The destinations for tax optimisation

0% on foreign-source income

The best-known territorial tax system: only income generated within Panama is taxed. Holdings, companies and residency with contained costs and international banking. Confirmed for 2026.

• ✓0% on dividends and consulting for foreign clients
• ✓Fixed Franchise Tax of $300 per year
• ✓Friendly Nations Visa for residency
• ✓Sociedad Anónima with flexible structure

Lump-sum taxation for non-EU residents

Lump-sum taxation (consumption tax) allows non-EU foreign residents to pay tax calculated on their lifestyle rather than actual income. Available in cantons such as Vaud, Valais, Ticino, Graubünden. The effective corporate rate ranges from 11.9% (Zug) to 20.5% (Bern). The STTR/OECD Pillar Two reform applies to groups with turnover >€750M.

• ✓Negotiated lump-sum, stable over time
• ✓No tax on foreign income not remitted
• ✓Top-tier political and legal stability
• ✓Excellent for wealth tax optimisation
• ✓Competitive cantonal rates (Zug 11.9%, avg 14.4%)

Foreign Income & Gains regime for new residents

From 6 April 2025 the old non-dom regime was replaced by the FIG (Foreign Income & Gains) 4-year regime. New residents (non-resident in the previous 10 years) pay no tax on foreign income and gains for the first 4 years. Corporation Tax at 25% with a 19% small profits rate below £50,000.

• ✓Exemption on foreign income and gains for 4 years
• ✓Access to global financial markets
• ✓Clear and predictable regime (FIG)
• ✓Strong common-law legal system

0% personal income tax, 9% corporate

The UAE applies no personal income tax. The 9% corporate tax applies to profits above AED 375,000 (~€94,500 at 2026 rates). Free Zones retain QFZP exemptions. The Golden Visa grants long-term residency (10 years, renewable).

• ✓0% personal income tax
• ✓Corporate 0% up to AED 375,000, then 9%
• ✓10-year Golden Visa
• ✓Global hub for freelancers and companies
• ✓Free Zone with QFZP status (0% corporate)

20% on qualified income (IFICI regime)

The IFICI regime (Tax Incentive for Research and Innovation), known as NHR 2.0, confirmed in 2026, applies a 20% rate on qualified employment income (science, technology, strategic sectors) for 10 years. The historical NHR has ended; IFICI requires specific professional qualification criteria.

• ✓20% flat on qualified income (IFICI)
• ✓Possible exemptions on foreign income
• ✓Favourable climate and cost of living
• ✓EU access for European citizens
• ✓10-year regime validity

35% corporate, refund 6/7 → 5% effective

Malta applies a nominal 35% rate, but the refund system allows non-resident shareholders to recover 6/7 of the tax paid, bringing the effective rate to 5%. The non-dom regime taxes only income remitted to Malta. An EU system with access to the European market.

• ✓Effective tax rate 5% (refund 6/7)
• ✓Non-dom within the EU
• ✓Efficient holding and trading companies
• ✓Access to the European market
• ✓Full imputation system with refund

12.5% corporate + EU dividend exemption

The 12.5% corporate rate and the intra-EU dividend exemption make Ireland the preferred holding base for groups operating in Europe. The Knowledge Development Box (IP box) applies an effective 10% rate on income from qualifying intellectual property. Pillar Two at 15% for groups with turnover >€750M.

• ✓Competitive 12.5% corporate rate
• ✓EU participation dividend exemption
• ✓IP box (Knowledge Development Box) at 10%
• ✓Extensive tax treaty network

17% corporate + exemptions and no capital gains

Singapore combines a 17% corporate rate with broad SME exemptions, no capital gains tax and family office regimes (VCC/13O/13U). The leading Asian hub for companies and wealth. The top personal bracket rose to 24% in 2024.

• ✓No capital gains tax
• ✓Family office with VCC (13O/13U)
• ✓Startup Tax Exemption for SMEs
• ✓Stability and rule of law