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Special Tax Regimes Hub 2026: Expat & New Resident Schemes

Daniel · CountryTaxCalc Updated September 2026
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KEY INSIGHT
Several European countries offer structured special tax regimes for qualifying new residents: Portugal's IFICI (20% flat rate, 10 years), Spain's Beckham Law (24% flat rate, up to 6 years), Netherlands 30% Ruling (up to 30% of salary tax-free, 27% from 2027, up to 5 years), Italy's lump-sum regime (€300,000 flat fee on foreign income), Denmark's 27% expatriate scheme (flat rate for 5 years). Use the guides below to find what you qualify for.
At a glance

Key Facts

Portugal IFICI (Formerly NHR)
Portugal's Non-Habitual Resident (NHR) regime was replaced by IFICI (Individual Incentive for Scientific Research and Innovation) from 1 January 2024. New applicants fall under IFICI; existing NHR holders retain their status. IFICI offers a 20% flat rate on eligible Portuguese-sourced income for 10 years. Eligibility is significantly more restricted than the original NHR — focused on qualifying professions, researchers, and tech workers. Foreign-sourced income may be exempt under the territorial approach.
Spain Beckham Law
Spain's Ley Beckham (Special Regime for Impatriates) allows qualifying new residents to pay income tax at a flat 24% on Spanish-sourced income (instead of the progressive scale, which reaches 47%) for up to 6 years. Qualifying workers must not have been Spanish tax residents in the previous 5 years and must move to Spain for employment or business activity. Following the 2023 reform, remote workers and digital nomads using Spain's Digital Nomad Visa can also qualify. Application must be made within 6 months of registering with Spanish social security.
Netherlands 30% Ruling
The Netherlands 30% Ruling (30%-regeling) allows qualifying highly-skilled migrants to receive up to 30% of their gross salary tax-free as an allowance for extraterritorial costs — significantly reducing their effective tax rate. The maximum falls to 27% from 1 January 2027 (employees who started using the ruling by 31 December 2023 keep 30%), and since 1 January 2026 the allowance is calculated on salary of at most €262,000 (maximum €78,600 tax-free). To qualify, the employee must be recruited from abroad (having lived more than 150km from the Dutch border for more than 16 of the previous 24 months) and have specific expertise, shown by meeting the 2026 salary norm: a taxable salary of at least €48,013 excluding the allowance (€36,497 for those under 30 with a qualifying master's degree; no minimum for certain scientific researchers and doctors in training). The maximum duration has been 5 years (previously 8) since 2019.
Italy's Two Flat Tax Regimes
Italy has two distinct flat tax programmes for new residents: (1) The High-Net-Worth Lump Sum regime (€300,000 per year, or €100,000 from 2024 for new applicants) applies a flat annual tax on all foreign-sourced income regardless of amount — no upper limit. (2) The Retiree Flat Tax of 7% applies to foreign pension and foreign-sourced income for qualifying pensioners who move to eligible towns in southern Italy, Sicily, or Sardinia with fewer than 20,000 inhabitants.
Introduction

Special tax regimes for new residents are one of the most powerful — and commonly misunderstood — tools in international tax planning. These are formally legislated preferential tax programmes designed by governments to attract high-skilled workers, high-net-worth individuals, or retirees from abroad. They are completely legal and transparent when used correctly.

This hub collects every special tax regime guide on CountryTaxCalc, covering the major European schemes and beyond. Each guide covers eligibility criteria, application processes, the actual tax savings in worked examples, and the anti-avoidance rules that govern each programme. All content is sourced from official tax authority publications.

Section 01

Portugal: NHR and IFICI Guides

Portugal remains one of the most popular destinations for tax-motivated relocation due to its combination of quality of life, EU membership, and favourable regimes:

Section 02

Spain: Beckham Law Guides

Spain's Beckham Law is one of the broadest special regimes in Europe — now accessible to remote workers via the Digital Nomad Visa as well as traditional employment relocations:

Section 03

Netherlands: 30% Ruling

The Netherlands 30% Ruling is one of the most generous salary-based tax incentives in Europe for internationally mobile professionals:

Section 04

Italy, Denmark & South Korea

Other European and Asian countries with significant special tax regimes for new residents or highly-skilled workers:

Section 05

UAE: Zero-Tax Residency

While not technically a 'special regime' (since all UAE residents pay 0% personal income tax), the UAE is the most common destination for tax-motivated relocation:

Section 06

Related Hubs

Special tax regimes connect closely with these broader planning topics:

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FAQ

Frequently Asked Questions

What is the Portugal NHR regime and is it still available?

The Non-Habitual Resident (NHR) regime was Portugal's flagship preferential tax programme, offering foreign-sourced income exemptions and a 20% flat rate on qualifying Portuguese income for 10 years. The NHR programme was officially closed to new applications from 31 December 2023. It was replaced by IFICI (Individual Incentive for Scientific Research and Innovation) from 1 January 2024. Existing NHR holders retain their status for the remainder of their 10-year period. New applicants must use IFICI, which has more restrictive eligibility requirements — focused on qualifying professions including researchers, tech workers, and startups. The IFICI application process and qualifying categories are covered in detail in the Portugal IFICI Regime 2026 guide.

Who qualifies for Spain's Beckham Law?

To qualify for Spain's Beckham Law (Special Impatriates Regime), you must: (1) not have been a Spanish tax resident in the previous 5 years; (2) move to Spain as a result of an employment contract, the displacement of an administrator to a Spanish company, or (from 2023) as a remote worker using the Digital Nomad Visa; (3) apply within 6 months of registering for Spanish Social Security or obtaining your NIE. Family members may also qualify under certain conditions. You cannot qualify if you were already a Spanish national returning to Spain, or if your income from a Spanish entity already benefits from reduced tax treatment. The flat 24% rate applies to the first €600,000 of Spanish-sourced employment income; income above that is taxed at 47%.

How much does the Netherlands 30% Ruling save?

The 30% Ruling allows the employer to pay up to 30% of the employee's total gross salary as a tax-free expense reimbursement. This effectively reduces the taxable salary by 30%, which can reduce the effective Dutch income tax rate significantly. For an employee earning €100,000 in 2026, the taxable salary becomes €70,000 — reducing Dutch Box 1 income tax from about €37,289 to about €20,953, a saving of roughly €16,300 per year (employee under AOW age, including the general and labour tax credits). The maximum falls to 27% from 1 January 2027 for employees who did not start using the ruling by 31 December 2023, and since 2026 the allowance is calculated on salary of at most €262,000. The ruling also allows you to exchange a foreign driving licence for a Dutch one without a test. The former option to be treated as a partial non-resident taxpayer for Box 2 and Box 3 was abolished from 2025 (with a transition to the end of 2026 for pre-2024 ruling users). The ruling lasts a maximum of 5 years (reduced from 8 years in 2019).

Can I use a special tax regime as a US citizen?

Yes — US citizens can apply for and benefit from special tax regimes in Portugal, Spain, the Netherlands, Italy, Denmark, and other countries. However, US citizens cannot simply eliminate their US tax liability by moving abroad. The US taxes citizens on worldwide income regardless of residence. Using a special regime in another country reduces your local tax liability in that country, but you still file a US return and may owe US tax on the same income after applying the Foreign Tax Credit or FEIE. For US citizens, the combination of a foreign special regime and the FEIE or FTC can significantly reduce total global tax — but the interaction is complex and specialist US expat tax advice is essential.

What happens when a special tax regime ends?

When your special regime period ends, you revert to the standard tax treatment of your country of residence. For most regimes (Portugal IFICI, Spain Beckham Law, Denmark 27% scheme), this means transitioning to the standard progressive income tax rates — which are significantly higher. Many people who moved under a special regime choose to reassess their residency situation when the regime expires: either renewing under a new regime if available, relocating to another favourable jurisdiction, or accepting the higher standard rates. Planning for regime expiry is an important part of international tax planning — ideally reviewed 2–3 years before the regime ends.
Disclaimer:Special tax regimes are legislated programmes subject to eligibility requirements, application deadlines, and legislative change. The guides on this hub are sourced from official government tax authority publications and reviewed annually. Programme eligibility, rates, and duration have changed for many regimes in 2023–2024 — verify current status before making relocation decisions. For US citizens, a foreign special regime does not eliminate US tax obligations. This hub provides general educational information only — not tax or legal advice. International tax planning involving regime changes should be handled by a qualified international tax adviser with expertise in the relevant jurisdiction.
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