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Flat Tax: A pre-agreed fixed annual tax on foreign-sourced income, regardless of total earnings. Common in countries like Greece and Italy, this tax regime allows high-net-worth individuals to limit tax liability while reporting global income.
Zero Tax: Jurisdictions like Dubai and Panama impose no personal income tax on either foreign or local income (in Panama’s case, only local income is taxed under its territorial system).
Goal: Maximize how much of your income you keep by legally reducing personal tax obligations in a compliant, strategic way.
Greece offers a non-domicile tax regime of €100,000 per year for the main applicant, and €20,000 for each dependent. No matter how much you earn from outside sources of income (whether it's dividends, capital gain, or income), you only pay this pre-agreed flat tax per year.
Duration and Renewal: This program can be renewed for 15 years.
Residency Requirements: As most countries, Greece treats you as tax resident if you spend at least 183 days (including partial days) in Greece in any 12‑month period, or if your “center of vital interests” (home, family, economic ties) is in Greece, even with fewer days. You don't need to reside full time in Greece, but also cannot be a tax resident of another jurisdiction which would be contradictory to your tax residency in Greece.
Tip: Day-count checks in Greece are not always rigorous, but you must still comply with the rules and ensure you’re not tax-resident in another country.
Non-dom eligibility:
- You must not have been a Greek tax resident for at least 7 of the previous 8 years before transferring your tax residence to Greece.
- The minimum asset investment or deposit should be €500,000 for the non-dom regime eligibility in Greece, but there is an allowance of 3 years to make this investment after the funds have been moved to Greece.
Immigration Status: The flat tax regime does not provide immigration status in Greece, which is separate and can be combined with a specific asset or investment to provide both immigration and tax status.
If the applicant plans to have immediate immigration status with the non-dom tax application, then the investment should be done at the time of application to qualify for both programs in one shot. The choice is up to the applicant on how they want to structure their status in Greece.
Italy also offers a non-domicile tax program called the neo-domicile program which is at a pre-agreed flat rate of €200,000 per main applicant and €25,000 per dependent.
However, this flat tax regime will be increasing to €300,000 per year in 2026 per main applicant and €50,000 per dependent.
This regime is broadly similar to the Greek non-domicile program, with comparable requirements for establishing tax residency. It also does not grant immigration or residency rights in Italy, meaning it cannot be used as a pathway to live in the country full-time.
Investment Requirements: Unlike the Greece program, the Neo-Domicile program does not require any investment in assets in Italy to qualify.However, in order to obtain residency in the country, an investment of €250,000 in Italian startups, or €500,000 in a private or listed company in Italy is the most straightforward route.
Duration: This program in Italy can be renewed for 15 years.
Dubai (UAE) has no personal income tax whatsoever. Although nobody can become a permanent resident of this emirate (part of the United Arab Emirates), a residency permit is possible to reside there full time and take advantage of this zero-tax jurisdiction.
Although it has implemented sales taxes and corporate taxes outside of the free zones, it is still significantly less than most of the western countries such as the USA, Canada, UK, and most of Europe.
It is relatively straightforward to obtain a residency permit in Dubai, UAE, whether through company incorporation or real estate investment. However, holding a valid UAE residence visa does not automatically confer tax residency. To be classified as a tax resident and qualify for a Tax Residency Certificate (TRC), an individual must meet additional criteria, such as being physically present in the UAE for at least 183 cumulative days within a 12-month period.
For more information contact our team
The downside with Dubai is that cost of living is typically higher, which many people consider as an indirect tax (i.e., education for children, food and groceries, entertainment, private medical insurance as there is no government coverage, etc.)
Panama offers a territorial tax regime, which means that any income earned outside of Panama borders is not taxed.
Similar to many other jurisdictions, becoming a tax resident of Panama requires spending more than 183 days (consecutive or not) within the country during a tax year. Multiple avenues exist for obtaining temporary or permanent residency in Panama, enabling individuals to meet this requirement. One of the most straightforward is through a real estate investment of at least US $200,000, which allows the applicant to reside in the country full-time if desired.
By becoming a tax resident of Panama, you gain access to its territorial tax regime as well as its very favorable domestic tax framework, even if you do not choose to reside in the country full-time
If you are interested in visiting Panama, exploring Panamanian real estate, or receiving expert guidance on the residency pathway best suited to your needs, please visit this link and allow our team to assist you.
Now we will cross-reference and compare these tax jurisdictions for these 3 profiles of real life applicants from Canada, the UK, and the US, on how each jurisdiction can benefit their total earned income which goes directly into their pockets instead of the government coffers.
Daniel M. is an American citizen residing in the Bay area in California with the following profile:
Profession: Co-founder & CEO of a SaaS company (majority sold to a private equity fund; still holds equity and advisory role)
Net Worth: ~USD 10-15 million (liquid + company equity + real estate)
Annual Income Breakdown:
- Base salary (W-2): USD 600,000
- Annual cash bonus: USD 200,000
- Long-term capital gains from periodic share sales: USD 400,000
- Dividends & interest from investment portfolio: USD 150,000
- Net rental income (2 properties in CA & TX): USD 100,000
Total annual gross income: USD 1,450,000
Age: 38
Married, 2 school-age children
- In the top federal bracket and living in a high-tax state (California)
- Citizenship-based taxation—meaning Daniel will be taxed by the IRS regardless of where he lives
- Feels that between federal, state, Medicare surtaxes, and property taxes, his "reward for taking risk" is heavily eroded
- Wants to know if moving to a zero-tax or low flat-tax jurisdiction would actually improve his after-tax position once lifestyle costs, relocation costs, and potential exit taxes are considered
Daniel's tax bill in California averages approximately US$530,000 to US$560,000 per year based on his salary, cash bonus, long-term capital gain from his tech shares, dividends and interest, as well as passive income on his rental collections.
Tax Breakdown:
- Federal ordinary income tax: ~US$264,000
- Federal long-term capital gains: ~US$100,000
- Federal investment income tax: ~US$25,000
- California state tax: ~US$144,000 (earning above US$1M per year)
- Plus payroll taxes on California income
James H. is a UK citizen working as a financial executive in the City of London with the following profile:
Profession: Senior executive (Managing Director level) at a London-based asset management firm
Net Worth: ~GBP 5-7 million (ISAs, pensions, company shares, London home, 2 buy-to-let properties)
Age: 48
Divorced, 2 children (shared custody), pays child support and school fees
- Base salary: GBP 400,000
- Annual cash bonus: GBP 300,000
- Taxable vested share awards (share schemes): GBP 150,000
- Net rental income from 2 UK buy-to-lets: GBP 50,000
- Investment income (dividends/interest outside ISA/pension): GBP 30,000
Total annual gross income: GBP 930,000
- Squarely in the UK additional rate (45%) band for income tax
- Pays high National Insurance and property taxes, plus non-deductible mortgage interest restrictions on rental properties
- Increasingly frustrated by complex UK rules on non-dom vs. dom status, changes in allowances, and tax on investment income and gains
- Considering relocation to a zero-tax or low flat-tax jurisdiction where his salary, bonuses, share income, and rental profits would be taxed more lightly or more predictably
James' tax bill in the UK is more than GBP 350,000 (€398,440) per year with some optimized tax structuring. UK taxes are increasing including property taxes and other categories, and his tax obligations may increase over the years as a high earner in his country.
Reduce tax bill as much as possible
Stay within a 3-hour time zone of the UK
Reside in a community with a large expat community
Ability to do business in English
Direct flights to London UK
Mediterranean region and GCC would be ideal
Enjoy all-year sunshine
Note: His obligations for alimony and child support would continue and would not change no matter where he plans to move to.
Jennifer K. is a Canadian citizen residing in Toronto with the following profile:
Profession: Owner of a digital marketing agency + a couple of e-commerce brands, all run through Canadian corporations
Net Worth: ~CAD 5-7 million comprising:
- Shares of her operating company
- Retained earnings in corporation
- Non-registered investment portfolio
- RRSP/TFSA
- Primary residence (Toronto) + 1 rental condo
Age: 42
Married, 2 young children (one in private school)
Business Income:
- Net active business income (after expenses, before her compensation): ≈ CAD 1,100,000 per year
Personal Income Taken:
- Salary from corporation: CAD 350,000
- Eligible dividends from corporation: CAD 200,000
- Investment income from non-registered portfolio (interest/dividends): CAD 60,000
- Net rental income (Toronto condo with mortgage): CAD 20,000
Total annual gross personal income: CAD 630,000
Retained in Corporation:
Retained earnings left in corporation each year: Typically CAD 200,000-250,000 (building up passive investment income inside the corp)
In the top combined federal + Ontario tax brackets on both salary and dividends
Corporate structure is "optimized" on paper, but:
Passive investment income in the corporation risks eroding access to the small business rate
Increasingly worried about future rule changes, OECD minimum tax discussions, and CRA scrutiny
Feels her effective tax rate on new income is north of 50% once she adds:
Personal income tax
Corporate tax on retained earnings
Property tax, HST on expenses, and payroll-related costs
Since her business is location-independent, she's actively exploring:
Moving herself and her family to a low flat-tax jurisdiction
Keeping her client base
Restructuring so that new income and future business growth are taxed more lightly
Jennifer's tax bill is over CAD$300,000 per year due to the high income bracket and various sources of income types she has, both passive and active.
Stay in North American time zones to keep close to clientele and main markets
English-speaking private school for her younger child
Not be further away than 4-5 hours flight from markets in the US and Canada
Tax savings are critical to invest more for family and children's future
Frustrated with deteriorating Canadian healthcare system, education, and safety
Feels government taxes more while services decline
Seeking better growth outlook and quality of life
Let's go through the different scenarios for each jurisdiction for James' income tax case to move out of the UK to save on taxes and upgrade his lifestyle.
Tax Savings: Approximately GBP 262,164 per year
How It Works:
- Pays only €100,000 per year as flat tax regime participant (his children would not be joining him full time but rather visiting regularly)
- His income, share bonuses, rental income, and other investments from the UK would not trigger any additional taxes in Greece as it's sourced from outside Greece
Investment Requirements: To reside in Greece, he would also be expected to make an investment of €500,000 in:
- Greek government bonds, OR
- Real estate, OR
- Greek securities
Immigration Benefits: If he invests in the right asset category, he can qualify for the Greece Golden Visa as well to obtain residency status for himself and even his kids in Greece. This money would not be a donation but rather a redeemable investment until he chooses to cancel the residency or convert to citizenship status after 7 years.
Financial Feasibility: Even considering the interest or opportunity cost of €500,000 per year, it would still make financial sense for him to keep a financial asset investment in Greece to obtain his tax savings.
Tax Savings: Only GBP 86,453 per year
How It Works:
- Pays €300,000 per year as flat tax regime participant in 2026 (increased from €200,000)
- His income from the UK would not trigger any additional taxes in Italy as it's sourced from outside Italy
Why Less Attractive: This is a significantly lower saving since the Italian regime is changing its flat tax rate and hence may not have been on James' shortlist, unless he enjoyed the Italian lifestyle and was not focusing on tax savings alone.
Investment Requirements: If he chooses to also reside in Italy, he would be expected to make an investment of €250,000 in Italian startups OR €500,000 in a private or listed company in Italy.
- €250,000 in Italian startups, OR
- €500,000 in a private or listed company in Italy
Tax Savings: 100% of his taxes
How It Works: He would be able to put all his income from different sources personally into his pocket in the UAE, less alimony and child support for his children and spouse in the UK.
Investment Required: He would only need to invest in a property in the UAE at 2 million AED (~GBP 412,185) to gain residency and then become a tax resident.
ROI Timeline: The investment would pay for itself within the first 15 months of him living there as a tax resident and saving 100% on his taxes he was paying back in the UK.
Tax Savings: 100% on his UK income
How It Works: His income from UK or anywhere else outside Panama would not trigger any additional taxes in this jurisdiction as it's sourced from another country.
Investment Requirements: To obtain permanent residency in Panama and become a tax resident, which could also lead to citizenship in 5 years, he would only need to invest US$200,000 (i.e., GBP 151,371) to qualify for the Friendly Nations Visa.
ROI Timeline: This means the investment would have paid for itself within 6 months of residing there as a tax resident.
Why Not Ideal: However, due to the time zone and travel distance, Panama may not have been his ideal choice compared to Greece and Dubai.
For James, the calculations are a no-brainer. Anywhere he goes will be feasible and pay for itself, but Greece, Panama, and Dubai would save him big.
His Choice: He decides to become a tax resident and EU resident in Greece, while residing full time in Dubai due to the very large UK expat community while conducting business from the DIFC (Dubai International Financial Centre). During this time, he will still retain his UK citizenship.
In Jennifer's case from Canada, due to the weak Canadian currency, the options may not be as wide open as it was for James. Italy's flat tax regime would not be very feasible for her, but she would like to stay in the North American time zones to keep close to her clientele and main markets.
Tax Savings: Approximately CAD 194,988 per year
How It Works:
- Pays €120,000 for her and her spouse to become tax residents of Greece
- Her children would not have any income at this point to justify changing their tax residencies
- Investment Requirements: She would need to invest €500,000 to qualify for this program in Greece.
Why Not Ideal: For her, this option may not be the ideal choice either and would look to other jurisdictions that meet her most important criteria (proximity, flight time, time zone, and financial feasibility).
Although Dubai would save her 100% on her personal income, it doesn't meet her time zone and proximity requirements to North American markets.
Tax Savings: Approximately CAD$300,000 per year (100% tax savings)
Why Panama Works:
- Aligned with North American time zones
- Saves 100% on taxes on all overseas sourced income
- Within 5-hour flight time to Toronto and other regions in her main market
Investment Requirements: She would need to invest at least USD$200,000 in real estate in Panama.
ROI Timeline: The investment would pay for itself in the first year of tax savings.
Timeline: She can gain this status within 90 days of the investment.
To structure her Canadian exit, she spoke with her CPA, and they planned a sale of her shares in her company to a trust before her move, in order to optimize her CRA 'disposition' when becoming a non-tax resident of Canada.
Business Restructuring: She was also advised to structure a company in Florida or Delaware, or any other tax-friendly jurisdiction such as BVI or Dubai where she would not be a resident, but rather continue her company brand to develop while keeping her Canadian operations with a skeleton crew and keeping profits minimal.
Asset Disposition: This entire project for her and her family would include disposing of her assets in Canada at the time of becaming a non-tax resident.
Banking Advantage: Thankfully, she was banking with RBC and CIBC wealth management and did not have to pay a hefty 'exit' tax to the CRA since she had over CAD$1M in her portfolio invested through her TFSA and RRSP's, that allowed the bank to provide a guarantee letter to the CRA. Basically, she became a non-tax resident on 'credit'.
She enjoys:
- 100% of her income in Panama as it's all sourced from outside the country
- Pays only 0.6-0.8% max property tax
- Her younger child attends Balboa Academy in Panama City, which are the top-rated private schools in the country with UK and US curriculums respectively
- Quality of Life Improvements: The choice is clear for her and the savings are undoubtedly in her family's best interest with Panama City offering:
All-year sunshine
Safety which Toronto cannot provide
An American-style healthcare system which provides her immediate access to any medical specialist she needs and will gladly pay for with the tax savings she has achieved
For Daniel M., our American citizen, his tax savings would be significant but would only work out if he traded in his American citizenship for another passport.
Daniel has a bigger hurdle to overcome than the other profiles in this article from UK and Canada since the US taxes its citizens worldwide and he cannot become a non-tax paying resident of the US.
If you’re an American citizen exploring a second nationality, get in touch with our team to build the strategy that fits your goals.
Tax Savings: US$400,000 per year
How It Works:
- Pays only €120,000 for himself and his spouse (his children would not be earning any income to include in the tax status)
- His income from the US would not trigger any additional taxes in Greece as it's sourced from outside Greece
- Investment Requirements (If Residing in Greece): He would be expected to make an investment of €500,000 in:
Greek government bonds, OR
Real estate, OR
Greek securities
Immigration Benefits: If he invests in the right asset category, he can qualify for the Greece Golden Visa as well to obtain residency status for himself and his family in Greece. This money would not be a donation but rather a redeemable investment until he chooses to cancel the residency or convert to citizenship status after 7 years.
Tax Savings: Approximately US$145,000 per year
How It Works:
- Pays €340,000 for himself and his spouse as flat tax regime participant of Italy in 2026 with the new increased flat tax fee
- His children would not be earning any income to participate in the non-dom regime in Italy but can join him as residents if he applied for the immigration status separately
- His income from US would not trigger any additional taxes in Italy as it's sourced from outside Italy
- Investment requirements in order to obtain residency in Italy:
- There are various ways to become an Italian resident, yet the simplest is investing:
€250,000 in Italian startups, OR
€500,000 in a private or listed company in Italy
Can include himself, his spouse, and children to obtain immigration status in the country
For other alternatives, reach out to our office and we’ll develop a plan tailored to your needs.
Tax Savings: All of his income, i.e., US$540,000 per year
How It Works: He keeps every penny of his income in his own pocket. His income from outside or inside the US would not trigger any additional taxes in the UAE as personal income, as UAE does not tax personal income in any way.
Tax Savings: 100% of all taxes paid in California
How It Works: His income from US would not trigger any additional taxes in Panama as it's sourced from outside Panama.
Critical Requirement: Keep in mind that for all of Daniel's scenarios, he would have to have traded in for another citizenship, meaning he has renounced his US citizenship to break away from the tax obligations.
Daniel M., with his new citizenship, renouncing his American citizenship, chooses to:
- Obtain an Argentinian passport in 2026 when program becomes available
- Become a tax resident of Italy
- Reside in Dubai
Why This Combination: Mainly due to the English-speaking environment in Dubai, while being a Schengen/EU region resident giving him access to the EU region at all times no matter what citizenship he owns.
Strategic Reasoning: His choice of Italy is due to him planning to dispose of his shares in the next 3 years and liquidating his positions in his tech company, hence the future tax planning makes sense even if he pays €340,000 per year.
Each profile and financial situation of various business owners and applicants around the world will vary. No specific solution could match all applicants, hence it's important to consider all options, compare them side by side, with our team and your CPA's from your home jurisdictions and our tax partners in the final destination countries.
One fact remains: if you are earning $250,000, $500,000, or over $1M a year, you're paying way too much to the tax man for what you're getting in return. The numbers speak for themselves, it costs you more not to do anything than to initiate and structure an 'exit' from your country.
A flat tax system charges a fixed annual amount regardless of income level (like Greece's €100,000 or Italy's €300,000), while a territorial tax system only taxes income earned within that country's borders, exempting all foreign-sourced income (like Panama).
US citizens face citizenship-based taxation, meaning they must pay US taxes on worldwide income regardless of where they live. To benefit from these programs, US citizens would need to renounce their citizenship and obtain another passport first.
Additional costs include:
- Required investments for obtaining residency or accessing the particular tax regime (€500,000 for Greece, US$200,000 for Panama, 2M AED for Dubai)
- Relocation expenses
- Potential exit taxes from home country
- Higher cost of living in some jurisdictions (especially Dubai)
- Legal and accounting fees for proper structuring
To become a tax resident in most countries, you are typically required to spend 183 days or more within a 12-month or calendar year. In some cases, you may also be deemed a tax resident if the country becomes the center of your personal or economic life, even if you spend fewer days there physically.
DISCLAIMER
INGWE Immigration provides global Investment & Migration consulting services and is licensed for select destinations. For all other jurisdictions, we collaborate exclusively with verified, licensed immigration, bank, legal and tax experts. The content shared in this article is for informational purposes only and should not replace personalized legal, immigration, or tax advice.
