Citizenship-based taxation: US citizens and green-card holders are taxed on worldwide income regardless of residence; expatriation may trigger an exit tax
🇳🇿 New Zealand NZ
39%
0%
Worldwide
Participates
None
None
4-year transitional exemption on foreign passive income for new migrants and returnees
🇮🇪 Ireland IE
40%
33%
Worldwide
Participates
None
Yes
Non-doms taxed on foreign income and gains on the remittance basis
Non-permanent resident regime: foreign income not remitted to Japan is untaxed during the first 5 years of residence
🇰🇷 Korea, Republic of KR
45%
—
Worldwide
Participates
None
Yes
—
🇬🇧 United Kingdom GB
45%
24%
Worldwide
Participates
None
Yes
Non-dom remittance basis abolished from April 2025; replaced by a 4-year foreign income and gains (FIG) exemption for new residents
🇪🇸 Spain ES
47%
30%
Worldwide
Participates
Yes
Yes
Beckham law: qualifying inbound employees taxed at 24% on Spanish-source income for up to 6 years
🇳🇴 Norway NO
47.4%
37.84%
Worldwide
Participates
Yes
None
—
🇵🇹 Portugal PT
48%
28%
Worldwide
Participates
None
None
NHR closed; successor IFICI ("NHR 2.0"): 20% rate on qualifying professional income
🇳🇱 Netherlands NL
49.5%
—
Worldwide
Participates
Yes
Yes
Expat regime with a partial salary exemption (30% ruling, being scaled down)
🇧🇪 Belgium BE
50%
10%
Worldwide
Participates
None
Yes
—
🇩🇰 Denmark DK
52%
42%
Worldwide
Participates
None
Yes
—
🇸🇪 Sweden SE
52%
30%
Worldwide
Participates
None
None
—
🇦🇹 Austria AT
55%
27.5%
Worldwide
Participates
None
None
—
🇫🇮 Finland FI
—
34%
Worldwide
Participates
None
Yes
—
🇷🇸 Serbia RS
—
15%
Worldwide
Not participating
None
Yes
—
🇨🇭 Switzerland CH
—
0%
Worldwide
Participates
Yes
Yes
Foreign nationals may opt for lump-sum taxation (forfait; tax base negotiated on living expenses)
A dash means no value is provided. Rate fields show top nominal rates.
🇦🇬 Antigua and Barbuda — CBI country. Personal income tax was abolished in 2016; no capital gains, estate or wealth taxes. Corporate tax 25%.
🇰🇳 Saint Kitts and Nevis — CBI country. No personal income tax; generally no capital gains tax (a 20% charge applies only to assets sold within one year of acquisition). Corporate tax 33%. No estate or wealth taxes.
🇦🇪 United Arab Emirates — No personal income, capital gains, estate or wealth taxes; a 9% federal corporate tax applies since 2023 (15% DMTT for large multinationals). One of the most popular zero-personal-tax bases for second-passport buyers.
🇻🇺 Vanuatu — CBI country. No personal income, corporate income, capital gains, estate or wealth taxes; revenue relies on VAT and fees.
🇳🇷 Nauru — CBI country. No general personal income tax (a 10% employment and services tax applies to certain local payments). Business taxation uses business profits / small business taxes with rates varying by category and threshold.
🇵🇾 Paraguay — Territorial system — foreign income exempt. Personal services income 8–10%, capital gains flat 8%, corporate 10%.
🇲🇴 Macau SAR — Territorial system; professional tax tops out at 12% and complementary (corporate) tax at 12%. No capital gains, estate or wealth taxes.
🇭🇰 Hong Kong SAR — Territorial system taxing only Hong Kong-source income; salaries tax capped at 17% progressive (15%/16% standard rate). No capital gains tax, no estate duty (abolished 2006), no wealth tax.
🇬🇪 Georgia — Flat 20% with foreign-source individual income exempt — attractive for offshore earners. Gains vary: taxed as income at 20%, residential property held 2+ years exempt, individual-to-individual sales often relieved, so the field is null. Corporate tax follows the Estonian model — 15% only on distribution. CRS exchanges since 2024.
🇵🇦 Panama — Strictly territorial — foreign income is untaxed. Panama-source income up to 25% for individuals, capital gains 10%. No estate or wealth taxes.
🇬🇩 Grenada — CBI country. Tax applies to Grenada-source income only, at up to 28%; no capital gains, estate or wealth taxes.
🇲🇾 Malaysia — Broadly territorial; top personal rate 30%. No general capital gains tax for individuals, but real property gains tax (RPGT) up to 30% depending on holding period. No estate or wealth taxes.
🇲🇺 Mauritius — Progressive personal tax up to 20%; residents' foreign income is taxed only when remitted. No capital gains, estate or wealth taxes; corporate 15%.
🇸🇬 Singapore — Residents taxed on Singapore-source income at up to 24%; foreign income received by individuals is generally exempt (territorial-plus-remittance hybrid). No capital gains, estate or wealth taxes.
🇱🇨 Saint Lucia — CBI country. Resident-and-domiciled individuals are taxed on worldwide income at up to 30%; resident non-domiciled individuals are taxed on foreign income only when remitted. No capital gains tax.
🇲🇹 Malta — CBI/residence hub. Resident non-doms are taxed on Malta-source income and remitted foreign income only. Gains are mostly taxed as income (up to 35%) with an 8% final transfer tax on property, so the CGT field is null. Corporate rate 35% nominal but effectively ~5% for foreign shareholders via refunds. No inheritance tax (stamp duty on property transfers).
🇹🇭 Thailand — Top rate 35%. Residents' foreign income is taxed when remitted (since 2024, regardless of the year earned). SET-listed share sales are exempt while most other gains are taxed as income, so the field is null. Inheritance tax 5–10% above THB 100m. LTR visa holders can shelter foreign income.
🇹🇼 Taiwan — Progressive tax up to 40% on Taiwan-source income; foreign income only under the 20% alternative minimum tax above NTD 7.5m. Securities gains tax is suspended and property gains follow a separate 15–45% regime, so the capital-gains field is null. Not an CRS participant (bilateral AEOI with Japan, Australia, UK). Estate and gift tax 10–20%.
🇧🇬 Bulgaria — Flat 10% for both individuals and companies — among the EU's lowest; gains on EU-regulated-market listed shares are exempt. Inheritance tax exempts spouses and direct line, otherwise 0.4–6.6%.
🇭🇺 Hungary — The EU's lowest corporate rate at 9%; flat 15% personal income tax and 15% capital gains. Inheritance duty is generally 18% but direct relatives and spouses are exempt.
🇲🇪 Montenegro — Personal rates 9%/15%, capital gains 15%, corporate 9–15% progressive. Inheritance tax around 3%, direct line exempt.
🇦🇲 Armenia — Flat 20% personal, 18% corporate. Individual capital gains vary widely by asset and counterparty (individual-to-individual property sales largely exempt; sales to entities 10%/20%), so the field is null. First CRS exchanges from September 2025.
🇰🇭 Cambodia — Salary tax up to 20%, corporate 20%. Not a CRS participant.
🇪🇪 Estonia — Flat 22% personal rate from 2025, gains taxed as income at the same rate. Corporate tax only on distributed profits (22/78); retained earnings untaxed. No inheritance or wealth taxes.
🇨🇿 Czech Republic — Two personal bands of 15%/23%. Gains are taxed as income, but securities held 3+ years are exempt (CZK 40m annual cap since 2025). Inheritances are income-tax exempt; no wealth tax.
🇵🇱 Poland — Progressive 12%/32% (plus a 4% solidarity levy above PLN 1m), investment gains 19%. Inheritance tax exempts close family; others taxed by relationship class.
🇨🇦 Canada — Federal top rate 33%; combined federal-provincial top rates reach about 54%. Capital gains are 50% includible (effective top around 27%), so the field is null. Corporate 15% federal (roughly 26.5% combined). No estate tax, but deemed disposition at death triggers capital gains tax.
🇨🇾 Cyprus — Top rate 35%. Securities gains are exempt; only gains tied to Cyprus real estate are taxed at 20%. No estate or wealth taxes. The non-dom regime exempts dividends and interest from SDC for 17 years — very investor-friendly.
🇩🇲 Dominica — CBI country. Residents are taxed on worldwide income at up to 35%; no capital gains, estate or wealth taxes.
🇮🇩 Indonesia — Top rate 35% on worldwide income for residents. Capital gains are mostly handled via final taxes — 0.1% of proceeds for listed shares, 2.5% on land/building transfers — with no single rate, so the field is null.
🇺🇸 United States — The only major citizenship-based tax system: citizens and green-card holders file on worldwide income wherever they live. Long-term capital gains top out at 20% (plus 3.8% NIIT). The US is NOT a CRS participant — it relies on FATCA instead. Estate tax up to 40% (exemption around USD 15m from 2026).
🇳🇿 New Zealand — No general capital gains tax (bright-line property rules aside), no estate or wealth taxes; top personal rate 39%. New migrants get a 4-year transitional exemption on foreign passive income.
🇮🇪 Ireland — Top rate 40% (plus USC up to 8%, ~52% combined), CGT 33%, capital acquisitions tax 33% on inheritances/gifts. Non-domiciled residents can use the remittance basis. Corporate 12.5% (15% for large groups).
🇹🇷 Turkey — CBI country. Top personal rate 40% on worldwide income for residents. Most capital gains are taxed at progressive rates, but real estate held over 5 years and most listed shares are exempt, so the field is null. Inheritance tax 1–10%.
🇱🇺 Luxembourg — Nominal top rate 42% (45.78% effective with the employment-fund surcharge). Securities gains are exempt after 6 months if the stake is below 10%; substantial participations taxed at half rates. Corporate 23.87% aggregate in Luxembourg City. Inheritance tax generally exempts the direct line. Personal wealth tax abolished.
🇮🇹 Italy — Top rate 43% (plus 1–3% local surcharges), financial gains 26%. New residents can elect a EUR 200k annual substitute tax on foreign income. Inheritance tax is a mild 4–8% with high allowances; small IVIE/IVAFE levies on foreign assets.
🇬🇷 Greece — Golden-visa hub. Top rate 44%, securities gains 15%. New HNW residents can elect a EUR 100k annual lump-sum tax on foreign income. Inheritance tax up to 10% for close relatives. ENFIA annual property tax applies.
🇦🇺 Australia — Top personal rate 45% (plus 2% Medicare levy). Capital gains are taxed as income with a 50% discount after 12 months (effective top about 23.5%), so the field is null. Corporate 30% (25% for small companies). No estate or wealth taxes.
🇨🇳 China, People's Republic of — Tax residents are taxed on worldwide income; top marginal rate 45%, capital gains generally 20%. No estate or wealth tax at present, though both have been discussed for years.
🇫🇷 France — Top rate 45% (plus 3–4% high-income surcharge), 30% flat tax (PFU) on financial gains. Real-estate wealth tax (IFI) applies; inheritance tax up to 45% direct line and 60% for unrelated heirs — plan before relocating.
🇩🇪 Germany — Top rate 45% (plus 5.5% solidarity surcharge); investment gains 26.375% including surcharge. Corporate 15% federal, about 30% combined with surcharge and trade tax. Inheritance tax 7–50% by relationship and amount. No current wealth tax.
🇯🇵 Japan — National top rate 45% (plus 10% local inhabitant tax, ~55% combined). Listed securities gains 20.315%. Effective corporate rate around 30%. Inheritance tax up to 55% — among the world's highest; plan before long-term residence.
🇰🇷 Korea, Republic of — Top rate 45% (plus 10% local income tax, 49.5% combined). Capital gains vary widely by asset: minor listed-share holders generally untaxed, major shareholders 22–27.5% including local tax, so the field is null. Inheritance tax up to 50%.
🇬🇧 United Kingdom — Top rate 45%, CGT up to 24%, inheritance tax 40%. The remittance-basis non-dom regime was abolished in April 2025, replaced by a 4-year foreign income and gains (FIG) exemption for new arrivals.
🇪🇸 Spain — General income taxed up to 47% at state level (higher in some regions); savings income including capital gains at 19–30%. Wealth tax plus the large-fortunes solidarity tax and inheritance tax apply — plan before relocating.
🇳🇴 Norway — Top marginal rate about 47.4%; share gains effectively 37.84% after the upward adjustment factor. Wealth tax of ~1.0–1.1% applies and exit taxation has tightened, driving a noted HNW outflow. No inheritance tax since 2014.
🇵🇹 Portugal — Golden-visa hub. Top personal rate 48% (plus solidarity surcharge up to 5%). Securities gains generally at a 28% flat rate. Corporate rate cut to 19% for 2026 with a path toward 17%. No inheritance tax; 10% stamp duty for non-direct-line heirs.
🇳🇱 Netherlands — Top rate 49.5%. No realized capital gains tax; instead Box 3 taxes a deemed return on assets at ~36% (regime under reform) — effectively a wealth-based tax, hence CGT null and wealth_tax true. Inheritance tax 10–40%.
🇧🇪 Belgium — Top rate 50% (plus ~7% municipal surcharge). From 1 Jan 2026 a 10% tax applies to financial-asset gains (EUR 10k annual exemption; pre-2026 historic gains grandfathered). A 0.15% annual securities-account tax also applies. Regional inheritance tax, 3–30% direct line.
🇩🇰 Denmark — Combined top rate about 52% (roughly 55.9% including the labour-market contribution); share income above the threshold taxed at 42%. Estate duty 15%, spouses exempt.
🇸🇪 Sweden — Combined national and municipal top rate about 52% (varies by municipality), capital income 30%. Inheritance tax abolished in 2005 and wealth tax in 2007.
🇦🇹 Austria — Top rate 55% (on income above EUR 1m), investment gains 27.5%. No inheritance tax since 2008 and no wealth tax.
🇫🇮 Finland — Combined national and municipal top marginal rate is roughly 55–57% depending on municipality, so the field is null. Capital income 30%, 34% above EUR 30k. Inheritance tax up to 19% direct line, 33% others.
🇷🇸 Serbia — Salary tax 10% with an additional annual tax of 10–15% above thresholds, so the effective top marginal rate depends on structure and the field is null. Capital gains 15%. Not in CRS automatic exchange (information on request only) — one of Europe's few non-CRS states. Inheritance tax 1.5–2.5%, direct line exempt.
🇨🇭 Switzerland — Rates are canton-driven: federal personal top rate 11.5% with combined rates around 22–45%, corporate roughly 12–21%, so both fields are null. Private capital gains on movable assets are tax-exempt. Cantonal wealth taxes apply; inheritance taxes are cantonal with spouses/children mostly exempt. Lump-sum taxation available for foreigners.
Tax comparison workbench
Citizenship ≠ tax residency: an extra passport does not by itself change where you pay tax — only a genuine move of tax residence (home, days, center of life) does.
Pick two to four jurisdictions and compare taxation basis, rates and CRS side by side — table first, rate profiles alongside.
CRS and FATCA: a second passport in the transparency era
The CRS (Common Reporting Standard) is an automatic exchange system for financial account information, with over 100 participating jurisdictions. Balances, interest, dividends and proceeds in your bank, brokerage and insurance accounts are reported by local financial institutions and automatically exchanged with your jurisdiction of tax residence.
The key point: financial institutions look at tax residence, not passports. Account self-certification requires declaring every tax residence; an extra passport does not change CRS reporting by itself — only a genuine move of tax residence (home, days of stay, center of life) does. Concealing tax residence with a false declaration is illegal in most jurisdictions.
The United States is the only major economy outside the CRS: it uses FATCA to require foreign financial institutions to report accounts held by US persons, while providing limited information in return. That asymmetry is one reason some families treat the US as a special case — though US citizens and green card holders themselves face worldwide taxation and FATCA reporting obligations.
Macro context: tax revenue as % of GDP
This is a macro fiscal indicator — total government tax revenue relative to GDP. It describes the overall tax environment and is not the same thing as an individual tax burden; do not mix the two.