Relocation for High Net-worth Individuals
Recently we have seen an increasing number of high net-worth individual clients world-wide interested in relocating to a new domicile country, due to economic, political, physical, legal and tax uncertainty as well as world-wide exchange of information initiatives resulting in financial information reaching their domestic tax authorities. A trend which the COVID-19 pandemic has increased.
Some of the most frequently used schemes attracting interest from HNWI clients are:
Andorra
Andorra offers several residency by investment programs. The most popular one requires a permanent and minimum investment of EUR 400’000 (approximately USD 475’000) in either real estate, participation in a local company, debt issued by a local company, a public debt instrument from Andorra, or securities with the Andorran National Finance Institute.
Another investment program provides residency to investors in order to operate a business with a minimum of 85% of the business outside of the country. A business plan will be required and the headquarters has to be in Andorra and may only hire one employee (otherwise another program will have to be chosen).
For both programs, the investor will have to produce evidence of sufficient means by proving a yearly income of 300% of the minimum salary (currently about EUR 13’000 or approximately USD 15’000) plus an additional 100% for each family member. Residents are subject to worldwide income and capital gains taxes (only applicable for holdings of over 25% of a company) of up to 10%. There are no net worth or inheritance taxes in Andorra. There are no gift taxes in Andorra either, but capital gains taxes may be applicable to the donor when gifts are not to close family members.
Australia
Australia has a series of temporary and permanent residency programs which are currently under review. The streams of the Business Innovation and Investment Program offer permanent residence after four years, subject to attaining certain requirements on investments and business turnover. Additionally a points-based test system will be used to assess eligibility. The streams are:
• The Business Innovation Stream requires investors to evidence a successful business career with a business turnover of at least AUD 500’000 (approximately USD 365’000), and net assets of AUD 800’000 (approximately USD 580’000). Substantial ownership and management of an Australian business must be demonstrated and maintained.
• The Investor Stream requires investors to demonstrate three years’ investment experience and commit to invest AUD 1.5 million in Australian state or territory bonds for four years, and own net assets of AUD 2.25 million.
• The Significant Investor Stream requires investors to commit at least AUD 5 million into a qualifying Australian investment for at least four years.
• The Entrepreneur Stream requires investors to have obtained a signed commitment to receive AUD 200’000 in venture capital funding from an Australian company in order to commercialize and/or develop a high-value business idea or product.
• The Business Talent Program includes the following streams and requires involvement in the business:
• The Significant Business History Stream requires investors to own parts of or a whole business with a turnover of at least AUD 3 million per year. Investors must further have a successful business career and have net assets of AUD 1.5 million. Investors must make a substantial contribution to a new or established business in Australia and take an active role in managing the business.
• The Venture Capital Entrepreneur Stream, where an investor must have obtained a written AUD 1 million commitment in venture capital funding for a start-up or product commercialization of a high-value business idea in Australia and must establish (or participate in) that business.
The Quality of Life Index rank is number 4 of 82 countries Quality of Life Index by Country 2021.
For permanent residents, personal income taxes in Australia are up to 45% and are applicable on worldwide income and capital gains (some exceptions on foreign income may apply to temporary residents). There are no wealth, inheritance or gift taxes. Capital gains taxes may be levied however on the transfer of assets to a beneficiary from the estate of a deceased person.
Bahamas
Permanent residency in the Bahamas can be obtained by purchasing real estate worth minimum BSD 750’000 (corresponds to USD 750’000).
There are no individual income, capital gains, wealth, gift or inheritance taxes in the Bahamas.
Bermuda
Individuals wishing to relocate to Bermuda can apply for a residential certificate if they possess valid health insurance coverage and have substantial means and/or have a continuous source of annual income without the need to engage in gainful occupation. Residential certificates do not hold a time limit but they are subject to revocation by the Minister of Home Affairs.
There are no income, capital gains, wealth or gift taxes in Bermuda. However there is a payroll tax of up to 8.75% for employees and a stamp duty of up to 20% applied to Bermudian real and personal property of estates. There is also an annual real property tax levied on the annual rental value of land. The value is fixed by the accountant general and the tax rate is progressive up to 50%.
Canada
There are several (frequently changing) immigrant investor programs for Canada and its provinces. A federal immigrant investor program requires the immigrant investor to demonstrate relevant experience of managing a qualified business and to become majority shareholder in a business or to prepare starting an own business in Canada. A start-up program will require proof of willingness to invest CAD 200’000 in the start-up (approximately USD 153’000). In Quebec the program requires the investor and his/her spouse to evidence having attained a net worth of minimum CAD 2 million (about USD 1.53 million). The required volume of investment in Quebec is CAD 1.2 million for a period of five years with no interest. The investment is government guaranteed and will be repaid in full at the end of the investment period.
The Quality of Life Index rank is number 21 of 82 countries Quality of Life Index by Country 2021.
Depending on the province in which the immigrant takes up residency, income taxes are between 44.5 and 54%. Capital gains are taxed at half the income tax rate. There are no wealth, inheritance or gift taxes, but inheritance and gifts will be treated as sale, possibly resulting in capital gains taxes.
Cayman Islands
The Cayman Islands offer a series of residency programs. The Residency Certificate for Persons of Independent Means is for investors with a continuous source of income of normally at least KYD 120’000 (approximately USD 144’000) and with KYD 400’000 (approximately USD 480’000) in an Cayman registered bank as well as at least KYD 500’000 (approximately USD 600’000) of developed residential real estate in the Cayman Islands together with further local investments totaling KYD 1 million (approximately USD 1.2 million) on the islands. The renewable residency certificate is issued at a cost of KYD 20’000 (approximately USD 20’000) and is valid for 25 years.
When investing at least KYD 1 million in any employment generating business (whether already existing or new) with substantial management control by an investor with a substantial business track record or background, the investor may also be granted residency. The same applies to investors who – directly or indirectly – own a minimum of ten percent of an approved category business with substantial business presence on the islands, or of which the investor will be employed in a senior management capacity requiring a yearly fee of at least KYD 21’000.
There are no income, capital gains, wealth, gift or inheritance taxes in the Cayman Islands.
Costa Rica
Permanten residency in Costa Rica can be obtained by investing a minimum of USD 200’000 in real estate in Costa Rica. Alternatively for an entire family a regular monthly income of at least USD 2’500 certified by a local or foreign bank. Alternatively, a life-time pension plan, social security or government pension plan of USD 1’000 will enable the beneficiary to obtain a residency permit. A real estate transfer tax of 1.5% is applicable.
Income taxes of up to 25% on Costa Rican source income are applicable. A capital gains tax of 15% is applicable on real estate sales in Costa Rica which are not primary residence. A 30% capital gains tax for Costa Rican habitual source gains may be applicable. No inheritance or wealth taxes. There may be an obligation to contribute to the social security system.
Greece
Tax residency with an alternative tax regime can be obtained for a maximum duration of 15 years, upon investing EUR 500’000 in real estate, a business, or qualifying Greek securities. Additional family members qualify with an additional EUR 20’000 each. The alternative tax regime requires the investor to pay an annual fixed tax of EUR 100’000, irrespective of the volume of income earned abroad. Inheritance and gift taxes on property abroad are also exempt.
There is also an alternative tax regime available for foreign pensioners immigrating from a jurisdiction with an administrative tax co-operation agreement with Greece. The alternative tax regime for qualifying pensioners is 7% on the total income obtained abroad.
Regular personal income tax is up to 44% (plus applicable local taxes), income from real estate up to 45% and there is a special solidarity contribution of an additional 10%. The regular donation and inheritance taxes are up to 40% (depending on degree of kinship) and there are real estate ownership and transfer taxes.
The Quality of Life Index rank is number 41 of 82 countries Quality of Life Index by Country 2021.
Greek residency will provide the holder with the possibility of visa-free movement within the Schengen Area.
Israel
As per the Law of Return, Jews, their children and grandchildren (even in some cases where not qualifying as such as per Jewish law), are entitled to immigrate to Israel and subsequently receive citizenship and access to all social benefits.
Such immigrants are granted a 10 year tax exemption on foreign source income, as well as a reporting exemption on foreign income and wealth.
The Quality of Life Index rank is number 32 of 82 countries Quality of Life Index by Country 2021.
Ordinary taxation in Israel consists of income taxation up to 50%. Israel does not have any inheritance, gift or wealth taxes.
Italy
Citizens from the EU have the right to live in Italy. The fast-track investor visa for non-EU nationals requires an investment of EUR 1 million in a local company or EUR 2 million in Italian public bonds. The Quality of Life Index rank is number 36 of 82 countries Quality of Life Index by Country 2021.
Newly resident individuals may apply for a lump-sum substitute tax of EUR 100’000 and a tax of EUR 25’000 for relatives on all of their non-Italian source income, wealth abroad and inheritance and gift tax exemption on foreign assets. Such an agreement can be prolonged for up to 15 years. Part of the Schengen Zone, permitting residents to travel freely to most parts of the European Union and Switzerland.
Jersey
Citizens from the EU and EEA countries and Switzerland do not need a residency permit. For other citizens, in order to qualify as a high value resident an applicant will have to show a sustainable worldwide earning comfortably in excess of GBP 725’000 (approximately USD 940’000) per year and the minimum tax payable on income will be of GBP 145’000 (approximately USD 188’000) calculated on a sliding scale based on 20% of the first GBP 725’000 of worldwide income and 1% on all income thereafter. All of this however does not guarantee the residency status, because the residency will also have to benefit the island in some way (usually commercially or socially, for example by funding educational and sporting activities, cultural contribution and skills, creation of jobs and/or training residents).
For ordinary residents income taxation is at 20% on their worldwide income. There are no wealth, capital gains, inheritance, or gift taxes. Probate stamp duty of up to GBP 100’000 (approximately USD 129’000) is levied.
Malaysia
Applicants for residency below 50 years of age will have to demonstrate proof of bankable assets of at least MYR 500’000 (approximately USD 120’000) and proof of income of at least MYR 10’000 (approximately USD 2’500) per month. Once granted the conditional approval, they will have to deposit at least MYR 300’000 (approximately USD 72’000) in a bank account of which after one year, up to MYR 150,000 (approximately USD 36’000) may be withdrawn for approved expenses relating to real estate, education of children in Malaysia or medical purposes. Thereafter, under the program a minimum balance of MYR 150’000 (approximately USD 36’000) must be maintained throughout the rest of the stay.
Applicants above 50 years of age will have to demonstrate proof of bankable assets of at least MYR 350’000 (approximately USD 85’000) and proof of income of at least MYR 10’000 (approximately USD 2’500) per month. Once granted the conditional approval, they will have to deposit at least MYR 150’000 (approximately USD 36’000) in a bank account of which after one year, up to MYR 50’000 (approximately USD 12’000) may be withdrawn for approved expenses relating to real estate, education of children in Malaysia or medical purposes. Thereafter, under the program a minimum balance of MYR 100’000 (approximately USD 24’000) must be maintained throughout the rest of the stay.
The Quality of Life Index rank is number 51 of 82 countries Quality of Life Index by Country 2021.
Residents are taxed on any income accruing in or derived from Malaysia only, at a maximum tax rate of 30%. Real property gains taxes can be taxed up to 30%. There are no wealth, inheritance or gift taxes.
Malta
There are various residence programs in Malta. To qualify for the Global Residence Program a nonMaltese citizen from the EU, EEU or Switzerland will be subject to a one-time payment of EUR 30’000 government contribution and a real estate purchase of EUR 320’000 (or EUR 270’000 in South Malta or Gozo), which alternatively can also be a yearly real estate lease of EUR 12’000 (or EUR 10’000 when in South Malta or Gozo). There is a pensioners’ program covering those nationals purchasing real estate with very similar conditions and benefits.
Global residence permit holders pay a flat rate personal income tax of 15% on foreign source income remitted to Malta only – a yearly minimum tax of EUR 15’000 however applies. Local source income will be taxed at 35%. There are no wealth, inheritance or gift taxes in Malta.
Malta residency will provide holder with visa-free movement within the Schengen Area.
Mauritius
Permanent residence can be obtained by investing USD 350’000 in a qualifying real estate. There are also work visas available for business investors starting at USD 50’000 or for retired with a monthly income of at least USD 1’500.
Resident individuals are subject to income tax on their worldwide income from all sources. However, income derived from abroad is taxable only to the extent that it is received in Mauritius. Personal income tax is up to 15% and a solidarity tax of 5% is applicable to income above approximately USD 90’000. There are no wealth, inheritance or gift taxes.
Monaco
Non-EU nationals need to apply for a long-term visa before applying for the residence permit. For the residency permit, evidence concerning proof of wealth without gainful employment has to be provided. Requirement of opening a bank account in Monaco with a minimum EUR 500’000. During the first nine years requirement to spend at least three months per year in Monaco.
There are no income, capital gains or wealth taxes in Monaco, except for French nationals who have to pay French income taxes. There are however inheritance and gift taxes up to 16%, but only on assets situated in Monaco, and not for direct line heirs such as parents, spouse and children. Monaco is not part of the Schengen Zone.
New Zealand
There are two investor programs in New Zealand. For the regular investor visa an experienced business-person under the age of 65 must invest a minimum of NZD 3 million (approximately USD 2 million) in qualifying assets for four years. Business experience and a points-based system to assess eligibility, as well as in certain cases an English language test are required. For the Investor Plus Visa, an investor must invest NZD 10 million (approximately USD 6.6 million) over a three-year period. There are no age limits, language or experience requirements.
The Quality of Life Index rank is number 8 of 82 countries Quality of Life Index by Country 2021.
In New Zealand income taxes on worldwide income are up to 33%. There are no general capital gains taxes, no wealth taxes, and no inheritance or gift taxes but local authorities impose a tax called “rates” on land.
Panama
Proof over an investment of a minimum of USD 500’000 in real estate or on the stock exchange in Panama have to be provided, plus USD 2’000 per additional dependent included in the visa. Alternatively persons with a lifetime annuity or pension of at least USD 1’000 per month.
The Quality of Life Index rank is number 57 of 82 countries Quality of Life Index by Country 2021.
Residents are taxed on their Panamanian source revenues only. Income taxes are up to 25%, and local capital gains are taxed at 10%. There are no inheritance or gift taxes in Panama. There are no wealth taxes, but a real estate tax of up to 1% p.a.
Portugal
Golden visa program for non-EU, EFTA and/or Swiss citizens. Amongst other requirements to qualify for the program, an investment of EUR 500’000 into any real estate, EUR 350’000 into a real estate more than 30 years old with the obligation of renovating it, transferring assets of EUR 1 million to Portugal, an investment of EUR 350’000 into a qualifying fund, or the creation of ten new full-time jobs are necessary.
The Quality of Life Index rank is number 18 of 82 countries Quality of Life Index by Country 2021.
Non-habitual resident status is available providing tax-exemptions for up to ten years. Exemptions from Portuguese taxation include most income from foreign sources, including revenues from nonPortuguese investments, and employment income. Incomes from foreign pensions however are taxed at a 10% flat rate.
Part of the Schengen Zone, permitting residents to travel freely to most parts of the European Union and Switzerland.
Singapore
The Singapore Global Investor Program grants residency to foreign entrepreneurs who invest at least SGD 2.5 million (about 1.85 million USD) in an approved fund investing in Singapore-based companies, the expansion of or new business in Singapore, or a single family office in Singapore managing assets of at least SGD 200 million of which at least 50 million are to be invested domestically. Government will want to see a track record and business plan of the entrepreneur with quite high thresholds.
The Quality of Life Index rank is number 34 of 82 countries (Quality of Life Index by Country 2021.
Income is normally only taxed at a rate up to 22%, when it accrues or is derived from Singapore. There are no capital gains or inheritance taxes. The only wealth tax applicable is on real estate (property tax).
Spain
Currently there is a relatively easy immigration process for high net-worth individuals with a golden visa process requiring an investment in real estate worth at least EUR 500’000 (other programs with higher minimums available).
The Quality of Life Index rank is number 16 of 82 countriesQuality of Life Index by Country 2021.
Upon becoming tax resident: high taxes (income tax depending on the autonomous region, for example the maximum marginal tax rate of 43.5% for an individual resident in Madrid and 48% for a resident in Catalonia). Inheritance and wealth taxes according to the applicable autonomous region. Spanish tax residents and non-residents are subject to tax on dividends, interest and capital gains at a maximum rate of 23%.
Limited tax planning opportunities, for example by obtaining a special fiscal residence permit, paying 24% on local income as non-resident on the first EUR 600’000 income. Part of the Schengen Zone, permitting residents to travel freely to most parts of the European Union and Switzerland.
Switzerland
EU-28 nationals are entitled to a residence permit. For non-EU nationals some additional restrictions like minimum age of 55 may apply.
The Quality of Life Index rank is number 2 of 82 countries Quality of Life Index by Country 2021.
Based on a tax ruling, a so called lump sum taxation is available, which essentially fixes the tax base at 7 times the annual rent for accommodation, with a minimum base of CHF 400’000 for federal tax purposes. Depending on the place of residence within Switzerland this may generate yearly taxation starting at some CHF 140’000. Social security payments may be applicable. Depending on the Canton of residence, your estate may be subject to inheritance taxes.
Part of the Schengen Zone, permitting residents to travel freely to most parts of the European Union.
Thailand
There are several residency by investment program options in Thailand. The most popular one is a five year entry visa which can be obtained by a foreigner with a one-time THB 500’000 (approximately USD 16’000) fee. Another program is designed for two foreigners obtaining five year residence visas with a one-time THB 800’000 (approximately USD 26’000) fee for both visas. This visa includes certain VIP privileges such as airport transfers for international flights and a government concierge and it can be enhanced by paying an additional THB 300’000 (approximately SD 10’000) per dependent family member. Another program includes a 20 year visa for a one-time payment of THB 1 million (approximately USD 32’000) which also comes with VIP privileges. After three years permanent residency can be applied for.
The Quality of Life Index rank is number 69 of 82 countries Quality of Life Index by Country 2021.
Resident taxpayers staying more than 180 days per tax year will only be taxed on income from sources within Thailand and foreign sourced income which is remitted to Thailand in the same year it is earned. Personal income taxes are up to 35%, inheritance taxes are up to 10%, and there are no wealth taxes.
United Arab Emirates
Residency can be obtained by purchasing real estate worth at least AED 1 million (approximately USD 275’000) and having a monthly income of a least AED 10’000. Alternatively, a company can be set up or purchased with a value of at least AED 50’000. The company does not need to carry out any effective commercial activity in the United Arab Emirates, and it can be set up in a free zone where companies are tax exempt, but restricted to do business within the free zone or abroad. There are no income, capital gains, wealth, inheritance or gift taxes in the United Arab Emirates.
The Quality of Life Index rank is number 24 of 82 countries Quality of Life Index by Country 2021.
United Kingdom
Most citizens from the EU, EFTA and Switzerland have the right to live in the UK (some of this may be subject to change soon). For other citizens the investor (minimum investment of GBP 2 million) or entrepreneur (minimum investment of GBP 200’000) routes may be available. The Quality of Life Index rank is number 19 of 82 countries Quality of Life Index by Country 2021.
Investors may apply for a UK resident non-domiciled status, enabling them to opt to apply a remittance basis during the first 15 years, taxing their UK income and gains as well as foreign income and gains of GBP 2’000 or more per year which they bring back to the UK. For the first six years of UK residency the claiming remittance basis is free, from the seventh year onward, a basic charge of GBP 30’000 is applicable which will be increased to GBP 60’000 after 12 years. Maximum income taxes for taxable income are up to 45% for incomes over GBP 150’000; maximum capital gains tax rates are 28%; the inheritance tax rate above GBP 325’000 is 40%. Trusts may offer capital gains tax and inheritance tax opportunities.
The United Kingdom is not part of the Schengen Zone.
United States of America
EB-5 Investors’ visa available for an investment of minimum USD 1.8 million, or USD 900’000 for investments in target employment areas. The Quality of Life Index rank is number 15 of 82 countries Quality of Life Index by Country 2021.
High taxes [federal income tax up to 37%, US estate (inheritance) tax of currently up to 40%], capital gains taxes up to 20%.
Limited tax planning opportunities for individuals setting up irrevocable trusts 5 years before migrating to the US may exempt the trust assets from US estate taxes upon the death of the settlor and subsequent US beneficiaries.
Uruguay
Residency permit may be granted by making a real estate investment of more than UYU 3.5 million (approx. USD 380’000 which are indexed), requiring a minimum presence of 60 days per year. Alternatively a residence permit with no minimum presence can be obtained by investing UYU 15 million (approx. USD 1.6 million).
The Quality of Life Index rank is number 47 of 82 countries Quality of Life Index by Country 2021.
Income of resident individuals from employment is taxed up to 36%. New residents may opt for a tax holiday during the first ten years of obtaining residency from foreign passive income (instead of a tax rate of 12%) or alternatively having it taxed at 7% (instead of 12%) indefinitely. There is an annual personal net-wealth tax on assets situated in Uruguay of up to 0.6%. There are no gift or inheritance taxes.
Vanuatu
Residency for families can be obtained by investors entering into a leasehold (there is no freehold in Vanuatu) of a real estate (residential lease agreements are possible for up to 50 years) with a value over VUV 10 million (approximately USD 88’000) and obtaining a local bank certification of receipt of monthly income over at least VUV 250’000 (approximately USD 2’200) per person included in the application. The visa is valid for one year, and if the requirements are still met thereafter it is renewable. Investors will be required to pay an annual fee of VUV 20,000. After ten years of holding a residence visa, investors are eligible for citizenship by naturalization.
An Individual and his/her partner obtaining a local bank certification of receipt of a monthly income over at least VUV 250’000 (approximately USD 2’200) per person included in the application, can be granted residency.
There is also a foreign investor program (which can include family members) if the investor obtains an approval certificate by the Vanuatu Investment and Promotion Authority indicating that the investor will operate a business in Vanuatu.
There are no income, capital gains, gift, inheritance or wealth taxes in Vanuatu, but there is a tax on rental income of 12.5%.
Further comments
Some additional points have to be taken into consideration when planning a relocation: The current country of residence may impose an exit tax on your leaving the country. Lately quite a number of countries have enacted laws trying to deter individuals or companies from leaving their tax jurisdiction. In many cases the tax authorities of the jurisdiction which is being left will also monitor or even audit the individual leaving or his family as to the substance of the relocation, i.e. check whether the center of vital interest as such has really moved away from their jurisdiction or not. The enter of vital interest includes establishing where the family of the individual in question is, where the social ties including club memberships are, the positions held, participation in political and cultural events, places of business and management of the family wealth, including where the pets are kept. They may also check whether the personal and economic relations to the new jurisdictions are in fact closer than to the jurisdictions being left. If the tax authorities come to the conclusion that the relocation does not have enough substance, i.e. that the center of vital interest and/or the personal and economic relations to the new jurisdiction are less than to their own jurisdiction, they may try to continue to tax the individual leaving as if he/she still remained resident.
Entrepreneurs may also encounter the following issues: If there are participations in the jurisdictions being left, dividend distributions may be subject to a withholding tax. Depending on a potential double tax treaty with the new jurisdiction, the impact of this withholding may however be reduced. Further, if the individual relocating to the new jurisdiction remains in full control, the new jurisdiction may want to tax the company as a local company due to place of effective management rules: The place of effective management is the place where key management and commercial decisions of a business are effectively made. The place of effective management will usually be where the most senior person or group of persons (for example a board of directors)takes its decisions.
Many jurisdictions also have non-residency or temporary residence programs with a minimum number of days per year to be spent in that jurisdiction, but under the condition of not staying more than roughly half the year in the jurisdiction or any other jurisdiction, as well as not having any other tax residence. Some of those jurisdictions even issue tax residence confirmations for qualifying non-residents. This article has not reflected any of these programs given the increased risk that other jurisdictions, especially the one of the last tax residence of the taxpayer, will not accept such a non-residency program as a regular new tax residence. The risk is even higher when considerable economic substance of an investor remains in the jurisdiction he/she is leaving. When this is the case, such jurisdictions may continue to tax the taxpayer fully, as if he/she had never left.
Whereas many of these relocation programs provide considerable tax advantages, careful prerelocation tax planning based on tax advice obtained in the old and the new jurisdiction is strongly recommended.
Copyright by René M. La Barre, Global Wealth Management Consulting GmbH, www.gwmc.ch, September 2020. All rights reserved.
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