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Special tax regimes for new residents in Europe compared

Compare Europe's regimes for new residents: Portugal IFICI, Spain's Beckham Law, Italy's flat tax, Greece 5A-5C, UK FIG, Cyprus non-dom, Swiss lump sum, Malta.

Short answer

Several European countries offer optional tax regimes to people who become resident there after living abroad. Some tax foreign income with a fixed yearly amount or a low rate, such as Italy's €300,000 substitute tax, Greece's €100,000 article 5A tax and the 7% pensioner regimes in Italy and Greece. Others lower the tax on local work income, such as Portugal's 20% IFICI rate, Spain's article 93 regime and Greece's 50% article 5C relief, and each one has its own look-back period, deadline and time limit.

What this covers

A special tax regime for new residents is a set of rules that a person who becomes tax resident in a country can elect, or claim, instead of some of the ordinary rules for residents. They do not decide whether you are resident. You become resident, or not, under the country's normal tests, and the regime changes how some income is taxed after that. Most regimes look back at earlier years of residence, need an application or claim by a set date, and end after a fixed number of years.

Understand what these regimes do and do not do

Each regime sits on top of residence. Portugal applies article 16.º of its IRS Code, Spain article 9 of its IRPF law, Italy article 2 of its income tax code and Greece article 4 of its Income Tax Code. If you are not resident under those tests, the regime is not the question. See the tax residence entry and the 183-day rule guide.

A visa or residence permit does not make you tax resident or put you in a regime. Spain names its teleworking visa as one way to meet a condition of article 93, and Greece's article 5A treats an investment residence permit as meeting its investment condition, but in both cases the tax rules decide. See digital nomad visas compared and golden visas in Europe.

These regimes also say nothing about the country you leave. That country may keep taxing you, tax gains on departure or apply a treaty tie-breaker. See leaving a country for tax.

Compare the regimes side by side

The table gives one row per regime, from the official pages listed in sources. Each row links to a FlagSage guide with the conditions and sources. Amounts and dates change often, so check the current official text before relying on any figure.

Special tax regimes for new residents in Europe (official sources, checked 9 November 2026)
Country and regimeWho it is forMain tax treatmentHow longGuide
Portugal: IFICI (EBF article 58.º-A)New residents not resident in the 5 prior years who carry out a listed research, innovation or qualified activity20% on net employment and business income from the activity. Foreign income generally exempt except pensions10 consecutive yearsPortugal IFICI
Spain: article 93 IRPF (Beckham Law)People who become resident because they move for work, not resident in the 5 prior tax periodsNon-resident rules: 24% up to €600,000 and 47% above. Other foreign income generally not taxedYear of the move plus 5Spain's Beckham Law
Italy: article 24-bis TUIRNew residents not resident for at least 9 of the 10 prior tax periodsFixed €300,000 a year on foreign income for moves from 2026, €50,000 per family memberUp to 15 yearsItaly flat tax
Italy: article 24-ter TUIRForeign pension holders moving to listed southern municipalities of up to 30,000 inhabitants or quake areas7% on all foreign incomeUp to 10 tax periodsItaly flat tax
Italy: impatriate regime (D.Lgs. 209/2023)Qualified workers who move from 2024, not resident in the 3 prior tax periods50% of Italian work income taxed (40% with a minor child), up to €600,000Year of the move plus 4Italy flat tax
Greece: article 5ANew residents not resident in 7 of the 8 prior years who invest at least €500,000 in Greece or hold an investment permit€100,000 a year on foreign income, €20,000 per relative15 tax yearsGreece 5A, 5B, 5C
Greece: article 5BForeign pensioners not resident in 5 of the 6 prior years, moving from a state with a tax cooperation agreement7% on all foreign income15 tax yearsGreece 5A, 5B, 5C
Greece: article 5CEmployees and self-employed people not resident in 5 of the 6 prior years who work in Greece50% of Greek employment and business income exempt7 tax yearsGreece 5A, 5B, 5C
United Kingdom: 4-year FIG regimeUK residents in their first 4 years of residence after at least 10 consecutive years of non-UK residenceClaimed foreign income and gains not taxed, foreign employment income excluded. Replaced the remittance basis on 6 April 2025Up to 4 tax yearsUK FIG regime
Cyprus: non-domiciled statusCyprus tax residents, under the 183-day or 60-day rule, who are not domiciled in CyprusNo Special Defence Contribution on dividends and interest (rent until the 2025 tax year)Until deemed domicile after 17 of 20 years, extendable for €250,000 per 5-year periodCyprus non-dom
Switzerland: lump-sum taxationForeign nationals resident for the first time or after 10 years away, with no gainful activity in SwitzerlandTax based on worldwide living expenses, with legal minimums. Not offered in some cantonsWhile the conditions are metSwiss lump-sum taxation
Malta: remittance basis and special schemesResidents not domiciled or not ordinarily resident in Malta. The Global Residence Programme is for people who are not EU, EEA or Swiss nationalsForeign income taxed when received in Malta, foreign capital gains not taxed. Special schemes have their own rulesWhile the conditions are metMalta residence tax regimes

Sort the regimes by the income they change

Some regimes are about income from abroad. Italy's article 24-bis, Greece's article 5A and Swiss lump-sum taxation replace the ordinary tax on foreign income with a fixed amount or a tax on spending. Italy's article 24-ter and Greece's article 5B apply a 7% rate to all foreign income. The UK FIG regime and Portugal's exemption method for IFICI beneficiaries leave some foreign income untaxed, Malta taxes foreign income of some residents only when it is brought into Malta, and Cyprus's non-domiciled status removes one tax on dividends and interest. See remittance basis.

Other regimes are about income from work in the new country. Portugal's 20% IFICI rate, Spain's article 93 regime, Italy's impatriate regime and Greece's article 5C lower the tax on local employment or business income, each with conditions about the kind of work.

A regime that helps one kind of income can leave another under the ordinary rules. Italian-source income stays outside article 24-bis, foreign pensions stay outside Portugal's IFICI exemption, and Spanish dividends are taxed under article 93. Map your income before reading any headline figure.

Check the look-back periods before you move

Almost every regime asks whether you were resident in that country in earlier years. The periods differ a lot, and some count tax periods while others count years.

Prior non-residence periods in the official texts (checked 9 November 2026)
RegimeYou must not have been resident in
Portugal IFICIAny of the 5 previous years
Spain article 93The 5 tax periods before the year of the move (10 before 2023)
Italy article 24-bisAt least 9 of the 10 previous tax periods
Italy article 24-terAt least the 5 previous tax periods
Italy impatriate regimeThe 3 previous tax periods, or 6 or 7 with the same employer or group
Greece article 5A7 of the 8 previous years
Greece articles 5B and 5C5 of the 6 previous years
UK FIG regimeAt least 10 consecutive tax years before arrival
Switzerland lump-sum taxationSwitzerland in the 10 previous years (it is for first-time residents or people returning after at least 10 years abroad)

Watch the application deadlines

Missing a date can cost years or the whole regime. Portugal's IFICI registration is due by 15 January of the year after you become resident, and a late one counts only from the year it is filed. Spain's form 149 must be filed within six months from the start date in the Social Security registration. Italy's article 24-bis option is made in the return for the year of the move or the following year.

Greece changed its procedure in 2026. AADE decision A.1147/2026 sets 30 September of the arrival year or the following year for article 5A, and decision A.1192/2026 sets 31 October for article 5B. The UK FIG regime is claimed on the Self Assessment return for each year. Use the day ledger to keep dates of arrival and presence that these deadlines depend on.

Track the changes from 2024 to 2026

Many of these regimes changed recently, and older pages still show earlier rules.

  • Portugal revoked the non-habitual resident (NHR) regime from 1 January 2024 and created IFICI, with transitional rules for some people. See the IFICI entry.
  • Spain's Law 28/2022 reshaped article 93 from 1 January 2023, cutting the look-back from 10 to 5 tax periods and adding remote workers, entrepreneurs and family members.
  • Italy raised the article 24-bis amount to €200,000 after 10 August 2024 and to €300,000 for moves from 1 January 2026. A 2026 law raised the 24-ter population limit to 30,000. The impatriate regime was rewritten for moves from 2024.
  • Greece amended article 5A through Law 5222/2025 and article 94 of Law 5313/2026, and AADE issued new procedures for articles 5A and 5B in 2026.
  • The UK replaced the remittance basis with the 4-year FIG regime on 6 April 2025.
  • Cyprus abolished Special Defence Contribution on rent after the 2025 tax year and added a paid extension for people deemed domiciled.

Ask what happens in both countries

A regime in the new country does not settle your position in the old one. The other country may still treat you as resident, and a treaty may then decide residence for treaty purposes. See when two countries claim you.

Treaties can also change how foreign tax is credited. Greece says foreign tax on income covered by the article 5A lump sum cannot be offset, while article 5B allows a credit in some cases. Portugal sets a 35% rate on some income from listed low-tax jurisdictions for IFICI beneficiaries. Ask an adviser in each country how your income will be treated before you move, and use the exposure check to list the countries involved.

Common misconceptions

Moving to a country with a special regime makes all your income lightly taxed.Each regime covers only some income. Italy's article 24-bis leaves Italian-source income under the ordinary rules, and Portugal's IFICI rate covers only employment and business income from listed activities.
A golden visa or digital nomad visa puts you in the tax regime.Tax residence and these regimes follow tax law. A permit can meet one condition, as in Greece's article 5A, but the other conditions and the application still apply.
Portugal's NHR is still open to new residents.Lei n.º 82/2023 revoked NHR from 1 January 2024. People already registered keep it for the rest of their 10 years, and new residents look at IFICI instead.
The UK still has a non-dom remittance basis.HMRC says the 4-year FIG regime replaced the remittance basis on 6 April 2025.

Questions to take to a professional

  1. In which country will I be tax resident in the year I move, and from which date?
  2. Which of my income is foreign income and which is local income in the new country?
  3. Do I meet the look-back period of the regime I am considering, counted the way that law counts it?
  4. What is the application deadline, and what happens if I miss it?
  5. How will the country I am leaving tax me in the year of departure and after?
  6. Will any treaty let me credit foreign tax, and does the regime limit credits?
  7. What happens to the regime if I change job, stop working or leave early?

Questions people ask

Which European countries have special tax regimes for new residents?

Official sources describe regimes in Portugal (IFICI), Spain (article 93), Italy (articles 24-bis and 24-ter and the impatriate regime), Greece (articles 5A, 5B and 5C), the UK (the 4-year FIG regime), Cyprus (non-domiciled status), Switzerland (lump-sum taxation) and Malta (remittance basis and special schemes).

Which countries tax foreign income with a fixed amount?

Italy's article 24-bis sets €300,000 a year for moves from 2026, and Greece's article 5A sets €100,000 a year. Switzerland's lump-sum taxation uses living expenses as the base rather than a fixed figure.

Which countries have a 7% tax for retirees?

Italy's article 24-ter applies 7% to foreign income of foreign pensioners who move to qualifying southern municipalities. Greece's article 5B applies 7% to all foreign income of foreign pensioners. The conditions differ.

What replaced Portugal's NHR?

IFICI, in article 58.º-A of the Tax Benefits Statute, which taxes income from listed activities at 20% for 10 years. People already registered for NHR on 1 January 2024 keep it for the rest of their period.

Does the UK still have non-dom status?

The remittance basis linked to domicile ended on 6 April 2025. HMRC now offers the 4-year FIG regime to people in their first 4 years of UK residence after at least 10 consecutive years of non-UK residence.

Do these regimes make me a tax resident?

No. Each country's residence tests decide that. The regime only changes how some income is taxed once you are resident.

Where this guide stops. A qualified tax adviser in the country you are moving to applies these rules to your facts and files the elections, and an adviser in the country you are leaving deals with your departure. FlagSage describes the rules and the questions they raise. It does not pick a regime, compare costs for your income or file anything.

Sources

Portugal IFICI (NHR 2.0): the 20% regime that replaced NHRSpain Beckham Law: conditions, 24% rate and forms 149 and 151Italy flat tax for new residents: €300,000, 7% and impatriatesGreece non-dom regimes: 5A €100,000, 5B 7% and 5C 50% reliefUK FIG regime: how the 4-year rule replaced non-dom statusCyprus 60-day rule and non-dom status: the conditionsSwiss lump-sum taxation: who can use the expenditure taxMalta non-dom tax and the Global Residence Programme rulesGolden visas in Europe 2026: which are open, closed or changedDigital nomad visas compared: income, length and tax in 2026Tax residencyLiving baseAssets🇵🇹 Portugal🇪🇸 Spain🇮🇹 Italy🇬🇷 Greece🇬🇧 United Kingdom🇨🇾 Cyprus🇨🇭 Switzerland🇲🇹 Malta
Countries covered
Portugal, Spain, Italy, Greece, United Kingdom, Cyprus, Switzerland, Malta
Sources
16 sources listed above
Tax year
Current rules as checked
Review
Not professionally reviewed
Sources checked November 9, 2026