hnwis residency comparison chart 2017/2018 · hnwis residency comparison chart 2017/2018 we are...

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HNWIs RESIDENCY COMPARISON CHART 2017/2018

We are pleased to enclose the Firm’s annual HNWIs Residency Comparison Chart (8th edition). In collating this information, we rely on our trusted

partners within jurisdictions where the Firm does not maintain a presence. We thank all Firms who took the time to provide up to date information

and keep us well informed of any changes. While we have exerted our best efforts to ensure that all the information gathered contained in the

Chart are accurate, we always recommend that specific professional advice is sought prior to any actions.

Methodology

Highlighting the features of 27 jurisdictions where HNWIs may consider relocating for tax purpose, the present Chart does not constitute an exhaustive list. Rather, it constitutes an eminently subjective selection of the jurisdictions which, in the Firm’s opinion, constitute the best all-round propositions for HNWIs relocation.

The Firm did select, compile and consider the following 22 factors:

• General easiness to obtain a Residence Permit

• Quotas on the number of Residence Permits issued yearly

• Requirement to obtain a fiscal quitus from the foreign country

• Mandatory interview; presence during application process

• Time frame for completion of the procedure and issuance of Residence Permit

• Requirement to effectively reside in the country

• Requirements in respect time spent annually in the jurisdiction (“day-counting”)

• Validity of Residence Permit; renewability of Residence Permit

• Annual tax filings

• Level of taxation on individuals (income tax, wealth tax, gift tax, inheritance tax, capital gain tax), minimal tax liability/lump-sum tax

• Tax basis (e.g. worldwide income, income remitted to the jurisdic-tion, income generated in the jurisdiction)

• Costs of issuance and renewal of Residence permit

• Costs of ongoing substantiation (e.g. cost of 1-bedroom flat)

• Location and international accessibility

• Climate

• Political stability

• General quality of life

• Cultural offering

• Security

• Cleanliness

• Presence of international schools

• Presence of internationally recognized financial, legal and tax ser-vices providers

The factors above, are a reflection of those jurisdictions to which at least one of the Firm’s client did relocate over the past three years. Where a way of securing a Residence Permit exists but its practical use was marginal over the same time period, it was not considered altogether. In this respect, the Chart is a true reflection of the Firm’s practice in the field of HNWIs relocation.

What’s New?

Global growth is firming, contributing to an improvement in confidence. A recovery in industrial activity has coincided with a pickup of global trade and with residential planning remaining on top of the agenda of many HNWIs and their families.

The UAE has continued to be a strong draw for citizens of both old world and emerging economies.

Programs in Spain, Portugal, Cyprus and Malta – providing special residency and/or tax status granted to non-EU nationals, coupled with potential mid-term citizenship access – remained popular, particularly amongst citizens from emerging economies. A number of applicants were drawn towards Italy, a relative newcomer in that group.

More exotic jurisdictions – e.g. Panama, Bahamas, Thailand and Malaysia – have continued to witness significant interest from both European and emerging market applicants. These jurisdictions are often used as alternative residencies for back-up purpose.

One interesting trend to follow is the increasingly more stringent requirements applicable to the issuance of tax residence certificate (TRC). This item is specifically tracked across all jurisdictions covered.

For a couple of years now, traditional jurisdictions such as the UK, Singapore, and Switzerland have been losing ground from a strict volume stand-point. A fascinating topic to monitor is the impact of the Brexit vote on the UK “resident non-domiciled” crew.

Who we are

We are a multi-services platform catering to a broad spectrum of clients – from individual entrepreneurs and local SMEs to wealthy interna-tional families, to established blue-chip companies and multinationals. Our one-stop-shop offering is unique in the Middle East: a holistic and cross-disciplinary combination of a market-leading corporate services firm, a law firm’s specialist expertise and a regulatory & compliance services practice, all through one single platform. We have broad experience in assisting clients with multi-jurisdictional interests in securing an alternative residence and domicile. Bringing together our tax and private wealth expertise, along with the broad capabilities of our sister fiduciary firm, our team can support our clients in all aspects of their immigration.

Headquartered in the UAE, we are an entrepreneurial firm for entrepreneurial clients.

Who will assist you

Stephanie CampbellHead of Immigration [email protected]

Yann MrazekManaging Partner [email protected]

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EUROPE (1)


Portugal Spain Gibraltar Ireland

Main advantages

No requirement to live in PortugalFavorable tax regime for non-habitual residentsNo wealth taxFree access to all Schengen statesComprehensive tax treaty networkGood standard of living and health care facilitiesPleasant climate

No minimum stayNo capital gain, wealth, gift and inheritance taxNo tax filingFree access to all Schengen statesComprehensive tax treaty networkGood standard of living and health care facilitiesPleasant climate

No minimum stayNo minimum investmentNo capital gain, wealth, gift and inheritance taxNo taxation on interest savingsGood standard of livingPleasant climate

Favourable tax system for non-domi-ciled individualsComprehensive tax treaty network care facilitiesAccessibilityPolitically stable and secure environ-mentGood standard of living and health care facilitiesGood education system

Key conditions in practice

Real estate investment in Portugal of a min. market value of EUR 500,000, or EUR 350,000 (“rehabilitation real estate“)orInvestment of a min. value of EUR 1 million in Portugal (including purchase of shares in companies)orCreation of 10 job positions in PortugalorCapital transfer (min. amount of resp. EUR 250,000 (artistic production, maintenance of cultural heritage), EUR 350,000 (scientific research, integrat-ed in national system) and 500,000 (purchase of units in capital funds aimed at the capitalization of SMEs)

Real estate investment in Spain of a min. market value of EUR 500,000orInvestment of a min. value of EUR 2 mio in Spanish public debtorInvestment of a min. value of EUR 1 mio in Spanish enterprisesorDeposit of a min. value of EUR 1 mio with Spanish finance entities

Real estate investment in GibraltarorSubscribe to a tenancy agreementandApplicant to evidence wealth in excess of USD 2.6 mio

Investment of a min value of EUR 500,000 in Irelandanda minimum net worth of EUR 2 mioorEmployment Contract as highly skilled migrant for non-EU and EFTA citizensorAvail of the Start-up EntrepreneurProgramme with innovative business proposal and financial backing of at least EUR 75,000

Quotas on number of issued resi-dence permits

None None None None

Dependents’ visas

Yes, extendable to spouse, children (minor and adult children, if studying, single and economically dependent on the investor), parents and spouse’s parents, if dependent on the investor

Yes, can extend to spouse, civil partner, unmarried dependent children (below 18) disabled dependent children (above 18) and dependent parents

Main applicant needs to secure residence permit first, then apply for immediate family member(s)

Yes, can extend to spouse and depen-dent children


Yes, extendable to spouse unmarried children below the age of 18; and dependent between 18 – 24 in certain circumstances


Mandatory interview

No No No No

Presence of applicant during the application procedure

Required to initiate process and cap-turing of fingerprints

Required Not required for initial applicationRequired 2-3 weeks following initial application

None

Age restrictions (both for young and old people)

None, but generally the applicant should be an adult




Time frame for completion of procedure and issuance of residence permit

4-6 months 5-8 weeks 1 month 3-4 months

Validity & renewability of residence permit

Valid for 1 year – renewable for up to 2 yearsAfter 5 years, a permanent residence can be applied forbutSubject to holder (and his family in case of family residence permit) avoid-ing absence for 6 consecutive or 8 in-terpolated months (temporary permit) and 24 consecutive or 30 interpolated months (permanent permit)orIf through the Golden Visa, 7 days in the 1st year and 14 days in the subsequent period of 2 years (for 5 initial years, to qualify for permanent residence)

Valid for 1 year – renewable for up to 2 yearsAfter 5 years, a permanent residence can be applied for

Granted for an indefinite periodbutTo be endorsed by Gibraltar Finance Centre every three years

2 years to be extended for further 3 years – renewable for 5 years

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EUROPE (1)


Portugal Spain Gibraltar Ireland

Required legal presence “Day counting”

De lege: not requiredIn practice: 7 days in the 1st year and 14 days in the subsequent period of 2 years required to qualify for perma-nent residence

De lege: not requiredIn practice: 1 day each year to qualify for permanent residence

De lege: Not requiredIn practice: recommendable not to spend more than 183 days in another jurisdiction

De lege: one day per calendar yearIn practice: 1 day every 6 months + rec-ommendable not to spend more than 183 days in another jurisdictionLoss of residency if outside of the country for a year

Main conditions to obtain TRC

To spend 183+ days in country within a single calendar yearor Place of habitual residence in country as of 31/12

To spend 183+ days in country within a single calendar year

Primary professional activities conducted in Spain – e.g. as self- or otherwise employed in country

Main interests in Spain (e.g. depen-dent(s) living in country together with applicant)

To spend 183+ days in country within a single calendar year and over 300 days in aggregate over three consecu-tive years of assessment

To spend 183+ days in country within a single calendar year or280 days or more in a tax year plus the previous tax year taken together, with a minimum of 30 days in each year

Average costs of 1bdr flat (70m2)

Rental: EUR 10,000/year Rental: USD 8,500/yearPurchase: USD 187,000

Rental: USD 24,000/yearPurchase: USD 425,000

Rental: 1,500 (Dublin)Purchase: 300,000 (Dublin)

Taxation

Annual tax filings: mandatory for all taxable subjectsIncome tax: residents are liable on their worldwide income; non-residents are liable only on Portuguese source incomeNon-habitual residents which are liable on net employment and self-employment income from «high value-added activities» at a flat rate of 20%, foreign-source income may be exempted, under certain conditionsWealth/net worth tax: noneGift/inheritance tax: 10% stamp duty; spouses, descendants and ascendants are exemptedOther tax: 0.8% on free transfer of real estate

Annual tax filings: none under the special HNWI schemeIncome tax: residents are liable on their worldwide income; non-residents are liable only on Spanish source incomeNot applicable to persons benefiting from the special HNWI scheme, except for non-residents where no double taxation is in placeWealth/net worth tax: noneGift/inheritance tax: only if deceased person/giver or beneficiaries are resident in Spain for tax purposes or inheritance/gift of Spanish assets, none if beneficiary is lineal ascendant/de-scendent of deceased person/giver in certain communities (e.g. Madrid)

Annual tax filings: mandatoryIncome tax: residents are liable on their worldwide income; non-residents are liable only on Gibraltar source incomeHNWI who obtain a Category 2 indi-vidual would be liable to income tax on the first USD 104,000 of assessable income and would be subject to maxi-mum USD 38,750 taxCapital gain tax: noneWealth/net worth tax: noneGift/inheritance tax: none

Annual tax filings: mandatoryIncome tax: residents are liable only on Irish source income; foreign income is only taxable to the extent of amounts remitted to Ireland. Non-habitual residents which are liable on net employment and trade exercised in IrelandCapital Gains tax: none, except for foreign gains remitted to IrelandWealth/net worth tax: noneGift/inheritance tax: none for the surviving spouse, civil partners; for other beneficiaries – 33% after the tax free threshold

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EUROPE (2)

1. In practice, USD 130,000 is recommendable


Isle of Man United Kingdom Belgium Netherlands

Main advantages

No minimum stay to achieve resi-dence, but need to demonstrate living on IslandNo wealth, gift, capital gains or inher-itance taxesGood standard of living and health care facilitiesPolitically stable and secure environ-mentHighly skilled workforcePart of UK common travel area

No minimum stay to maintain the Investor visa but note that a day count applies if the applicant wishes to obtain indefinite leave to remain and British citizenshipCompetitive tax systemTax incentive schemesRelatively low capital gain taxNo wealth taxComprehensive tax treaty networkGood standard of living and health care facilitiesPolitically stable and secure environ-mentAccessibilityGood education system and univer-sities

No minimum stayNo minimum investment1

No wealth taxRelatively low to nil gift taxes (for movable property)Free access to all Schengen statesComprehensive tax treaty networkGood standard of living and health care facilitiesPolitically stable and secure environ-ment

No minimum stayCompetitive tax systemNo taxation on foreign savings and investment incomeReimbursement of school fees for children – tax freeNo wealth taxGood standard of livingFree access to all Schengen statesPolitically stable and secure environ-ment


(Entrepreneur) category requires an investment of at least £200,000 in a new or existing business that is registered in and pays tax in the Isle of Man. After the initial three-year period, a holder can apply for an extension of the Leave to remain in the Isle of Man for a further two years. After five years the individual can apply for Indefinite Leave to Remain (ILR) in the Isle of ManorInvestment of at least £2 million into a “permissible investment” in the Isle of Man. After the initial three-year period, a holder can apply for an extension of the Leave to Remain in the Isle of Man for a further two years. After five years the individual can apply for ILR in the Isle of Man. ILR can be accelerated to three years if an individual invests £5 million and two years if an individual invests £10 million

Investment of a min. value of GBP 2 million, GBP 5 million or GBP 10 million into qualifying UK investments

Investment of a min. value of USD 130,000 in BelgiumandApplicant to dispose of USD 600,000 (sufficient means of subsistence or the ability to obtain those means through work and health insurance)

Residence permit: full-time Employ-ment as highly skilled migrant (or blue cardholder) with min. salary EUR 57,000 and applicant to evidence proof of residency domicile in Nether-lands and ability to sustain one’s livingorInvestment of a min. EUR 1.25 million the Dutch economyorInvestment through Dutch American Friendship Treaty (preferential immi-gration scheme for US entrepreneurs and business proprietors). A US national has to invest the “substantial amount” of EUR 4,500 in the Dutch enterprise or at least own 25% of the shares of the company


None None None None

Dependents’ visas

Yes, extendable to spouse, unmarried children below the age of 18


Yes, can extend to spouse, partners and dependent children (dependent children must be 18 or under and have not formed an independent life)

Dependants can apply at the same time as the main applicant, or after the main applicant has secured the visa

Yes, can extend to spouse, registered partner, children or (sisters & brothers, grandchildren, parents or grandpar-ents subject to certain conditions)


Yes, extendable to spouse/registered partner and unmarried children under 18 years subject to certain conditions


Mandatory interview

No No – but the UK immigration authori-ties reserve the right to interview

Yes, for non EU/EFTA citizens No


No, unless a National Insurance num-ber is required

Not required Required for initial application and collection of residence permit

Not required


No None, but the main applicant must be at least 18 years old

Required for initial application and collection of residence permit



No residency permit required. If Na-tional Insurance number/work permit is required 2 to 3 weeks

4-8 months approximately 4-6 weeks 3-5 weeks

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EUROPE (2)

2. Except if the absence was due to force majeure or the obligation to fulfil a compulsory military service3. Look-through taxation may apply in relation to Trusts, Foundations & listed off-shore companies


Isle of Man United Kingdom Belgium Netherlands


None Valid for 3 years – renewable for up to 2 yearsIf investing £2 million, after 5 years, the main applicant can apply for indefinite leave to remain (permanent residency) If investing £5 million, after 3 years, the main applicant can apply for indef-inite leave to remainIf investing £10 million, after 2 years, the main applicant can apply for indef-inite leave to remain

EU/EFTA citizens: valid for 5 years – after 5 years of continuous residency, a permanent residence can be applied forAll others: valid for 3 years (limited stay) or 5 years (unlimited stay) – renewable for same term until perma-nent residence permit is issued,butSubject to avoiding absence for more than 3 months but less than 1 year (provided local authorities are in-formed) and more than 1 year (unless demonstrated that the main interests were located in Belgium)

Valid for maximum of 5 years – re-newable for up to 5 years (provided the applicants centre of residence is in Netherlands)


By Law: Not specifically requiredIn practice: Recommended to spend at least 90 days per tax year physically present on Island and to have accom-modation available

De lege: not required to maintain the investor visaIn practice: To be eligible to apply for indefinite leave to remain (permanent residency) the main applicant should not spend more than 180 days in any 12-month period outside of the UK. Please note, however, the day count in the UK is higher if the main applicant and dependants wish to apply for Brit-ish citizenship after holding indefinite leave to remain in the UK for one year

De lege: not requiredIn practice: 183 days is recommend-able if outside of the country for between 3-12 months, applicant must inform local authorities of the expected departure and return; loss of residency if outside of the country for more than one year2

De lege: 4 months per yearIn practice: Netherlands should be the main “centre of interests”Loss of residency if a min 120 days period of stay in the country within a year is not met


To spend 183+ days in country within a single calendar year orTo spend 90+ days in country per calendar over a period of four+ con-secutive years

Confirmation of type of income in respect of which one wishes to make a claim and particular income article under which one wishes to make a claim.Confirmation of the period for which one requires TRC (if not for the date on which the certificate is to be issued)

Presumption of tax residency: – if registration in the national registerorFor spouses (and legally cohabiting partners) where the household (domi-cile) is established

Qualification as tax residents based on factual analysis taking into con-sideration different components, e.g. 183 days in country within a single calendar year

For married applicant: family accom-panies applicant into countryorFor single applicant: to spend 183+ days in country within a single calen-dar year


Rental: £10,000 per yearPurchase: £200,000+


Rental: USD 11,500/yearPurchase: USD 252,000 (in Brussels)

Rental: EUR 18,000/ year (in Amster-dam centre)Purchase: USD 450,000

Taxation

Annual tax filings: mandatoryIncome Tax: Residents are taxed at maximum rates of 20% on worldwide income. Credit for foreign taxes suf-fered available on a unilateral basis.Income tax can be capped at a maximum of £150,000 per annum for 2018/19, to be elected in the 2017/18 tax year (£175,000 per annum for 2019/20; elections commencing from the beginning of the 2018/19 tax year) on application for a 5 year period. Liability to income tax can be limited to Isle of Man sourced employment in-come if the individual is a key employ-ee and the concession was granted by the Income Tax Division. Limit applies for first three fiscal years. This limit is independent of the tax cap.Company taxation: Companies gener-ally taxed at 0%, individuals taxed at 20% maximum but can be tax capped at £125,000 (£150,000 from 2018/19) per annum; companies taxed at 0% (unless derive income from IOM land/property taxed at 20% and retail with profits > £500,000 or banking taxed at 10%)Capital gains tax: NoneWealth/net worth tax: NoneGift/inheritance tax: None

Annual tax filings: mandatoryIncome tax: tax residents are liable on their worldwide income, non-residents are liable on their UK source income, such as compensation attributable to UK workdays and certain UK-source investment incomeSpecial regime available to so-called “resident non-domiciled” individuals: only UK source income and foreign income remitted to the UK is subject to tax, after 7 years, remittance basis charge (GBP 30,000 to GBP 50,000 depending on the number of years of residence)Wealth/net worth tax: noneGift/inheritance tax: gift tax but with possible exemption; no inheritance tax for an estate of up to a max value GBP 325,000 and 40% on any value beyond the threshold

Annual tax filings: mandatoryIncome tax: residents are liable on their worldwide income; non-residents are liable only on Belgium source income; Income subject to progressive tax rates (max tax rate of 50% to be increased with local surcharges (average 6%)3

Capital gain tax: none on private gain realized in the course of normal trans-actions, except for:

• property transaction gains on specific investment products, 30%

• real estate taxable at 33% or 16.5% depending on certain conditions

• capital gains on “abnormal” transactions taxed at 33%

• transfer of substantial share-holdings, 16.5%

Wealth/net worth tax: noneGift/inheritance tax: vary between 3% and 65% (Flanders) and 3% and 80% (Brussels & Wallonia) depending of the region of residence of the deceased/donor, depending of the region special rates for gifts with respect to (family owned) businesses or immovable property

Annual tax filings: mandatoryIncome Tax: residents are liable on their worldwide income; non-residents are liable on specific Netherlands source income. Income taxed between 30% and 52% depending on the type income.Exception: Tax free payment of 30% for highly skilled migrants and exemption of foreign savings and investment income availableCapital gain tax: none with exceptions of sale of shares in in the NetherlandsWealth/net worth tax: noneGift/inheritance tax: 10-40%, only if deceased person/giver is a resident in Netherlands

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EUROPE (3)


Luxembourg Switzerland Monaco Italy

Main advantages

No wealth taxFree access to all Schengen statesComprehensive tax treaty networkGood standard of living and health care facilitiesPolitically stable and secure environ-mentAAA rated stateStrict banking secrecy for Luxembourg residentsAccessibility

No need to declare worldwide income and assets under annual lump-sum taxation regimeNo capital gain tax, except on sale of real estateFree access to all Schengen statesComprehensive tax treaty networkGood standard of living and health care facilitiesPolitically stable and secure environ-mentGood education system and univer-sities

No income, capital gain, wealth and local taxNo direct inheritance tax, except for assets located in the countryNo tax on gifts to spouse, ancestors or descendantsNo tax filingFree access to all Schengen statesGood standard of living and health care facilitiesPleasant climatePolitically stable and secure environ-ment

No wealth taxNo minimum investment requiredComprehensive tax treaty networkFree access to all Schengen statesGood standard of living and health care facilitiesPleasant climate


There is no specific residence permit for “investors”.Permit for private reasons: subject to approval by the Ministry of Immigra-tion and Foreign Affairs, namely third country nationals who can prove that they can live with their own resources without exercising a gainful economic activity (min. EUR 23.100 per year)orSelf-Employed permit: prove applicant meets the required skills to exercise the described activity, necessary resources to carry out his activity in Luxembourg, demonstrate economic utility of the activity and proof appli-cant has an appropriate accommo-dation.orPermit for employees: Subject to the declaration of the employer with the Employment Administration he cannot find a suitable candidate on the local labour market

Lump sum taxation – where availableorEmployment contract for at least 12 monthsorProof of self–employmentIn case of no professional activity, proof of ability to sustain one’s living as well as existence of health insurance

Real estate investment in MonacoorSubscribe to a tenancy agreementandReference from a bank in Monaco confirming that the applicant has sufficient funds (i.e. at least €500,000) available to live in the Principality

Real estate investment in Italy (no min value)orSubscribe to a tenancy agreement (no min value)andProof of independent, stable and regu-lar income with income from financial resources of an amount of not less than Euro 12,000 per year (excluding employment income) plus 6,000 each per family membersgetting an insurance medical policy (cost 300 euros)


None EU/EFTA citizens: noneAll others: yes for first time applicants except for retirees above 55 years

None None

Dependents’ visas

Yes, extendable to spouse/registered partner and unmarried children under 18 years subject to certain conditions


Yes, extendable to spouse and un-married children below 18 subject to certain conditions


Yes, extendable to spouse, children 16 years old and below


Yes, extendable to spouse, unmarried children below the age of 18 and dependent parents


Mandatory interview

No No Yes No


Yes Not required Yes, required for initial application and for interview

Required for initial application and collection of residence permit




16 years of age and above None, but generally the applicant should be an adult


1 to few days EU/EFTA citizens: 2-4 weeksAll others: 2-4 months

EU/EFTA citizens: 7-10 weeksAll others: depending on the French Embassy of their country of living

4-8 weeks


EU citizens: granted for an indefinite period

EU/EFTA citizens: 5 years (B permit). After 5 years, a permanent residence (C permit – with no limit on validity) can be applied forAll others: valid for 1 year – annual renewal until C permit can be applied for (10 years initial period, based on the canton and commune of the legal domicile chosen different additional regulations may apply)butSubject to the holder (and family member in case of family residence permit) visiting Switzerland once every 6 months

Residence permit 1-3: valid for 1 year and renewable yearlyResidence permit 4-6: valid for 3 years and renewable for the same termResidence permit 7 & beyond: valid for 10 years and renewable for the same termbutSubject to the holder (and family member in case of family residence permit) residing in Monaco for at least 3 months per year

Valid for 1 year (or longer, according to the visa entry) – renewable for up to 5 years (provided the applicant does not remain outside Italy for a continuous period of over 6 months)After 5 years, a permanent residence can be applied for citizenship

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EUROPE (3)


Luxembourg Switzerland Monaco Italy


No minimum required, but it is recommended to spend a minimum of time per year

De lege: min. of 180 days per yearIn practice: can be less if special personal situation applies, importance of the “centre of interests” criterion in order not to arouse scrutiny from local authorities. Authorities may ask for evidence of regular presenceLoss of residency if the min 180 days mandatory period of stay in the coun-try within a year is not met

De lege: required: 3 months; 6 months per year (or main centre of activities) if certificate of residence is neededIn practice: 183 days is recommend-ableLoss of residency if a min 90 days mandatory period of stay in the coun-try within a year is not met

De lege: Applicant should ensure not to leave Italy for a continuous period of over 6 monthsLoss of residency if a min 180 days period of stay in the country within a year is not met


To spend 183+ days in country within a 12 months period

If applicant stays in country with inten-tion to exercise gainful activities for a consecutive period (ignoring short absences) of 30+ daysorApplicant stays in country with no in-tention to exercise gainful activities for a consecutive period (ignoring short absences) of 90+ days

Provide proof of residence (title to real estate property or lease relevant utility bills for previous 12 months.Certify on honor that one:Resides 183+ days in country per calendar yearor Has main centre of activities in country

Applicant registered in the Records of the Italian Resident PopulationorApplicant has a ‘residence’ in Italy (habitual abode)orApplicant has a ‘domicile’ in Italy (prin-cipal centre of business, economic and social interests, e.g. the family)


Rental: EUR 12,000/ yearPurchase: EUR 420,000


Rental: USD 57,000-80,000/yearPurchase: USD 3,400,000-5,400,000


Taxation

Annual tax filings: mandatoryIncome tax: residents are liable on their worldwide income; non-residents are liable only on Luxembourg source income. Income taxed at progressive rates up to 43% (excluding additional contribution).Capital gain tax: short-term capital gains subject to progressives rates. Long-term gains (6 months holding period) on substantial participation (more than 10%) partially exempt under certain conditions. Capital gains on non-substantial shareholdings (10% or less) and other securities tax-free only if they are realized more than six months after acquisitionWealth/net worth tax: noneGift/inheritance tax: if deceased person resident in Luxembourg on the entire net estate (exemptions available) or on Luxembourg real estate for non-Luxembourg resident deceased. Rates from 0% to 48%. 0% rate to heirs In direct line and spouse. Gift and donations taxed only if required to be registered with the Administration de l’Enregistrement. Rates range from 1.8% to 14.4%, depending on the relationship between the donor and the donee

Annual tax filings: mandatoryIncome tax: levied at federal, cantonal and municipal level 4. Rates for federal tax are progressive up to 11.5%. Can-tonal and municipal tax rates varyResidents are liable on their worldwide income; non-residents are liable only on Swiss source incomeNot applicable to HNWI eligible for lumpsum taxationCapital gain tax: none, except on sale of real estateWealth/net worth tax: levied at the cantonal and municipal levelGift/inheritance tax: based on the canton of the domicile chosen, not applicable for all cantons

Annual tax filings: noneIncome Tax: none (French citizens are taxed in France)Capital gain tax: none (French citizens are taxed in France)Wealth/net worth tax: noneGift/inheritance tax: on Monaco assets only: 0 to 16% on Monaco assets (Spouse, ancestors or descendants – exempted, Brothers and Sisters – 8%; uncle, aunts, nephews, nieces – 10%; unrelated parties – 16%)

Annual tax filings: mandatory, except of owning the house without rental incomeIncome Tax: residents are liable on their worldwide income, but there’s no double taxation if any income is taxed abroad (like pensions, capital gains etc.); non-residents are liable only on Italian source income. Income subject to progressive tax rate (ranging from 23% to 43%) to be increased by local surcharges (average rate 2% to 3%). Rental income can be taxed at a fixed rate of 21% or 10% under certain con-ditions of the lease contract (so called “cedolare secca” )Capital Gain Tax: flat rate of 20% arising from the sale of real property; total exemption if sale occurs after 5 year from the purchase in case of natural persons Wealth/Net Worth Tax: noneGift/Inheritance Tax: If the heirs are spouse or direct ascendants/dece-dents tax rate 4% (exemption applies up to Euro 500,000 euros); in case of other heirs tax rate ranges from 6% to 8% (subject to certain conditions).

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EUROPE (4)


Malta Hungary Greece Latvia

Main advantages

Permanent Residence from day oneFamily members are included (no age limit for children)No minimum stayNo wealth, gift and inheritance taxNo worldwide tax, remittance basis onlyCertificate for permanent residence for life & Residence cardFree access to countries in the Schen-gen AreaComprehensive tax treaty networkGood standard of living and health care facilitiesPleasant climatePolitically stable and secure environ-ment

No minimum stayNo capital gain under certain circum-stances No net wealth taxNo gift and inheritance taxFree access to all Schengen statesComprehensive tax treaty network

No minimum stayNo wealth taxFree access to all Schengen statesComprehensive tax treaty networkGood standard of living and health care facilitiesPleasant climate

No minimum stayAll foreign income exempted even if remitted to LatviaNo wealth taxFree access to all Schengen states


Real estate investment in Malta (for non EU/EFTA citizens, min. value of EUR 320,000 in Malta / EUR 270,000 in Gozo/South of Malta)orProperty rental (for non EU/EFTA citizens, annual rental of not less than EUR 12,000 in Malta/EUR 10,000 in Gozo/South of Malta)+Investment of at least EUR 250,000 in governmental bonds+Government contribution of EUR 30,000+Proof of an annual income of not less than EUR 100,000 per year arising outside Malta or possession of capital of not less than EUR 500,000

Investment of a min. value of EUR 300,000 in a governmental investor residency bond program either personally or through a business entity in which the applicant is the majority shareholder of (returned to the inves-tor after 5 years

Real estate investment in Greece of a min. market value of EUR 250,000orSubscribe to a tenancy agreement of at least 10 years with a min. total contract value of EUR 250,000orSubscribe to a 10 year lease of hotel accommodation or furnished tourist accommodations (houses) in tourist accommodation complexes with a min. total value of EUR 250,000

Constitution of a company that employs no more than 50 employees and has an annual turnover of no more than USD 12 mio (including purchase of shares in companies of a min. mar-ket value of USD 57,000 plus payment of USD 12,000 in the state budgetorReal Estate investment of a min. mar-ket value of USD 280,800orinvestment in a Latvia credit institu-tion of a min. value of USD 315,000 plus payment of USD 28,000 in the state budgetorPurchase of state securities of a min. value of USD 280,000 plus payment of USD 28,000 in state budget


None None None None

Dependents’ visas

Yes, extendable to spouse, partner in a long durable relationship, dependent children, parents and grandparents under certain conditions. There are no age limits for children provided they are un-married and economically dependent on the Main Applicant

Yes, extendable to spouse and children under the age of 18 as well as parents under the care of the main applicant


Yes, extendable to spouse and children under the age of 21 as well as parentsunder the care of the main applicant


Yes, extendable to spouse and children under the age of 18


Mandatoryinterview

No mandatory interview is required No No No, with possible exceptions


Required for biometrics test after in principle approval

Required for initial application (possi-ble through consulate abroad)

Required only at the stage of the reception of the applicant’s biometrical data. If the applicant is not present the day of the application, there is a six-month time frame to arrange the meeting for this purpose.

Required for visa processing and collection of residence permit


None, but the Main Applicant must be 18+





3-4 months 2-3 weeks 2-6 months 2-3 months

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EUROPE (4)


Malta Hungary Greece Latvia


Residence Certificate valid for lifeResidence Card valid for 5 years – renewable for up to 5 years

Granted for an indefinite period but permit per se subject to periodicalrenewals (after 5 years)

Non EU/EFTA citizens: up to 5 years – renewable up to 5 years

Valid for 5 years – to be registered yearlybutSubject to holder (and his family in case of family residence permit) visit-ing Latvia once every 6 monthsAfter 5 years, a permanent residence can be applied for


De lege: not required De lege: not requiredIn practice: recommendable not to spend more than 183 days in another jurisdiction

De lege: not requiredIn practice: recommendable not to spend more than 60 days every 3 months in another jurisdiction

De lege: not requiredIn practice: recommendable not to spend more than 183 days in another jurisdiction


To spend 183+ days in country within a single calendar year orEvidence of intention to reside in country in spite of professional and/ or personal circumstances not allowing applicant to meet 183+ days threshold

Neither the tax authority nor any other authority issues certificates of residence

To spend 183+ days in country within a single calendar year orHas domicile or habitual residence or center of (personal, social, financial) interests in country

Applicant registered (declared) place of residence in countryTo spend 183+ days in country within a single calendar year


Rental: Approx €1,200 per month upwards depending on location Purchase: Approx €100.000 upwards depending on location


Rental: USD 11,000/yearPurchase: USD 133,000A 2BR villa (200m2) in the capital can currently be bought for the equivalent of the real estate investment min. market value


Taxation

Annual tax filings: Depending whether the client is registered as tax resident of Malta. Income tax: Maltese tax residents who are not domiciled in Malta are taxable on a remittance basis. Non-domiciled residents of Malta are taxable on a re-mittance basis (0-35%) only on foreign source income (not foreign-source capital) remitted to Malta and only to the extent remitted. Income and cap-ital gains arising in Malta are always subject to tax in Malta at the applica-ble personal income tax rates.Capital gain tax: none for capital gains arising outside Malta, whether or not remitted to Malta;None for capital and savings remitted to Malta.Wealth/net worth tax: noneGift/inheritance tax: none

Annual tax filings: mandatory [if the applicant is a tax resident in Hungary, i.e spending more than 183 days in the country]Income tax: residents are liable on their worldwide income; non-residents are liable only on Hungarian source in-come; income subject to 15% personal income taxCapital gain tax: noneWealth/net worth tax: no, except for real estate tax, depending on the local municipalityGift/inheritance tax: exemption from gift and inheritance duty for surviving spouse, grandparents, and descen-dants

Annual tax filings: mandatory – but only for property tax or income tax in the case there is rental income from tenanted propertiesIncome tax: residents are liable on their worldwide income; non-resi-dents are liable only on Greek source income; income taxed as follow: 15% on income from dividends and shares’ royalties; 15% interest income from de-posits; 15% on rental income up to EUR 12,000 and 35% thereinafter and 45% on rental income up to EUR 35,001Capital gain tax: 22% on capital gain up to EUR 20,000, 29% from EUR 20,001 to EUR 30,000, 37% from EUR 30,001 to EUR 40,000 and 45% thereinafterWealth/net worth tax: noneGift/inheritance tax: tax rate 0% to 40% depending on the proximity of rel-atives to the deceased and the value of asset inheritedLand tax: varies according to portfolio. Key points for its calculation are the area, the price of the zone and the age of the property (ex: apartment with an area of 100m2, up to 10 yrs old, in a zone with an average price has a land tax of EUR 750 per year approx.)

Annual tax filings: mandatoryIncome tax: residents are liable on their worldwide income; nonresidents are liable only on Latvia source income Current rate is 23% (except for capital income subject to reduced ratesCapital gain tax: taxed as revenue gains; 2% on sale of the property or real estate company sharesWealth/net worth tax: noneGift/inheritance tax: No inheritance tax except for royalties received by legal successor of the deceased person which are taxable as personal income (15%); gift above USD 1,500 are subject to 15% tax if received from non-relatives

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EUROPE (5)


Cyprus France Bulgaria

Main advantages

No minimum stayNo capital gain (except in certain cases), wealth, gift and inheritance taxScheduled to join Schengen states by 2016Comprehensive tax treaty networkPleasant climate

No minimum stayCompetitive tax system for foreigners who decide to live in FranceFree access to all Schengen statesExcellent standard of living and health care facilitiesGreat industry, infrastructures and transport facilitiesGood education system and universitiesPolitically stable and secure environmentExcellent lifestyle ((the French “art de vivre)Accessibility

No minimum stayLow capital gain, gift and inheritance taxNo wealth taxDeductions and allowancesComprehensive tax treaty network


Real estate investment in Cyprus of a min. market value of EUR 300,000 (VAT is not included) and evidence of payment for at least EUR 200.000 (not including VAT) should be provided upon the submis-sion of the application. It should be stressed that the full payment of the real estate value shall be settled in an account in a financial institution in Cyprus and the said amounts shall be transferred to Cyprus from abroad. It is noted that the applicant should submit together with the application, title deeds, or a sale contract in his/her name and/or his/her spouse, which has been officially filed at the Department of Lands and Surveys, of the above said real estate investment. The real estate investment shall be sold for the first time by a development company.andApplicant should submit a confirmation letter from a financial institution in Cyprus that he/she has deposited a minimum capital of EUR 30,000, blocked for a period at least 3 years). It must be approved that the said amount has been transferred to Cyprus from abroad.andApplicant should prove evidence of an annual income of at least EUR 30,000,plus an additional EUR5,000, for each dependent person of the applicant’s family (spouse and children), plus EUR 8,000 for every de-pendent parent or parent-in-law. This income should derive from abroad as well, and may include salaries from employment, pensions, dividends from shares, fixed deposits, rents etc. For the calculation of the total amount of the annual income, the spouse’s income may by also taken into consideration

Foreign investors has to undertake a planned investment and apply for the “Talent Passport “ pro-gram marked as ‘Business investor’. The minimum investment is at least €300,000 in fixed tangible or intangible assets.

Investment of a min. value of EUR 180,000 in Bulgaria.andApplicant to dispose of EUR 1 mioorInvestment of a min. value of EUR 511,292 in a gov-ernmental bond portfolio (returned to the investor after 5 years with no accrued interest)


None None None

Dependents’ visas

Yes, extendable to spouse and children under the age of 18. Unmarried children aged between 18 and 25, who prove that they are students in an institution of tertiary education abroad with at least six months of remaining study period from the date of the submission of the application and, furthermore, that they are financially dependent on the applicant. In such a case, the applicant must present an addition-al annual income of EUR 5,000 for every such depen-dent child as described above.

Main applicant needs to secure residence permit first, then apply for immediate family member(s). An Immigration Permit may also be granted to the parents and parents-in-law of the applicant/holder of an Immigration Permit with the submission of an application and the payment of the relevant fee, with the condition that the applicant/holder of an Immigration Permit presents only an additional an-nual income of EUR8.000 for every such dependent parent as described above.

The spouse and dependent children of a Talent Pass-port car holder can also enjoy the French residency.

By applying the spouse will obtain a ‘Talent Passport – Family’ residence permit. This permit authorizes the family to stay and get any paid employment and study in France as long as the foreign investor’s residence permit is valid.

Yes, extendable to spouse and unmarried children under the age of 21


Mandatory interview

No, with possible exceptions No No


Not required, since the application may be submit-ted through authorized representatives, which appli-cations must be accompanied by an authorization letter from the applicant stating the particulars, full address and contact number of the representative.

Investors living outside France will have to apply to the French consular authorities from their usual place of residence.

The residence permit should be applied for at the same time as the long-stay visa marked Passeport Talent (‘Talent Passport’) authorizing the foreign investor to enter France.

Once the applicant is in France, the residence permit is issued for the investor by the Prefecture (district) of their department of residence upon presentation of the long-stay visa.

Required for collection of applicant’s pre-approved residency visa; another visit is required if main appli-cant applying for dependents

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EUROPE (5)


Cyprus France Bulgaria


None, but generally the applicant should be an adult None None, but generally the applicant should be an adult


2 months from the date of the submission of a com-plete application

Around 3 months 6-9 months


Granted for an indefinite period but Subject to hold-er (and his family in case of family residence permit) visiting Cyprus at least once every 2 years. They should also visit Cyprus within one year from the date of issuance of the residence permit certificate.

Valid for 4 years – renewableApplicants must provide documents showing that they keep on matching with the terms of the re issuance of their residency card.Applications should be made by the Prefecture (dis-trict) of the applicant’s place of residence in France.

5 years – renewable for up to 5 years (if the appli-cant does not apply for citizenship after the initial 5 year term)


De lege: not requiredIn practice: to visit Cyprus at least once every two years + recommendable not to spend more than 183 days in another jurisdiction

No De lege: Not requiredIn practice: recommendable not to spend more than 183 days in another jurisdiction


Applicant to confirm no intention to undertake any sort of employment in Cyprus. Domicile or habitual residence or center of (person-al, social, financial) interests in country

Habitual abode of the applicant or family in country, or country is principal place of sojourn.Professional activities are carried out in countryorCentre of economic interests in countryTie-breaker tests including criteria e.g. permanent home, personal and economic relations (centre of vital interests), habitual abode, nationality,

Applicant registered (declared) place of residence in countryTo spend 183+ days in country within a single cal-endar year orCentre of economic interests in country


Rental: USD 9,500/yearPurchase: USD 206,220A 3Bdr flat (150 m2) flat in the capital can currently be bought for the equivalent of the real estate investment min. market value**These are estimates and may differ depending on the area and other factors.

Paris:Rental: €26,000/yearPurchase: €700,000

Nice:Rental: €14,300/yearPurchase: €350,000

Lyon:Rental: €11,500/yearPurchase: €350,000

Bordeaux:Rental: €11,500/yearPurchase: €350,000

Cannes:Rental: €14,200/yearPurchase: €455,000

Marseille:Rental: €10,900/yearPurchase: €210,000


Taxation

Annual tax filings: mandatoryIncome tax: residents are liable on their worldwide income; non-residents are liable only on Cyprus source income. Income taxed at progressive rates up to 35%. min. tax liability for non – EU/EFTA citizens: EUR 19,500Capital gain tax: none, except gains arising from the sale of real property located in Cyprus or shares in companies owning Cypriot real estate (20%)Special Contribution for the Defence of the Republic Law (SDC): residents not domiciled in Cyprus are not subject to SDC on interest, rents or dividends regardless of whether such income is derived from sources within Cyprus and is remitted to a bank account or economically used in Cyprus.Wealth/net worth tax: noneGift/inheritance tax: none

Non-dom rulesTo attract expatriates and high net-worth individuals to come and become tax residents in Cyprus.

Benefits of the new rulesForeign nationals who become Cyprus tax residents and can be considered as non-domiciled in Cyprus, will be exempted from Special Defence Contribution tax (SDC) on dividends, interest and rental income. This will make investments in dividend/interest earning assets i.e. shares and bonds more attractive. Subject to conditions that need to be met.

A special exemption scheme for expatriates exists to help attract company directors and employees to France by providing partial income tax exemption and diminishing their liability for the ‘wealth tax’ (impôt de solidarité sur la fortune – ISF).

ConditionsThe scheme is open to employees and company directors, regardless of nationality, coming to work full-time in France on condition that:They have not been a tax resident in France during the five years prior to the date they commenced their post.They are resident in France for tax purposes.

Annual tax filings: mandatoryIncome tax: residents are liable on their worldwide income; non-residents are liable only on Bulgarian source income; 10% on income generated in Bulgaria (non-resident individuals special regime); 10% on worldwide income if applicant physically resides in Bulgaria for more than 183 days within 12 consecutive months or conducts business in BulgariaDividends: noneCapital gain tax: capital gains arising from the sale of real property generallyare taxable (but certain exemption may apply)Wealth/net worth tax: noneGift/inheritance tax: 0.4% to 6.6% and levied at the municipal level

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REST OF THE WORLD (1)


UAE Mauritius Thailand Singapore

Main advantages

No minimum stayTotal exemption from income, wealth, gift and inheritance taxNo tax filingComprehensive tax treaty networkAccessibilityYearly sunny climateGood standard of living and health care facilitiesSecure environment

No minimum stayNo capital gains, wealth, gift and inher-itance taxComprehensive tax treaty networkYearly sunny climateGood standard of living

No minimum stayNo wealth, gift and inheritance taxGood standard of living and health care facilitiesTropical climate

All foreign sourced income of individu-als (except that received throughpartnership in Singapore) is tax ex-empted even if remitted to Singapore.No capital gains, wealth, gift and inher-itance taxComprehensive tax treaty networkGood standard of living and health care facilitiesPolitically stable and secure environ-ment


Constitution of a companyorReal Estate investment of a min. mar-ket value of USD 360,000

Occupation Permit (Investor, Profes-sional and Self-employed)orRetired non-citizen (should be 50 years of age, or above, and must undertake to transfer, to a local bank account in Mauritius, at least USD 40,000 annually) orReal Estate investment of a min. market value of USD 500,000 or its equivalent in any freely conver- tible foreign currency through the Integrat-ed Resort Scheme(IRS), Real Estate Scheme(RES), Property Development Scheme (PDS) and Smart City Scheme (SCS)

Non – Immigrant visa: Employment for 3 consecutive years with a minimum salary of THB 80,000Investment through company regis-tered in Thailand with a min. capital of at least THB 2 mio orThailand Elite visa (THB 500,000/USD 14,300 for 5 years; THB 800,000/USD 22,900 for 10 years; THB 1 mio/USD 57,030 for 20 years) orRetirement Visa (non-Immigrant “O”): Foreigners above 50 years old with a min. of THB 800,000 maintained for at least 3 months on a local bank account orTransfer of retirement income of at least THB 65,000 monthly to Thailand orInvestment through an approved busi-ness under the Board of Investment promoted activities

Investment through the Global Investor Programme (“GIP”) of a min. value of SGD 2.5 mio in a new or existing foreign business operation engaged in one or more specified industriesorInvestment of a min. value SGD 2.5 mio in an approved GIP fund that invests in Singapore-based companies. Applicant to produce 3-year auditedfinancial statement of his/her compa-ny, and for the company to have an annual turnover of at least SGD 50 mio


None None Annual quota of 100 people per nation-ality, except for the applicant of the Thailand Elite visa

None

Dependents’ visas

Yes, extendable to spouse, male children below 18 years (with some ex-ceptions) unmarried female children, and dependent parents, grandparents, brothers and sisters


Yes, extendable to spouse or unmar-ried partner, children below the age of 24

Main applicant secures residence permit first, then apply for immediate family member(s)

Yes, extendable to spouse, children below the age of 20 and dependent parents

Main applicant may submit simultane-ously the application with the family member(s)

Yes, spouse and unmarried children below the age of 21 are eligible to apply for Singapore Permanent Residence (“SPR”) under the principal applicant’s GIP application.

Parents and unmarried children (above the age of 21) are not eligible to apply for SPR under the principal applicant’s GIP application. They may instead apply for family members for 5 years Long Term Visit Pass, tied to the validity of the main applicant’s Re-Entry Permit

Mandatory interview

No Required for initial application of occupation permitNot required for permanent residence visa obtained through the acquisition of property or real estate

Yes Yes


Not required for initial applicationRequired for visa processing and collection of residence permit

Required for occupation and retired noncitizens permitsOthers: not required

Yes Required for interviewNot required otherwise


None, but Residence Permit may be issued for shorter period for applicantaged resp. over 60 and 65 years old

16 years of age and above None None, but generally the principal applicant should be an adult, which under Singapore law for present purposes is 21


3 weeks (plus 2-6 weeks for the consti-tution of the company/acquisitionand registration of real estate)

Occupation Permit: 10 days if all documents are submitted at one goRetired Non-Citizens: Maximum of 15 daysOther: 2 months

2-3 months 4-6 months for in principle approval; some applications may take a longertime to process

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UAE Mauritius Thailand Singapore


Valid up to 3 years – renewable for up to 3 yearsbutSubject to the holder (and his family in case of family residence permit) visit-ing the UAE once in every 6 months.

Occupation Permit: valid up to 3 years – renewableRetired Non-Citizens: valid up to 3 years – renewable. After 3 years, a Per-manent Residence can be applied forResidence Permit: valid until permit holder sells his/her IRS, RES, PDS or SCSPermanent Residence: valid for 10 years – renewable

Valid for initial 6 months – renewable for up to 1 yearAfter 3 years, a permanent residence can be applied for

Valid up to 5 years – renewable subject to compliance with certain specified conditions and validity of re-entry permit


De lege: not requiredIn practice: 1 day every 180 days + rec-ommendable not to spend more than 183 days in another jurisdictionLoss of residency if outside of the country for more than 180 consecutive days



Required: no specific periodIn practice: the 183 days period is for the purpose of determining whether one is a “tax resident”, not to deter-mine “residency”


To spend 183+ days in country within a single calendar yearValid Ejari/Tenancy/Title Deed6 months UAE/local bank account statements – personalProof of income in UAEImmigration Report specifying number of days stay in the UAE


Applicant registered (declared) place of residence in countryProof of addressTo spend 183+ days in country within a single calendar year



Rental: USD 12,000 - 25,000/yearPurchase: USD 300,000

Rental: Min of USD 2,500Purchase: Min of 250, 000A villa of 3 bedroom: Min USD 850,000 (without furniture)


Rental: USD 30,000/yearPurchase: USD 1,100,000

Taxation

Annual tax filings: noneIncome tax: noneCapital gain tax: noneWealth/net worth tax: noneGift/inheritance tax: none

Annual tax filings: mandatoryIncome tax: residents are liable on their worldwide income; non-residents are liable only on Mauritius source income; Income taxed at 15%.Capital gain tax: noneWealth/net worth tax: noneGift/inheritance tax: none

Annual tax filings: mandatoryIncome Tax: residents and non-res-idents are liable on their Thailand source income. Residents liable only if income brought into Thailand in the year derived (after exempt). Income taxed at progressive rates up to 35%Capital gain tax: taxed at standard income tax rateWealth/net worth tax: noneGift/inheritance tax: 5% for ascendants and descendants or 10% for other re-cipient or heirs for assets worth above THB 100 mio

Annual tax filings: mandatoryIncome tax: residents and non-resi-dents are liable with certain exceptions to pay tax on income accrued in or de-rived from Singapore. Foreign-sourced income received or deemed received in Singapore by a resident or non-resident is tax-exempt (except income received from partnership in Singapore); For residents, income taxed progressively and up to 22% on income generated in Singapore; none on foreign income even if remitted to Singapore. For nonresidents, employ-ment income is taxed at a flat rate of 15% or the progressive resident tax rates, whichever is higher tax amount. Director’s fees, consultation fees and all other income of nonresidents are taxed at 22%Capital gains tax: noneWealth/net worth tax: noneGift/inheritance tax: none

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Malaysia Hong Kong Panama Bahamas

Main advantages

No minimum stayNo wealth, gift and inheritance taxGood standard of living and health care facilitiesPolitically stable and secure environ-mentTropical climate

No minimum stayNo capital gains, wealth, gift and inher-itance taxNo corporate tax on offshore profitsComprehensive tax treaty network (37 DTAs as of 1st July 2017)Good standard of living and health care facilitiesPolitically stable and secure environ-mentInternational Financial CentreInternational logistics hub with good infrastructureGateway to Mainland China

No minimum stayAll foreign income is exempted even if remitted to PanamaNo wealth, gift and inheritance taxComprehensive tax treaty networkGood standard of living and health care facilitiesPleasant climate

No minimum stayTotal exemption from income, wealth, gift and inheritance taxNo tax filingYearly sunny climateGood standard of living


Employment Visa: demonstrate appli-cant possesses high skills (health and medical, sports, science, technology, banking and finance)orEmployment for min. period of 3 yearsInvestment Visa: Applicant to maintain a personal bank account locally with a min. balance of USD 2 mio (blocked for 5 years)orInvestment through the Malaysia My Second Home Program (“MM2H”)

• for applicants 50 years old and above:

min. value of MYR 10,000 from Gov-ernment or Private Approved Pensions Funds monthly salary of MYRE 10,000 and MYR 150,000 fixed depos- it5 and bank liquid assets of min. MYR 350,000 for applicants below 50 years old: monthly salary of MYRE 10,000 and MYR 300,000 fixed depos- it6 and bank liquid assets of min. MYR 500,000orReal Estate Investment through MM2H of a min. MYR 1 mio

Entrepreneur Visa: demonstrate the business is of substantial benefit to Hong Kong economy (e.g. creation of local jobs)orEmployment Visa: demonstrate applicant possesses a special skill, knowledge or experience which are of value to and not readily available in Hong Kong

Permanent Residency is granted after 7 years of continuous ordinary residence

Constitution of a Panamanian com-panyandOpening a bank account (initial amount of USD 10,000) in Panama

Real estate investment in Bahamas of a min. market value of USD 500,000orBusiness investment of a min. market value of USD 500,000


None None None None

Dependents’ visas

Yes, extendable to spouse, children below the age of 21 and parents aged 60 and above


Yes, extendable to spouse and children subject to certain conditions


Yes, extendable to spouse and children

Main applicant needs to secure residence permit first, then apply for immediate family members; unmarried children between 18 – 25 to evidence enrolment in a recognized college or university in Panama (full time)

Yes, extendable to spouse of Bahamian citizen and children below the age of 18 subject to certain conditions


Mandatory interview

Yes No No No


Yes No Required for initial application (5 days stay in Panama)

Not required



None, but generally the applicant should be an experienced professional or high graduated young professional




2-3 months Entrepreneur Visa: 3-6 monthsEmployment Visa: 4-6 weeksPermanent Residency: 4-6 weeksHigh Net Worth Individual Visa: 4-6 weeks

6 months Annual residence permit: 2-3 monthsPermanent residence permit: 6-12 months

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Malaysia Hong Kong Panama Bahamas


Valid for initial 6 months – renewable for up to 10 years

After 10 years, a permanent residence can be applied for

Valid for initial stay for 2 years renewable twice for up to 6 years of continuous residence

After 7 years, a permanent residence can be applied for (provided the applicant or his family satisfies the conditions of continuous stay)

The residency is valid for a lifetimebutSubject to the holder (and his family in case of famiy residence permit) visit-ing Panama once in every 24 months ID card to be renewed every ten years

Annual residence permit: valid for 1 year – renewable for periods of 1 year

Permanent residence permit: perma-nent (provided the applicant does not abandon Bahamas)


De lege: not requiredIn practice: recommendable not to spend more than 183 days in another jurisdiction Save for MM2H program, loss of residency if a min 180 days mandatory period of stay in the country within a year is not met

De lege: not requiredIn practice: Hong Kong should be the main “center of interests”Loss of residency if the condition of continuous stay is not met (i.e. spend a min of 180 days/year in Hong Kong)




To spend 182+ days in country within a single calendar year (duly docu-mented)

To spend 180+ days in country within a single calendar year Applicant registered (declared) place of residence in countryTo spend 183+ days in country within a single calendar year orCentre of economic interests in country

To spend 182+ days in country within a single calendar year Applicant registered (declared) place of residence in countryProof of address in country

Neither the tax authority nor any other authority issues certificates of residenceDepartment of Immigration issues confirmation letter upon request



Rental: USD 41,500.00/yearPurchase: USD 1.5M-3M

Rental: between USD 12,000 and USD 15,000/yearPurchase: between USD 154,000 and USD 168,000


Taxation

Annual tax filings: mandatoryIncome Tax: resident and non-resident liable on income derived from Malay-sia. Foreign-source income exempt. Resident taxed at progressive rates up to 25%; non-resident taxed at a flat rate of 25%Capital gain tax: exempt, except for gains derived from disposal of real property (flat rate of 30%) or alien-ation of shares in realproperty companyWealth/net worth tax: noneGift/inheritance tax: none

Annual tax filings: mandatoryIncome Tax: individuals earning income arising in or is derived from a Hong Kong Office or Hong Kong em-ployment, or from services rendered in Hong Kong during visits of more than 60 days in any tax year, are subject to salaries tax. Salaries Tax: progressive rates up to 17% with a global rate capped at 15%Profit Tax: 16.5% for onshore profits; 0% for offshore profitsProperty Tax: 15%Capital gains tax: noneWealth/net worth tax: noneGift/inheritance tax: noneWithholding tax on dividends: 0%Withholding tax on interest: 0%Withholding tax on Royalties: 4,95% for body corporate / 4,5% for non-corpo-rate person

Annual tax filings: mandatory if income derived from business activity in PanamaIncome tax: both residents and nonresidents are liable on their Pana-ma-source income only. Income taxed up to 25% on any income arising in Panama exceeding USD 50,000Capital gain tax: 10%Wealth/net worth tax: noneGift/inheritance tax: none

Annual tax filings: none under the special HNWI schemeIncome tax: noneCapital gain tax: noneWealth/net worth tax: noneGift/inheritance tax: none

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