has NOT adopted the Income Inclusion Rule (IIR) or Undertaxed Profits Rule (UTPR) — DMTT only. | 137 double taxation agreements concluded, per MOF's own count. | Not listed — absent from FATF's 'Jurisdictions under Increased Monitoring' as of the 13 February 2026 publication (removed 2024-02-23). Not listed on the EU's current Annex I/Annex II (17 February 2026 update); UAE historically appeared on this list in an earlier period per the same historical-timeline document, but is absent from the current snapshot. |
| United Arab Emirates — DIFCchecked 2026-09-13 | Shared UAE federal baseline: 0% on taxable income not exceeding AED 375,000; 9% above that threshold. Effective for financial years starting on or after 2023-06-01 (Cabinet Decision No. 116 of 2022 confirming the threshold). | Free-zone-specific: DIFC is a Designated/Qualifying Free Zone; a Qualifying Free Zone Person (QFZP) can access a 0% Corporate Tax rate on Qualifying Income (non-qualifying income taxed at the standard 9%). | 0% -- the UAE levies no general personal income tax, uniformly across the whole country including DIFC. Federal Decree-Law No. 47 of 2022, Art. 11(3)(c) and Art. 12(2), makes a natural person a taxable ('Resident') Person -- and taxes them -- only with respect to income from a 'Business or Business Activity' conducted in the UAE, not on wages or passive/investment income generally. Cabinet Decision No. 49 of 2023, Art. 2(2)(a), further confirms that 'Wage' income is excluded from Corporate Tax entirely, 'regardless of the amount of Turnover.' No separate individual/personal income tax statute exists at the federal level: the UAE Legislation portal's complete Tax-sector legislative index (40 currently enacted instruments) lists only Corporate Tax, Tax Procedures, VAT, Excise Tax and Top-up Tax (Pillar Two) legislation and their implementing decisions. This is a federal, not free-zone-specific, rule and applies identically to DIFC. | No standalone capital gains tax, uniformly across the UAE including DIFC. (1) Individuals: gains from 'Personal Investment' activity and from 'Real Estate Investment' are excluded from Corporate Tax outright, 'regardless of the amount of Turnover' -- Cabinet Decision No. 49 of 2023, Art. 1 + Art. 2(2)(b)-(c). (2) Juridical (corporate) persons, including a DIFC entity: gains are ordinarily folded into Taxable Income and taxed at the standard rates (0%/9%, or the QFZP 0%/9% split if the entity is a Qualifying Free Zone Person), EXCEPT gains on a qualifying 'Participating Interest' (5%+ ownership, 12+ months held/intended, comparable-tax test), which are exempt under the Article 23 Participation Exemption. | No wealth tax and no inheritance/estate tax at the federal level; applies uniformly to DIFC. The UAE Legislation portal's Tax-sector legislative index (40 currently enacted instruments) lists only Corporate Tax, Tax Procedures, VAT, Excise Tax and Top-up Tax legislation and their implementing decisions; no wealth, estate, or inheritance tax instrument appears. Corroborated by MOF's own site taxonomy (Tax menu: VAT / Corporate Tax / Top-up Tax only). DIFC separately operates its own optional Wills Service and DIFC Probate Registry for civil-law-style succession of assets -- a civil-succession mechanism, not a tax, and not addressed by this cell. | None. The UAE has no personal-income-tax-based 'new resident' regime, because it levies no general personal income tax to grant relief from in the first place. Cabinet Decision No. 49 of 2023, Art. 2(1)-(2), taxes a natural person's Business/Business Activity Turnover above AED 1,000,000/year the same way regardless of how long that person has been UAE-resident; individual tax residency and CT scope are not free-zone-specific, so this does not vary for DIFC. | Not applicable -- see new_resident_special_regime. No residency-tenure-based individual tax regime exists to which a threshold or fee could attach. | Federal Economic Substance Regulations (ESR) apply UAE-wide -- mainland and every free zone alike, including DIFC -- by activity type, not by Emirate or registry identity. Introduced by Cabinet of Ministers Resolution No. 31 of 2019 (30 April 2019), superseded by Cabinet of Ministers Resolution No. 57 of 2020 (10 August 2020), most recently amended by Cabinet of Ministers Resolution No. 98 of 2024. An entity carrying out a defined 'Relevant Activity' (Banking, Insurance, Investment Fund Management, Lease-Finance, Headquarters, Shipping, Holding Company, Intellectual Property, or Distribution & Service Centre business) must maintain adequate 'economic presence' in the UAE and, within 12 months of financial year-end, file an annual Notification (and, unless exempt, an Economic Substance Report) with its regulatory authority. No DIFC-specific carve-out or variant from the federal ESR regime was found in the source reviewed. | UAE Domestic Minimum Top-up Tax (DMTT) in force from 2025, applying to in-scope MNE groups (consolidated revenue >= EUR 750 million). | 137 Double Taxation Agreements (DTAs) concluded by the UAE 'with most of its major trading partners,' per MOF's own count; combined with Bilateral Investment Treaties (BITs), the total network is 193 agreements. This is federal, not free-zone-specific -- a DIFC entity accesses the same DTA network as any other UAE tax resident, subject to obtaining a Tax Residency Certificate and meeting each treaty's own conditions (not addressed by this cell). | Not on the FATF 'grey list' (Jurisdictions under Increased Monitoring) as of the current 19 June 2026 update -- the UAE does not appear anywhere in the full list of jurisdictions under review (Algeria, Angola, Bolivia, Bosnia and Herzegovina, Bulgaria, Cameroon, Cote d'Ivoire, DR Congo, Haiti, Iraq, Kenya, Kuwait, Lao PDR, Lebanon, Monaco, Namibia, Nepal, Papua New Guinea, South Sudan, Syria, Venezuela, Vietnam, Virgin Islands (UK), Yemen). UAE was removed from this list on 23 February 2024 and has not reappeared since. Not on the EU list of non-cooperative jurisdictions for tax purposes -- absent from both the current Annex I (10 jurisdictions) and Annex II (9 jurisdictions) as of the 17 February 2026 update; the same document's own historical timeline shows the UAE briefly appeared on Annex I earlier (2019) before being removed, and has not reappeared since. This is a jurisdiction-level (UAE-wide) determination, not free-zone-specific. |
| United Arab Emirates — ADGMchecked 2026-09-13 | Shared UAE federal baseline: 0% on taxable income not exceeding AED 375,000; 9% above that threshold. Effective for financial years starting on or after 2023-06-01 (Cabinet Decision No. 116 of 2022 confirming the threshold). | Free-zone-specific: ADGM is a Designated/Qualifying Free Zone; a Qualifying Free Zone Person (QFZP) can access a 0% Corporate Tax rate on Qualifying Income (non-qualifying income taxed at the standard 9%). | 0% -- the UAE levies no general personal income tax, uniformly across the whole country including ADGM. Federal Decree-Law No. 47 of 2022, Art. 11(3)(c) and Art. 12(2), makes a natural person a taxable ('Resident') Person -- and taxes them -- only with respect to income from a 'Business or Business Activity' conducted in the UAE, not on wages or passive/investment income generally. Cabinet Decision No. 49 of 2023, Art. 2(2)(a), further confirms that 'Wage' income is excluded from Corporate Tax entirely, 'regardless of the amount of Turnover.' No separate individual/personal income tax statute exists at the federal level: the UAE Legislation portal's complete Tax-sector legislative index (40 currently enacted instruments) lists only Corporate Tax, Tax Procedures, VAT, Excise Tax and Top-up Tax (Pillar Two) legislation and their implementing decisions. This is a federal, not free-zone-specific, rule and applies identically to ADGM. | No standalone capital gains tax, uniformly across the UAE including ADGM. (1) Individuals: gains from 'Personal Investment' activity and from 'Real Estate Investment' are excluded from Corporate Tax outright, 'regardless of the amount of Turnover' -- Cabinet Decision No. 49 of 2023, Art. 1 + Art. 2(2)(b)-(c). (2) Juridical (corporate) persons, including an ADGM entity: gains are ordinarily folded into Taxable Income and taxed at the standard rates (0%/9%, or the QFZP 0%/9% split if the entity is a Qualifying Free Zone Person), EXCEPT gains on a qualifying 'Participating Interest' (5%+ ownership, 12+ months held/intended, comparable-tax test), which are exempt under the Article 23 Participation Exemption. | No wealth tax and no inheritance/estate tax at the federal level; applies uniformly to ADGM. The UAE Legislation portal's Tax-sector legislative index (40 currently enacted instruments) lists only Corporate Tax, Tax Procedures, VAT, Excise Tax and Top-up Tax legislation and their implementing decisions; no wealth, estate, or inheritance tax instrument appears. Corroborated by MOF's own site taxonomy (Tax menu: VAT / Corporate Tax / Top-up Tax only). ADGM separately operates its own common-law probate/succession framework (ADGM Courts) for civil-law-style succession of assets -- a civil-succession mechanism, not a tax, and not addressed by this cell. | None. The UAE has no personal-income-tax-based 'new resident' regime, because it levies no general personal income tax to grant relief from in the first place. Cabinet Decision No. 49 of 2023, Art. 2(1)-(2), taxes a natural person's Business/Business Activity Turnover above AED 1,000,000/year the same way regardless of how long that person has been UAE-resident; individual tax residency and CT scope are not free-zone-specific, so this does not vary for ADGM. | Not applicable -- see new_resident_special_regime. No residency-tenure-based individual tax regime exists to which a threshold or fee could attach. | Federal Economic Substance Regulations (ESR) apply UAE-wide -- mainland and every free zone alike, including ADGM -- by activity type, not by Emirate or registry identity. Introduced by Cabinet of Ministers Resolution No. 31 of 2019 (30 April 2019), superseded by Cabinet of Ministers Resolution No. 57 of 2020 (10 August 2020), most recently amended by Cabinet of Ministers Resolution No. 98 of 2024. An entity carrying out a defined 'Relevant Activity' (Banking, Insurance, Investment Fund Management, Lease-Finance, Headquarters, Shipping, Holding Company, Intellectual Property, or Distribution & Service Centre business) must maintain adequate 'economic presence' in the UAE and, within 12 months of financial year-end, file an annual Notification (and, unless exempt, an Economic Substance Report) with its regulatory authority. No ADGM-specific carve-out or variant from the federal ESR regime was found in the source reviewed. | UAE Domestic Minimum Top-up Tax (DMTT) in force from 2025, applying to in-scope MNE groups (consolidated revenue >= EUR 750 million). | 137 Double Taxation Agreements (DTAs) concluded by the UAE 'with most of its major trading partners,' per MOF's own count; combined with Bilateral Investment Treaties (BITs), the total network is 193 agreements. This is federal, not free-zone-specific -- an ADGM entity accesses the same DTA network as any other UAE tax resident, subject to obtaining a Tax Residency Certificate and meeting each treaty's own conditions (not addressed by this cell). | Not on the FATF 'grey list' (Jurisdictions under Increased Monitoring) as of the current 19 June 2026 update -- the UAE does not appear anywhere in the full list of jurisdictions under review (Algeria, Angola, Bolivia, Bosnia and Herzegovina, Bulgaria, Cameroon, Cote d'Ivoire, DR Congo, Haiti, Iraq, Kenya, Kuwait, Lao PDR, Lebanon, Monaco, Namibia, Nepal, Papua New Guinea, South Sudan, Syria, Venezuela, Vietnam, Virgin Islands (UK), Yemen). UAE was removed from this list on 23 February 2024 and has not reappeared since. Not on the EU list of non-cooperative jurisdictions for tax purposes -- absent from both the current Annex I (10 jurisdictions) and Annex II (9 jurisdictions) as of the 17 February 2026 update; the same document's own historical timeline shows the UAE briefly appeared on Annex I earlier (2019) before being removed, and has not reappeared since. This is a jurisdiction-level (UAE-wide) determination, not free-zone-specific. |
| United Arab Emirates — RAK ICCchecked 2026-09-13 | Federal Corporate Tax applies to a RAK ICC entity as it does to any other UAE-incorporated juridical person. Federal Decree-Law No. 47 of 2022, Art. 11(3)(a), makes 'a juridical person that is incorporated... under the applicable legislation of the State, including a Free Zone Person' a Resident (taxable) Person -- so a RAK ICC company is a Resident Person, not categorically exempt. Two rate paths then apply depending on Free-Zone-for-Corporate-Tax-purposes/Qualifying-Free-Zone-Person (QFZP) status (see cit_territorial_or_exempt_regime -- which path actually governs a RAK ICC entity was not resolved this session): (a) under the ordinary rules, Art. 3(1): 0% on Taxable Income up to AED 375,000 (per Cabinet Decision No. 116 of 2022), 9% above; (b) if the entity is a QFZP, Art. 3(2) and the FTA's own Free Zone Persons bulletin apply instead: 0% on Qualifying Income only, and 9% on ALL other Taxable Income, with NO AED 375,000 threshold. | Not yet researched | 0% -- the UAE levies no general personal income tax, uniformly across the whole country including RAK ICC. Federal Decree-Law No. 47 of 2022, Art. 11(3)(c) and Art. 12(2), makes a natural person a taxable ('Resident') Person -- and taxes them -- only with respect to income from a 'Business or Business Activity' conducted in the UAE, not on wages or passive/investment income generally. Cabinet Decision No. 49 of 2023, Art. 2(2)(a), further confirms that 'Wage' income is excluded from Corporate Tax entirely, 'regardless of the amount of Turnover.' No separate individual/personal income tax statute exists at the federal level: the UAE Legislation portal's complete Tax-sector legislative index (40 currently enacted instruments) lists only Corporate Tax, Tax Procedures, VAT, Excise Tax and Top-up Tax (Pillar Two) legislation and their implementing decisions. This is a federal, not free-zone-specific, rule and applies identically to RAK ICC. | No standalone capital gains tax, uniformly across the UAE including RAK ICC. (1) Individuals: gains from 'Personal Investment' activity and from 'Real Estate Investment' are excluded from Corporate Tax outright, 'regardless of the amount of Turnover' -- Cabinet Decision No. 49 of 2023, Art. 1 + Art. 2(2)(b)-(c). (2) Juridical (corporate) persons, including a RAK ICC entity: gains are ordinarily folded into Taxable Income and taxed at the standard rates (0%/9%, or the QFZP 0%/9% split if the entity is a Qualifying Free Zone Person -- see cit_headline/cit_territorial_or_exempt_regime), EXCEPT gains on a qualifying 'Participating Interest' (5%+ ownership, 12+ months held/intended, comparable-tax test), which are exempt under the Article 23 Participation Exemption. | No wealth tax and no inheritance/estate tax at the federal level; applies uniformly to RAK ICC. The UAE Legislation portal's Tax-sector legislative index (40 currently enacted instruments) lists only Corporate Tax, Tax Procedures, VAT, Excise Tax and Top-up Tax legislation and their implementing decisions; no wealth, estate, or inheritance tax instrument appears. Corroborated by MOF's own site taxonomy (Tax menu: VAT / Corporate Tax / Top-up Tax only). | None. The UAE has no personal-income-tax-based 'new resident' regime, because it levies no general personal income tax to grant relief from in the first place. Cabinet Decision No. 49 of 2023, Art. 2(1)-(2), taxes a natural person's Business/Business Activity Turnover above AED 1,000,000/year the same way regardless of how long that person has been UAE-resident; individual tax residency and CT scope are not free-zone-specific, so this does not vary for RAK ICC. | Not applicable -- see new_resident_special_regime. No residency-tenure-based individual tax regime exists to which a threshold or fee could attach. | Federal Economic Substance Regulations (ESR) apply UAE-wide -- mainland and every free zone alike, including RAK ICC -- by activity type, not by Emirate or registry identity. Introduced by Cabinet of Ministers Resolution No. 31 of 2019 (30 April 2019), superseded by Cabinet of Ministers Resolution No. 57 of 2020 (10 August 2020), most recently amended by Cabinet of Ministers Resolution No. 98 of 2024. An entity carrying out a defined 'Relevant Activity' (Banking, Insurance, Investment Fund Management, Lease-Finance, Headquarters, Shipping, Holding Company, Intellectual Property, or Distribution & Service Centre business) must maintain adequate 'economic presence' in the UAE and, within 12 months of financial year-end, file an annual Notification (and, unless exempt, an Economic Substance Report) with its regulatory authority. No RAK-ICC-specific carve-out or variant from the federal ESR regime was found in the source reviewed. | UAE Domestic Minimum Top-up Tax (DMTT) in force from 2025, applying to in-scope MNE groups (consolidated revenue >= EUR 750 million) -- a jurisdiction-level status; most individual/small-group RAK ICC holding vehicles would fall well under this threshold in practice, but that is an entity-level applicability question distinct from the jurisdiction-level status recorded here. | 137 Double Taxation Agreements (DTAs) concluded by the UAE 'with most of its major trading partners,' per MOF's own count; combined with Bilateral Investment Treaties (BITs), the total network is 193 agreements. This is federal, not free-zone-specific -- whether a RAK ICC entity itself can claim treaty benefits (a Tax Residency Certificate question, likely bound up with the same Free-Zone/QFZP status question flagged in cit_territorial_or_exempt_regime) was not addressed by this cell. | Not on the FATF 'grey list' (Jurisdictions under Increased Monitoring) as of the current 19 June 2026 update -- the UAE does not appear anywhere in the full list of jurisdictions under review (Algeria, Angola, Bolivia, Bosnia and Herzegovina, Bulgaria, Cameroon, Cote d'Ivoire, DR Congo, Haiti, Iraq, Kenya, Kuwait, Lao PDR, Lebanon, Monaco, Namibia, Nepal, Papua New Guinea, South Sudan, Syria, Venezuela, Vietnam, Virgin Islands (UK), Yemen). UAE was removed from this list on 23 February 2024 and has not reappeared since. Not on the EU list of non-cooperative jurisdictions for tax purposes -- absent from both the current Annex I (10 jurisdictions) and Annex II (9 jurisdictions) as of the 17 February 2026 update; the same document's own historical timeline shows the UAE briefly appeared on Annex I earlier (2019) before being removed, and has not reappeared since. This is a jurisdiction-level (UAE-wide) determination -- not RAK-ICC-specific. |
| Singaporechecked 2026-09-13 | Flat 17% corporate income tax rate on chargeable income, for both local and foreign companies. Budget 2026 grants a CIT Rebate of 40% of tax payable for YA 2026 (enhanced to 50% per a later cashflow-support update referenced on the same page). | Not purely territorial — a remittance-basis system layered with statutory exemptions. Singapore-sourced income is always taxable. Foreign-sourced income is taxable only when received/remitted into Singapore, EXCEPT foreign income accruing from a trade or business carried on in Singapore, which is taxed on accrual regardless of remittance. On top of this, specified foreign-sourced dividends, foreign branch profits and foreign-sourced service income received by a Singapore tax-resident company are exempt from tax under Section 13(8) of the Income Tax Act 1947 (generally regardless of remittance, subject to conditions), with further exemptions for specified scenarios under Section 13(12). Separately, at the domestic-income level, new companies get the Start-Up Tax Exemption (first 3 YAs) and all companies get the Partial Tax Exemption on normal chargeable income. | Highest personal income tax rate for resident individuals is 24% (progressive, YA2024 onwards schedule). | No general capital gains tax. IRAS states plainly that capital gains (e.g. gains on sale of fixed assets, gains on foreign exchange on capital transactions) are not taxable. The one carve-out: under Section 10L of the Income Tax Act 1947 (effective 1 Jan 2024), certain gains from the sale/disposal of foreign assets ARE treated as income chargeable to tax when received in Singapore by an in-scope entity — but this does not apply if the entity has adequate economic substance in Singapore (confirmed via IRAS's advance-ruling process), and does not apply to intellectual property rights disposals or to disposals carried out as part of/incidental to the entity's business operations. | No inheritance/estate tax and no general net-wealth tax. Estate Duty (Singapore's estate/inheritance-type tax) was abolished for deaths on and after 15 February 2008, per IRAS. Singapore has never levied a general net-worth/wealth tax; it does not appear anywhere in IRAS's enumerated 'Other Taxes' category (Estate Duty, Stamp Duty, Trusts, Betting/casino taxes, etc.), which was checked directly on the fetched Estate Duty page and its site navigation. | None currently active. Singapore's only new-resident special income-tax regime, the Not Ordinarily Resident (NOR) scheme, has ceased. The last NOR status was granted for YA2020, valid through YA2024; individuals under that final cohort's concession window have now lapsed (YA2024 was the last eligible year). No new NOR applications have been accepted since. Singapore has no other special flat-tax/tax-holiday regime for new residents; the Global Investor Programme (GIP) is a Permanent-Residence-by-investment immigration scheme administered by EDB/Contact Singapore, not a tax concession. | Not applicable in current form — the NOR scheme itself is discontinued (see new_resident_special_regime). While it was active, the scheme was not fee-based: its main benefit, the time-apportionment concession on Singapore employment income, required 'total Singapore employment income must be at least $160,000' (S$160,000) as an income-eligibility floor — not a lump-sum application fee. This should not be confused with the separate, non-tax Global Investor Programme (GIP), which sets PR-by-investment minimums of S$10 million (Option A: new/expanded Singapore business), S$25 million (Option B: GIP-select fund), or S$200 million AUM with S$50 million deployed in Singapore (Option C: single family office) — an immigration-status investment threshold, not a tax-regime fee. | No dedicated, freestanding Economic Substance Act (unlike BVI/Cayman-style ESR regimes). Instead, Singapore's 'economic substance' concept is a specific statutory test embedded in Section 10L of the Income Tax Act 1947 (the foreign-sourced disposal gains rule, effective 1 Jan 2024): gains from the sale/disposal of a foreign asset are chargeable to tax when received in Singapore UNLESS the entity has 'adequate economic substance' in Singapore. IRAS operates a formal advance-ruling process for entities seeking certainty on adequacy of economic substance (dedicated ESR application form; a favorable ruling can be valid for up to 5 Years of Assessment). | Multinational Enterprise Top-up Tax (MTT, = Income Inclusion Rule) and Domestic Top-up Tax (DTT) both effective for financial years beginning on/after 2025-01-01, implemented via the Multinational Enterprise (Minimum Tax) Act 2024. Applies to MNE groups with consolidated revenue >= EUR 750 million (met in 2 of the preceding 4 FYs). Minimum effective rate 15%. Online registration opens May 2026; for a 2025-12-31 FY-end group, IRAS registration deadline is 2026-06-30 (10% surcharge on top-up tax if missed). | Approximately 100 jurisdictions, per IRAS's own combined count of Avoidance of Double Taxation Agreements (DTAs), limited DTAs, and Exchange of Information (EOI) Arrangements. IRAS publishes the full itemized list as an interactive/filterable table (filterable by 'In Force' and 'Modified by the MLI' status) rather than as static HTML, so an exact break-out of comprehensive DTAs alone (excluding limited DTAs and EOI-only arrangements) could not be extracted from the fetched page. | Not on the FATF grey list (Jurisdictions under Increased Monitoring) or black list (High-Risk Jurisdictions subject to a Call for Action), as of the FATF's current 19 June 2026 publications. Not on the EU list of non-cooperative jurisdictions for tax purposes (Annex I or Annex II), as of the EU's 17 February 2026 update (the most recent as of this check — the EU's next scheduled update had not yet occurred as of 2026-09-13). |
| Hong Kongchecked 2026-09-13 | Two-tiered profits tax: 8.25% on the first HK$2 million of assessable profits, 16.5% on the remainder, for corporations (7.5%/15% for unincorporated businesses). A one-off 100% profits-tax reduction for YA2025/26 (capped at HK$3,000 per case) was gazetted 2026-05-22. | Hong Kong taxes on a territorial (source) basis. Per the IRD's own statement of the scope of Profits Tax: persons carrying on a trade, profession or business in Hong Kong are chargeable to tax on all profits arising in or derived from Hong Kong from that trade, profession or business, and there is no distinction made between residents and non-residents -- a resident may derive profits from abroad without suffering Hong Kong tax, while a non-resident may suffer tax on profits arising in Hong Kong. Offshore-sourced profits are therefore generally outside the Profits Tax net, subject to the Foreign-Sourced Income Exemption (FSIE) anti-avoidance carve-out for specified passive income of MNE-group entities (see economic_substance_rules). | Hong Kong has no unified general personal income tax; individuals are taxed under Salaries Tax (income from an office, employment or pension) and, separately, Property Tax on rental income. Per the IRD's official 'Allowances, Deductions and Tax Rate Table' (Pamphlet 61(e), current as of August 2026), Salaries Tax/Personal Assessment payable is the LOWER of: (a) progressive rates on net chargeable income -- 2% on the first HK$50,000, 6% on the next HK$50,000, 10% on the next HK$50,000, 14% on the next HK$50,000, and 17% on the remainder (17% is the top marginal progressive rate); or (b) a standard rate applied to net income before allowances -- currently a two-tiered standard rate of 15% on the first HK$5,000,000 of net income and 16% on the remainder. | Hong Kong has no general capital gains tax and no separate capital-gains statute. Profits Tax -- the closest analogue -- is explicitly charged only on trading profits arising in or derived from Hong Kong, EXCLUDING profits arising from the sale of capital assets. Gains of a genuinely capital nature realized by a business, and gains realized by individuals on personal investments (e.g. shares, investment property), fall outside the scope of Hong Kong's three direct taxes (Profits Tax, Salaries Tax, Property Tax). (Gains that are in substance trading profits rather than capital gains remain chargeable under Profits Tax on ordinary badges-of-trade principles; and specified foreign-sourced equity/IP/other-property disposal gains of MNE-group entities can be pulled into charge under the FSIE regime -- see economic_substance_rules.) | No annual net wealth tax. No inheritance/estate tax -- Estate Duty was abolished for deaths occurring on or after 2006-02-11 under the Revenue (Abolition of Estate Duty) Ordinance 2005; no estate duty affidavits, accounts, or clearance papers are required for deaths on or after that date. (A nominal transitional duty of HK$100 applied only to 'transitional estates' of persons dying 2005-07-15 to 2006-02-10 with principal value exceeding HK$7.5 million -- not relevant to any current decedent.) | Unverified (no primary source yet) | Not yet researched | Hong Kong operates a Foreign-Sourced Income Exemption (FSIE) regime targeting passive income of MNE-group entities rather than a discrete standalone 'economic substance act.' The Inland Revenue (Amendment) (Taxation on Specified Foreign-sourced Income) Ordinance 2022, enacted 2022-12-23, brought foreign-sourced dividends, interest, IP income, and equity-interest disposal gains received in Hong Kong by an MNE-group entity into the Profits Tax charge with effect from 2023-01-01, unless the entity satisfies an economic substance requirement, participation requirement, or nexus requirement (as applicable to the income type). The Inland Revenue (Amendment) (Taxation on Foreign-sourced Disposal Gains) Ordinance 2023, enacted 2023-12-08 and effective 2024-01-01, expanded the disposal-gains limb to cover all property types (not just equity interests), implementing the EU's Updated FSIE Guidance, and added an intra-group transfer relief. | Income Inclusion Rule (IIR) and Hong Kong Minimum Top-up Tax (HKMTT) codified by the Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Ordinance 2025, enacted 2025-06-06, effective retrospectively for FYs beginning on/after 2025-01-01. Applies to MNE groups with consolidated revenue >= EUR 750 million. Undertaxed Profits Rule (UTPR) deferred. Mandatory e-filing for in-scope entities begins YA2025/26. | Per the IRD's own 'Comprehensive Double Taxation Agreements concluded' table (61 line-items, parsed programmatically this session from the underlying HTML table rows): Hong Kong has concluded Comprehensive Double Taxation Agreements/Arrangements with 60 distinct jurisdictions. (The table lists a 1998 Mainland-China shipping/aircraft-income arrangement as a separate line, but the table's own Note 5 states it 'has ceased to have effect' since being superseded by the comprehensive 2006 Mainland-China Arrangement -- so 61 raw rows resolve to 60 distinct current-or-pending treaty relationships.) Of these 60, 9 are signed but NOT YET in force as of the fetch date -- Barbados, Cyprus, Jordan, Kyrgyzstan, Maldives, Nigeria, Norway, Rwanda, and Slovenia (all show 'Pending' in the Date-of-Entry-into-Force column) -- leaving 51 CDTAs currently in force. This is a comparatively broad treaty network for the region, though structurally smaller than Singapore's. | Not on the FATF list of Jurisdictions under Increased Monitoring (the 'grey list') per the FATF statement of 19 June 2026 -- 'Hong Kong, China' does not appear among the 21 jurisdictions this specific statement's own page metadata names as currently monitored (Venezuela, Iraq, South Sudan, Nepal, Kuwait, Vietnam, Papua New Guinea, Angola, Bulgaria, Monaco, Cameroon, Syria, Bosnia and Herzegovina, Bolivia, Virgin Islands UK, Kenya, Democratic Republic of the Congo, Haiti, Cote d'Ivoire, Yemen, Lao People's Democratic Republic, Lebanon); the only 'Hong Kong, China' occurrence anywhere on the fetched page is in the unrelated, site-wide FATF-member-countries navigation menu (Hong Kong, China is a FATF member, which is a different fact from being under increased monitoring). Not on the EU's Annex I or Annex II list of non-cooperative jurisdictions for tax purposes (17 February 2026 update), reconfirmed by this row's pre-existing citation from a prior pass, which independently checked full surrounding context (not a bare substring match). |
| Estoniachecked 2026-09-13 | Distributed-profit tax rate is 22% (applied as 22/78 of the net distribution: the taxable amount is the distribution divided by 0.78 then multiplied by 22%), effective 2025-01-01 (Income Tax Act (Tulumaksuseadus) SS4(1) and (1^1)). Undistributed/retained corporate profit is not taxed at the point of retention -- taxation is deferred to the distribution event. | Not a distinct territorial/exempt-company regime -- the CIT structure itself IS the exemption (0% on retained/reinvested profit; see cit_headline). SS10 ("Low tax rate territory") and SS10^1 ("Non-cooperative jurisdiction for tax purposes") impose CFC-style anti-avoidance provisions on income routed through low-tax/non-cooperative jurisdictions. | 22% flat rate on all ordinary personal income (employment, business, capital gains, rent/royalties, interest, dividends) -- Estonia has no progressive personal income tax bands. The general income-tax rate set by SS4(1) applies uniformly to a resident individual's aggregate taxable income as enumerated in SS12(1); no separate/different individual-income rate schedule exists elsewhere in the Act. The only rate carve-outs -- SS4(2) 10% for specific pension/insurance payouts, SS4(5) 18% for credit-institution advance payments, SS4(6) 0% for the narrow events in SS13(5)-(6) -- are inapplicable to ordinary wage, business, or capital-gains income. | Capital gains are not a separate tax category or schedule -- gains from the sale or exchange of property (securities, real estate, business/partnership interests, crypto-assets, rights, etc.) are one of the enumerated categories of a resident individual's aggregate taxable income (SS12(1)(3), referencing SS15) and are taxed at the same flat 22% headline rate as other income (SS4(1)). There is no preferential capital-gains rate, no holding-period distinction (short vs. long term), and no general annual exemption threshold for individuals. Gain/loss is computed as selling price (or exchange market price) minus acquisition cost and directly related certified expenses. | No inheritance tax, no gift tax on individual recipients, and no general net-wealth (net-worth) tax. (a) Inheritance: SS15(4)(1) expressly exempts 'the accepted estate' from the income-tax charge on gains from transfer of property -- accepting an inheritance is not itself a taxable event. There is no stepped-up basis, however: SS37(11) provides that on a later sale of inherited property, the acquisition cost is deemed to include only 'the expenses incurred by a successor' (essentially a carryover/near-zero basis) -- so the economic gain embedded in inherited property is captured as an ordinary capital gain on the heir's eventual disposal, not as an inheritance tax at the point of transfer. (b) Gifts: SS19(3)(6) exempts from income tax gifts and donations received by an individual from a natural person, a state or municipal authority, a resident legal person, or (conditionally) a non-resident -- ordinary gifts received by an individual are not taxed to the recipient (the SS49 gift/donation charge falls on a donor company's own gift-giving, not on the individual recipient). (c) Wealth tax: the Income Tax Act -- Estonia's general recurring tax statute for individuals, and the natural home for such a levy if one existed -- contains no net-worth/wealth-tax provision anywhere in the consolidated text reviewed. | None. No special or preferential tax regime exists for new tax residents, returning expatriates, or holders of Estonia's residence/visa programmes. Estonia applies a single ordinary tax-residency test uniformly: a natural person becomes a resident -- taxed on worldwide income at the same flat 22% rate as any other resident -- purely by having a place of residence in Estonia or by being physically present for at least 183 days within a 12-month period (SS6(1)). There is no separate chapter, section, or rate schedule anywhere in the Act's 13 chapters for newly-arrived, foreign, or returning residents (contrast with e.g. Portugal's NHR, Italy's flat-tax regime, or Cyprus non-dom). This is independently corroborated by Estonia's own e-Residency/Digital Nomad Visa (DNV) FAQ, which states that a DNV holder becomes an ordinary Estonian tax resident -- taxed under the same general rules -- once the 183-day threshold is crossed, with no mention of any preferential rate, holiday, or reduced base tied to the visa or to e-Residency (which itself confers no tax residency or tax status at all). | n/a -- no special new-resident tax regime exists for Estonia to attach a threshold, minimum-investment amount, or flat annual fee to (see new_resident_special_regime). | Estonia has no stand-alone 'Economic Substance Act' of the kind BVI/Cayman/UAE use for zero-or-low-tax regimes (no substance-declaration/reporting-obligation checklist regime). Instead, substance-over-form is enforced through three general anti-abuse mechanisms embedded in the Income Tax Act: (1) a general anti-abuse rule (GAAR) at SS5^1, disregarding for tax purposes any transaction or series of transactions whose main purpose is a tax advantage and which is 'not genuine' -- defined as lacking 'real vital or commercial reasons, which reflect the actual economic substance of the transaction'; (2) a controlled-foreign-company (CFC) regime at SS543, attributing a CFC's profit to the controlling Estonian resident company where that profit derives from 'ostensible transactions' -- i.e. where the CFC would not hold the relevant assets or bear the relevant risks absent control by an entity whose own 'significant people functions' actually drive the value creation -- computed on an arm's-length basis, with a de minimis carve-out (CFC profit under EUR 750,000 and other passive/financial income under EUR 75,000 in the prior financial year); and (3) a targeted denial of the participation exemption on inbound dividends (SS18(1^1)-(1^2)) where the underlying arrangement is 'devoid of economic substance' and tax-advantage-motivated. Together these implement ATAD-style substance tests rather than a checklist-based local-presence substance regime. | Estonia has NOT implemented the substantive Pillar Two charging rules. Estonia formally notified the European Commission (by 31 Dec 2023) that it is exercising the Article 50(1) election under the EU Minimum Tax Directive (Council Directive (EU) 2022/2523) to delay application of the Income Inclusion Rule (IIR) and Undertaxed Profits Rule (UTPR) for six consecutive fiscal years from 31 December 2023 (an option available to Member States with no more than twelve in-scope ultimate parent entities); European Commission Notice C/2023/1536 (OJ C, 12.12.2023) names Estonia, alongside Latvia, Lithuania, Malta and Slovakia, as having made this election. Consistent with this, Estonia's own Income Tax Act Chapter 10^3 'Global Minimum Tax' (SS5410-SS5411, in force from 12.05.2024) implements only the ancillary obligations the Directive still requires of an electing state -- designation of a filing entity, information-sharing to that entity, and rules for determining a constituent entity's jurisdiction -- for Estonia-headquartered (ultimate-parent-in-Estonia) groups with at least EUR750,000,000 consolidated revenue in 2 of the preceding 4 years; no IIR/UTPR/QDMTT charging, tax-base, or rate provision appears anywhere in the reviewed consolidated Act text. The Article 50 election does not waive top-up-tax liability group-wide, so Estonian-parented in-scope groups remain subject to top-up tax collected under other jurisdictions' IIR/UTPR during the deferral window. | Estonia has concluded double taxation avoidance agreements (DTAs) with 70 countries, of which 66 are currently in force (per the Ministry of Finance's own published tally). A further 8 are signed and/or ratified but not yet in force ('in preparation': Bosnia and Herzegovina, Botswana, Morocco, Qatar, Russia, South Africa, Tajikistan, and a renegotiated treaty with the United Kingdom). The numbered in-force list runs from #1 Albania to #66 Viet Nam; the most recently entered-into-force treaty is with Andorra (in force 26.03.2026). | Not on the FATF black list ('High-Risk Jurisdictions subject to a Call for Action': Democratic People's Republic of Korea, Iran, Myanmar) or grey list ('Jurisdictions under Increased Monitoring', 19 June 2026 update: Angola, Bolivia, Bosnia and Herzegovina, Bulgaria, Cameroon, Cote d'Ivoire, DR Congo, Haiti, Iraq, Kenya, Kuwait, Laos, Lebanon, Monaco, Nepal, Papua New Guinea, South Sudan, Syria, Venezuela, Vietnam, Virgin Islands (UK), Yemen) -- Estonia does not appear in either FATF enumeration. Also not on the EU list of non-cooperative jurisdictions for tax purposes (17 Feb 2026 update, Annex I or Annex II) -- as an EU member state Estonia is categorically outside the scope of that list (which assesses only third countries); its Annex I and Annex II enumerations (American Samoa, Anguilla, Guam, Palau, Panama, Russia, Turks & Caicos Islands, US Virgin Islands, Vanuatu, Viet Nam / Belize, British Virgin Islands, Brunei Darussalam, Eswatini, Greenland, Jordan, Montenegro, Morocco, Turkiye) contain no EU member state. |
| Vanuatuchecked 2026-09-13 | none | none | none | none | none | Not applicable. Vanuatu levies no personal or corporate income tax of any kind (cit_headline and pit_top_rate are publish_ready 'none' elsewhere in this row, confirmed via CIR's exhaustive 'Licenses and Taxes' enumeration and, independently this session, via the 'Why Pay Taxes?' brochure's exhaustive 'Acts of Parliament' enumeration underlying CIR's powers -- neither contains any income-tax statute). With no baseline personal or corporate income-tax regime in force, there is no mechanism for, and neither CIR enumeration contains, a preferential tax regime specific to new residents (e.g. a remittance-basis, lump-sum, or flat-tax scheme of the kind seen in other rows, such as Switzerland's Aufwandbesteuerung). Distinct from this: Vanuatu's citizenship/investment 'Development Support Program' (Citizenship Act [CAP 112], Citizenship (Development Support Program) Regulations Order No. 33 of 2019) is an immigration/citizenship-grant scheme -- it does not itself confer or alter tax liability, so it is a distinct instrument from a 'new resident tax regime' and is out of scope for this tax-focused field. | Not applicable -- dependent on new_resident_special_regime (this row), which is itself not applicable: no special new-resident tax regime exists because no income tax exists at all, so no associated threshold, minimum investment, or flat fee arises under a tax regime. (Vanuatu's separate citizenship-by-investment Development Support Program does carry its own financial contribution thresholds, but that is an immigration-status fee schedule, not a tax-regime threshold, and remains out of scope for this field.) | Unverified (no primary source yet) | Not applicable -- no Pillar Two/GloBE exposure. Vanuatu does not appear on the OECD/G20 Inclusive Framework on BEPS' current official membership roster ('Members of the OECD/G20 Inclusive Framework on BEPS,' updated 5 December 2025) -- the framework under which the Pillar Two global minimum tax (GloBE rules) operates -- and separately has no corporate income tax at all (cit_headline, publish_ready 'none' elsewhere in this row) for a domestic or foreign top-up tax to apply against. | 97 partner jurisdictions confirmed on Vanuatu's official AEOI/CRS 'Reportable Jurisdictions 2024' list (Vanuatu Competent Authority / DCIR) -- the jurisdictions with which Vanuatu automatically exchanges financial-account information under the OECD Common Reporting Standard Multilateral Competent Authority Agreement. This is Vanuatu's confirmed international tax-information-exchange network size. Separately, and NOT independently primary-confirmed this session: Vanuatu is widely reported by secondary/advisory sources (not cited as primary here) to have zero bilateral double-taxation-avoidance agreements (DTAs) in force. That figure is consistent with, but not directly proven by, this row's own already-confirmed absence of any Vanuatu income tax (cit_headline/pit_top_rate, publish_ready elsewhere in this row) -- a jurisdiction levying no income tax has little need to negotiate DTA relief. No dedicated Vanuatu government DTA-specific registry or list was located or fetched this session to independently confirm '0 DTAs' as a primary figure. | Listed on EU Annex I (non-cooperative jurisdictions for tax purposes) continuously across every tracked update in the fetched cross-cutting snapshot, including the most recent 17 February 2026 update. Vanuatu was NOT found in the substantive list content of the shared cross-cutting FATF snapshot fetched for the uae/ row. |
| United Kingdomchecked 2026-09-13 | Main Corporation Tax rate is 25% on profits above GBP250,000; Small Profits Rate is 19% for profits of GBP50,000 or less; marginal relief applies between the two thresholds. | The UK taxes resident companies on worldwide profits (a worldwide-basis system, not territorial), but two exemption mechanisms remove most double taxation of foreign profits. (1) Dividend/distribution exemption: Part 9A Corporation Tax Act 2009 (CTA09) is structured so that, per HMRC's own manual, 'CTA09/Part 9A is designed to ensure that the great majority of dividends and other distributions will be exempt' from corporation tax -- Chapter 2 exempts distributions received by small companies (S931B-S931C), Chapter 3 exempts distributions received by all other companies subject to anti-avoidance conditions (S931D-S931Q), and Chapter 4 allows an election that exemption should not apply (S931R-S931W). (2) Foreign branch (permanent establishment) exemption: an elective regime under CTA09/S18A lets a UK-resident company exempt the profits of its foreign branches from UK corporation tax. The election must be made to HMRC before the start of the first accounting period it covers, is irrevocable once that period begins, and is automatically revoked if the electing company ceases UK residency. | Additional rate of 45% applies to taxable income over GBP125,140 (no Personal Allowance is available once taxable income reaches GBP125,140). Basic rate is 20% on GBP12,571-GBP50,270; higher rate is 40% on GBP50,271-GBP125,140. | From 6 April 2026: basic-rate taxpayers pay 18% and higher/additional-rate taxpayers pay 24% on most chargeable gains (rate depends on how the gain stacks with taxable income against the basic-rate band). Business Asset Disposal Relief (BADR) qualifying gains (sole traders, partnerships, trustees) are taxed at 18% from 6 April 2026. The Capital Gains Tax tax-free (annual exempt) allowance for the 2026 to 2027 tax year is GBP3,000. | Standard Inheritance Tax rate is 40%, charged only on the portion of an estate above the GBP325,000 nil-rate threshold (a reduced 36% rate applies where a qualifying charitable-gift condition is met). No separate annual wealth tax exists. | 4-year Foreign Income and Gains (FIG) regime, effective 2025-04-06, replacing the former remittance-basis regime for non-UK-domiciled individuals. Available to UK tax residents within their first 4 tax years of UK residence, conditional on >=10 consecutive prior years of non-UK tax residence. | Unverified (no primary source yet) | Unverified (no primary source yet) | The UK has implemented OECD Pillar Two via Multinational Top-up Tax (MTT) and Domestic Top-up Tax (DTT). MTT implements the Income Inclusion Rule (IIR) -- the main charging rule -- applying for accounting periods beginning on or after 31 December 2023. The Undertaxed Profits Rule (UTPR), the backstop rule, is also implemented within MTT as a separate charging mechanism, applying for accounting periods beginning on or after 31 December 2024. DTT is the UK's Qualifying Domestic Minimum Top-up Tax (QDMTT), ensuring UK operations of in-scope groups face no additional top-up charge elsewhere; DTT shares MTT's implementation date. Together these are the UK's implementation of the OECD/Inclusive Framework 'GloBE' rules, ensuring large groups pay an effective tax rate of at least 15% in every territory of operation. | Unverified (no primary source yet) | The United Kingdom is not on the FATF list of 'Jurisdictions under Increased Monitoring' (grey list) or the FATF high-risk/black list (13 February 2026 update): the only occurrence of 'United Kingdom' in the full FATF document is in the FATF Global Network / membership-directory listing of FATF members (alongside Ireland, Italy, Japan, etc.), not in either the increased-monitoring or high-risk sections. The United Kingdom is not named anywhere in the EU's list of non-cooperative jurisdictions for tax purposes (Annex I or Annex II, 17 February 2026 update) -- zero occurrences of 'United Kingdom' in the full document text. |
| Wyomingchecked 2026-09-13 | No state corporate income tax of any kind. | none | No state personal income tax of any kind. | Not taxed at the state level -- Wyoming has no personal or corporate income tax of any kind, so capital gains (as a component of income) are not subject to state tax. | No standalone Wyoming inheritance tax (Wyo. Stat. Title 39, Ch.6, Art.8 'Inheritance Taxes' was repealed by Laws 1982, ch. 74, Sec.3). A separate estate-tax chapter (Title 39, Ch.19, Sec.39-19-101 to -111) remains codified and NOT formally repealed, but is pegged entirely to the federal state-death-tax credit ("the maximum state death tax credit allowed ... against federal estate taxes"); because Congress phased out that federal credit (fully eliminated by 2005, EGTRRA), the Wyoming tax computes to $0 in current practice even though the statute is still on the books. | none | none | none | Identical federal fact -- see delaware row. | 58 bilateral/multilateral income-tax-treaty instruments listed in the IRS's own Table 3 (List of Tax Treaties, updated through Sept. 26, 2025) -- including the legacy US-USSR treaty, which per the table's own footnote 6 extends coverage to 9 successor states (Armenia, Azerbaijan, Belarus, Georgia, Kyrgyzstan, Moldova, Tajikistan, Turkmenistan, Uzbekistan) not separately listed. Counting those successor states, the network reaches 67 countries. This is a single, uniform federal fact -- US states do not separately negotiate tax treaties. | Identical federal fact -- see delaware row. |
| Nevadachecked 2026-09-13 | No state corporate income tax. Nevada instead imposes a Commerce Tax (NRS ch.363C, gross-receipts basis, industry-tiered rate schedule) on businesses with NV gross revenue exceeding $4,000,000/fiscal year -- transcluded from staging/franchise-tax-matrix/matrix.json's NV cell -- but this is a gross-receipts tax, not a corporate income tax. | none | No state personal income tax -- constitutionally barred (Nevada Constitution bars the state from levying an income tax on the wages or personal income of natural persons). | No state tax on capital gains (individual or corporate) -- Nevada has no income tax of any kind to apply to gains. | No Nevada inheritance, gift, or estate tax. | none | none | none | Identical federal fact -- see delaware row. | 58 bilateral/multilateral income-tax-treaty instruments listed in the IRS's own Table 3 (List of Tax Treaties, updated through Sept. 26, 2025) -- including the legacy US-USSR treaty, which per the table's own footnote 6 extends coverage to 9 successor states (Armenia, Azerbaijan, Belarus, Georgia, Kyrgyzstan, Moldova, Tajikistan, Turkmenistan, Uzbekistan) not separately listed. Counting those successor states, the network reaches 67 countries. This is a single, uniform federal fact -- US states do not separately negotiate tax treaties. | Identical federal fact -- see delaware row. |
| South Dakotachecked 2026-09-13 | "South Dakota does not impose a corporate income tax." | none | No state personal income tax. | No state tax on capital gains -- South Dakota has no income tax of any kind to apply to gains. | No South Dakota inheritance tax (repealed by voters effective 2001-07-01) and no estate tax. | none | none | Not yet researched | Identical federal fact -- see delaware row. | 58 bilateral/multilateral income-tax-treaty instruments listed in the IRS's own Table 3 (List of Tax Treaties, updated through Sept. 26, 2025) -- including the legacy US-USSR treaty, which per the table's own footnote 6 extends coverage to 9 successor states (Armenia, Azerbaijan, Belarus, Georgia, Kyrgyzstan, Moldova, Tajikistan, Turkmenistan, Uzbekistan) not separately listed. Counting those successor states, the network reaches 67 countries. This is a single, uniform federal fact -- US states do not separately negotiate tax treaties. | Identical federal fact -- see delaware row. |
| Delawarechecked 2026-09-13 | Flat 8.7% on federal taxable income allocated/apportioned to Delaware (Form CIT-TAX), per Title 30 Del. C. sec.1902(b). Since TY2020, apportionment of unallocated income is based solely on Delaware's share of total US gross receipts (single-sales-factor). NOTE (do not conflate): Delaware ALSO levies a wholly separate, non-income recurring charge -- the corporation/LLC Franchise Tax / LLC Annual Tax (8 Del.C. sec.501-504 corp; 6 Del.C. sec.18-1107 LLC, $400 flat + $100/series) -- transcluded from staging/franchise-tax-matrix/matrix.json's DE cell (snapshot_sha256 37ecd2681b14e8b99bc5de6cd7e6987c9f81dfbb09e05dcd1a3e4283de44bef2). The two are legally/administratively distinct (Division of Corporations vs Division of Revenue) and this field reports the income tax only. | No general territorial/exempt-company CIT regime, but a narrow statutory carve-out exists: Title 30 Del. C. Sec.1902(b)(8) exempts "corporations whose activities within this State are confined to the maintenance and management of their intangible investments ... and the collection and distribution of the income from such investments" (the so-called 'Delaware loophole' for passive intangible-holding-company income: stocks, bonds, notes, patents, trademarks, etc.). | Graduated 2.2%-6.6%; the maximum rate of 6.60% applies to taxable income of $60,000 or over (income under $60,000 taxed 2.2%-5.55%). | Capital gains are taxed as ordinary income under Delaware's graduated personal income tax (2.2%-6.6%) -- Delaware taxable income starts from federal adjusted gross income (Title 30 Del. C. Sec.1105) with no separate preferential capital-gains rate. The only capital-gains-adjacent provision found is a narrow $12,500 retirement-income exclusion (age 60+) that includes capital gains among several eligible income types -- not a general preferential rate. | No Delaware estate or inheritance tax. Title 30 Del. C. Chapter 15 ("Estate Tax") was repealed in its entirety effective January 1, 2018 (81 Del. Laws, c. 52, Sec.1). | none | none | none | The US has NOT domestically enacted OECD Pillar Two (no QDMTT/IIR/UTPR in US domestic law). Via a 'Qualified Side-by-Side' arrangement announced by Treasury 2026-01-05, the US secured exemption from Pillar Two's IIR and UTPR for US-headquartered MNE groups (FYs commencing on/after 2026-01-01); the US's existing GILTI regime is treated as the domestic-minimum-tax analog instead of adopting GloBE directly. | 58 bilateral/multilateral income-tax-treaty instruments listed in the IRS's own Table 3 (List of Tax Treaties, updated through Sept. 26, 2025) -- including the legacy US-USSR treaty, which per the table's own footnote 6 extends coverage to 9 successor states (Armenia, Azerbaijan, Belarus, Georgia, Kyrgyzstan, Moldova, Tajikistan, Turkmenistan, Uzbekistan) not separately listed. Counting those successor states, the network reaches 67 countries. This is a single, uniform federal fact -- US states do not separately negotiate tax treaties. | The United States is a full FATF member (appears in FATF's own Global Network membership listing) -- NOT on FATF's black list (Iran, North Korea, Myanmar) nor its grey/increased-monitoring list (22 jurisdictions as of the June 2026 plenary). Not on the EU list of non-cooperative jurisdictions either (17 Feb 2026 update: Annex I = American Samoa, Anguilla, Guam, Palau, Panama, Russia, Turks & Caicos, US Virgin Islands, Vanuatu, Viet Nam; Annex II = Belize, BVI, Brunei, Eswatini, Greenland, Jordan, Montenegro, Morocco, Turkiye -- US in neither). |
| Floridachecked 2026-09-13 | 5.5% flat rate on federal taxable income (as modified and apportioned via a property/payroll/sales three-factor formula), for tax years on/after 2022-01-01; $50,000 exemption; no minimum-tax floor of any kind. (Fla. Stat. Ch. 220.) | none | No state personal income tax -- constitutionally barred (Florida Constitution Section 5; reinforced by a 2018 amendment requiring a two-thirds legislative supermajority to impose any new state tax). | Corporations: capital gains taxed as part of ordinary federal-taxable-income base under the 5.5% CIT (Florida's Income Tax Code 'piggybacks' the federal code for corporate capital-gains treatment), per Sec. 220.13, Fla. Stat. Individuals: no capital-gains tax, since there is no individual income tax. | No Florida estate or inheritance tax. Fla. Stat. Sec.198.02 imposes estate tax only in an amount equal to the (now-eliminated) federal state-death-tax credit -- "a sum equal to the amount by which the credit allowable under the applicable federal revenue act ... exceeds the aggregate amount of all ... taxes actually paid to the several states" -- so the tax computes to $0 since Congress phased out that federal credit (fully eliminated 2005, EGTRRA). The statute remains codified but is currently inoperative in substance; Florida separately imposes no gift/inheritance tax of any kind. | none | none | none | Identical federal fact -- see delaware row. | 58 bilateral/multilateral income-tax-treaty instruments listed in the IRS's own Table 3 (List of Tax Treaties, updated through Sept. 26, 2025) -- including the legacy US-USSR treaty, which per the table's own footnote 6 extends coverage to 9 successor states (Armenia, Azerbaijan, Belarus, Georgia, Kyrgyzstan, Moldova, Tajikistan, Turkmenistan, Uzbekistan) not separately listed. Counting those successor states, the network reaches 67 countries. This is a single, uniform federal fact -- US states do not separately negotiate tax treaties. | Identical federal fact -- see delaware row. |
| Puerto Ricochecked 2026-09-13 | 18.5% normal tax on net corporate taxable income (reduced from 20% for tax years beginning after 31 Dec 2018 per Act 257-2018/subsequent amendments), PLUS a graduated surtax on income subject to additional tax: not over $75,000 = 5%; $75,000-$125,000 = $3,750 + 15% of excess over $75,000; $125,000-$175,000 = $11,250 + 16% of excess over $125,000; $175,000-$225,000 = $19,250 + 17% of excess over $175,000; $225,000-$275,000 = $27,750 + 18% of excess over $225,000; over $275,000 = $36,750 + 19% of excess over $275,000. Combined top marginal rate: 18.5% + 19% = 37.5%. A reduced 5% normal tax applies during an initial period for certain small/new corporations under Act 120-2014. | Act 60-2019 (Ley de Incentivos de Puerto Rico, consolidating and superseding the former Act 20/Act 22 tracks) offers a fixed preferential corporate tax rate of 4% for qualifying export-services businesses ('tasa fija preferencial de contribución sobre ingresos de un cuatro por ciento (4%)'); the fetched text also references a temporary 2% rate for an initial 5-year period in a specific enhanced-incentive context, and the 4% rate for the remainder of the applicable decree period. | Not yet researched | Outside of an Act 60 decree, individuals/estates/trusts may elect a preferential flat rate of 15% on net long-term capital gain in excess of net short-term capital loss for sales/exchanges after 30 June 2014 (10% before), or ordinary rates if more beneficial. SEPARATELY, for Act 60 Individual Resident Investor decree holders (Secciones 2022.01-2022.02, as amended by Ley 38-2026), gains are split on TWO independent axes: (1) by property-holding period -- gains from appreciation BEFORE PR residency began are taxed at a flat 5% (not exempt) after a 10-year residency hold, for BOTH pre-2027 and post-2027 decree applicants alike (this 5% rate is not new -- it was in the original 2019 Act 60 text and simply carried forward by Ley 38-2026); (2) by decree-application date, for gains from appreciation AFTER PR residency began -- 100% EXEMPT through 2035-12-31 for decrees applied for on or before 2026-12-31, versus a flat 4% (not exempt) through 2055-12-31 for decrees applied for on or after 2027-01-01. Both tracks require the decree application to have been filed on or before 2026-12-31 to access the pre-2027 (fully-exempt) track at all. | Not yet researched | Act 60's Individual Resident Investor incentive: available to individuals who become bona fide Puerto Rico residents and were NOT PR residents during a preceding statutory look-back window, granting the capital-gains/dividend/interest treatment described above. | Statutory requirement: beginning the 2nd tax year after decree issuance, the Individual Resident Investor must make an annual charitable donation of at least $10,000 to PR-based, certified nonprofits unrelated to the decree holder (Sección 2023.01(c), 13 L.P.R.A. §45151). A commonly-cited $5,005 DDEC annual filing/compliance fee appears in secondary sources but is delegated to DDEC's own regulation, not a specific dollar figure in the statute itself — not independently confirmed against that regulation this pass. | Act 60 (Codigo de Incentivos de Puerto Rico) Sec.1030.01 "Creacion de Empleos" (13 L.P.R.A. Sec.45022) imposes a tiered minimum-employment substance requirement on Exempt Businesses with actual or projected annual gross business volume over $3,000,000: at least 1 full-time direct employee for decrees granted under Chapter 3 of Subtitle B (Export Services -- the chapter relevant to this row's individual-investor/export-services regime), or 3 full-time direct employees under Chapter 6 (Manufacturing). Decrees granted under any other chapter carry no employment-creation requirement. The Secretary may impose a higher requirement in the best interests of Puerto Rico. | Not yet researched | Puerto Rico does not independently negotiate tax treaties; it operates within the US federal treaty framework with PR-specific coordination arrangements — see the PR-US tax coordination agreement. | Not listed — the US (which PR falls under for FATF purposes) is a FATF member country, not on the black list. Not listed on the EU's Annex I/Annex II as of 17 February 2026 — notably unlike three other US territories (American Samoa, Guam, US Virgin Islands) which ARE listed. |
Hover column headers to see field definitions. Hover cell text to see source notes. Typed unknowns (e.g., “Portal not observable”) are methodological limits, not data gaps.
Research scope
Rows are the jurisdictions on the Private Pierce international roster, plus six US jurisdictions — Wyoming, Nevada, South Dakota, Delaware, Florida, and Puerto Rico. The US rows are here because they legislate on this same axis and are the jurisdictions readers most often hold up against an offshore option; putting them in the same table on the same fields lets the statutory terms be read against each other instead of described in two separate vocabularies. Where a jurisdiction runs more than one regime, the divergent regimes appear as their own rows directly beneath the parent. Cells that read as not established or unknown are typed unknowns — the research pass did not confirm that field against an official source, the reason is on hover, and they will be backfilled through this same data file rather than by rewriting this page.
How to read this matrix
Each row is a jurisdiction. cit_headline and pit_top_rate are statutory headline rates, not effective rates. cit_territorial_or_exempt_regime records whether the corporate charge is territorial or carries an exempt class. capital_gains_treatment and wealth_inheritance_tax record those charges where the jurisdiction levies them. new_resident_special_regime and new_resident_regime_threshold_or_fee describe any regime open to arriving residents and its stated entry condition. economic_substance_rules, pillar_two_status, treaty_network_size, and fatf_oecd_eu_listing record the international-compliance surface. Sub-rows carry the regime-specific values where a parent jurisdiction taxes mainland and free-zone entities differently.
What this page does not claim
- It does not compute anyone's tax. A headline rate is not a liability; deductions, credits, surcharges, local additions, and residence facts all sit outside this matrix.
- It does not advise on structuring. It does not recommend a jurisdiction, a regime, or a combination of them.
- It does not guarantee currency. Tax law changes more often than most fields on this site; verify against the linked official source and with local counsel and a tax advisor.
Sources
Each row links to one primary official domain for that jurisdiction, chosen as its lead source. Every published cell carries its own pinpoint citation, source URL, and the first segment of the snapshot hash of the document it was read from, visible on hover; the snapshots themselves are retained on file. Where a jurisdiction publishes a consolidated text, the consolidation date it was read at is recorded with the underlying matrix rather than restated here. The full source taxonomy lives at /about/source-registry/, and the research method at /about/methodology/.
Not legal advice
Private Pierce is not a law firm and does not provide legal advice.
Nothing on this page is legal, tax, or immigration advice, and it is not a recommendation to use any jurisdiction; foreign law is described from official sources as published and may have changed — consult counsel licensed in the relevant jurisdiction.
Frequently asked questions
What is a headline rate, and what does it leave out?
The headline rate is the statutory rate a jurisdiction publishes, before the deductions, credits, surcharges, local or cantonal additions, and regime-specific carve-outs that determine an actual liability. It is a comparison anchor, not an effective rate, and it is not a computation of what anyone would owe.
What is a territorial or exempt regime?
A territorial regime taxes income sourced inside the jurisdiction and generally leaves foreign-source income outside the charge; an exempt regime removes a defined class of entity or income from the charge entirely. The matrix records which description each jurisdiction's own law supports rather than sorting jurisdictions into a binary.
Why do sub-regime rows appear for some jurisdictions?
Because the tax rules inside one jurisdiction can differ by regime — a mainland company and a financial free-zone entity are not on the same footing. Where that divergence exists, each regime gets its own row directly under its parent so a value is never attributed to the wrong one.
How current are these figures?
Each published cell carries the pinpoint, source URL, and snapshot hash it was read from, and the row carries the date it was checked. Tax law changes frequently and foreign law may have changed since the snapshot; confirm against the linked official source before relying on any figure.
Go deeper with source-backed research
Explore methodology, datasets, and related matrices cited on this page.