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Low tax countries

Where you can legally pay less tax, and what each place really costs

Twenty six places people ask about, with the published rates, the residence conditions, who each one genuinely suits, and the catch that stops most people saving anything.

A layered green world map with brass pins on low tax countries

Read this before the tables: there is no hiding place left

Every country on this page reports your accounts back to your own tax office automatically. Names, balances and income, once a year, without you being asked. So this page is not about hiding money, which is a crime and carries penalties far bigger than the tax. It is about the legal version, which is often worth more: choosing where you live, where your company is genuinely run, and where you bank, then paying the correct lower amount out in the open.

  • More than 100 countries automatically exchange account holder names, balances and income each year under the Common Reporting Standard.
  • The United States receives the same data through FATCA agreements with banks worldwide.
  • Beneficial ownership registers in the Crown Dependencies and Overseas Territories are open to law enforcement and tax authorities.
  • Economic substance rules mean a company with no people and no decisions in a zero tax place can be denied its benefits.
  • Failure to correct an offshore matter in the UK can carry a penalty of up to 200 percent of the tax due.

Places researched

26

Rates as published for 2025 and 2026

Countries swapping account data

100+

Common Reporting Standard and FATCA

UK penalty for an uncorrected offshore matter

Up to 200%

Of the tax due, on top of the tax

United Arab Emirates (Dubai and Abu Dhabi)

The Gulf 路 rates for 2026

No personal income tax, and company tax of 9 percent only above a modest profit level.

Personal income tax
No personal income tax on salary, dividends or investment income.
Company tax
0 percent on taxable profit up to AED 375,000 and 9 percent above it. Small business relief lets a business with revenue up to AED 3 million elect to be treated as having no taxable income, now extended to periods ending on or before 31 December 2029.
Capital gains
No personal capital gains tax.
Dividends
No tax on dividends received by an individual.
Inheritance
No inheritance tax, though Sharia rules can apply to local assets without a registered will.
What being there costs
A free zone licence, office or flexi desk and visa typically run several thousand pounds a year, plus health insurance, plus a real place to live if you want residence to hold up.
Days and residence test
Tax residence normally needs 183 days in the country, or 90 days with a home and a job or business, for the 12 month period.
Reporting to your tax office
Reports UK, US and Australian account holders automatically under the Common Reporting Standard and FATCA.

Genuinely suits

  • Remote business owners who genuinely move
  • Traders and consultants with worldwide clients
  • People selling a business after leaving home for good

Not for: Anyone who keeps living in the UK, the US or Australia and only registers a company there.

The catch: A free zone company is inside the corporate tax system, not automatically exempt. Only a qualifying free zone person with real substance gets 0 percent on qualifying income.

UAE Federal Tax Authority

Qatar

The Gulf 路 rates for 2025

No personal income tax, 10 percent company tax.

Personal income tax
No personal income tax on employment income.
Company tax
10 percent on locally sourced business profit, with special rules inside the financial centre.
Capital gains
No personal capital gains tax on ordinary private gains.
Dividends
No personal tax on dividends.
Inheritance
No inheritance tax.
What being there costs
Employment or business sponsorship is normally needed, so this suits people with a job offer or a real local trade.
Days and residence test
Residence follows the visa and the physical presence, generally more than 183 days.
Reporting to your tax office
Common Reporting Standard participant.

Genuinely suits

  • Employees on Gulf packages
  • Engineering, energy and construction contractors

Not for: Passive residence shopping. Entry is tied to sponsorship.

The catch: Leaving your home country properly matters more than the Qatari rate. Your home rules decide who taxes you first.

Qatar General Tax Authority

Saudi Arabia

The Gulf 路 rates for 2025

No personal income tax, 20 percent company tax, and a fast growing jobs market.

Personal income tax
No personal income tax on salary.
Company tax
20 percent corporate income tax for foreign owned companies, plus zakat rules for Saudi and Gulf ownership.
Capital gains
Gains inside a business are taxed as profit. Private individuals have no personal capital gains tax on ordinary assets.
Dividends
No personal tax on dividends received.
Inheritance
No inheritance tax.
What being there costs
Regional headquarters and licence rules apply to businesses selling to government. Employment usually needs sponsorship.
Days and residence test
183 days of presence generally makes you resident.
Reporting to your tax office
Common Reporting Standard participant.

Genuinely suits

  • Salaried professionals relocating
  • Companies with genuine Gulf operations

Not for: Someone who wants a paper company with nobody there.

The catch: Withholding tax applies on many payments out of the country, which surprises consultants invoicing from elsewhere.

Zakat, Tax and Customs Authority

Ireland

Europe 路 rates for 2026

12.5 percent trading company tax inside the EU, with a real economy behind it.

Personal income tax
20 and 40 percent income tax, plus USC and PRSI, so personal tax is not low.
Company tax
12.5 percent on trading profit, 25 percent on non trading income, and a 15 percent top up for groups with revenue over EUR 750 million.
Capital gains
33 percent capital gains tax.
Dividends
Taxed as income, with a dividend withholding tax mechanism.
Inheritance
33 percent capital acquisitions tax above tax free thresholds.
What being there costs
Directors, an office, accounts and audit thresholds. Substance rules are taken seriously.
Days and residence test
183 days in a year, or 280 days across two years, makes you resident.
Reporting to your tax office
Full exchange of information with the UK, the US and Australia.

Genuinely suits

  • Software and services businesses that really operate there
  • Groups needing EU market access
  • Holding companies with treaty needs

Not for: Someone wanting low personal tax. Ireland taxes people at normal European levels.

The catch: The 12.5 percent applies to trading profit earned in Ireland by people working in Ireland, not to profit you earn at home.

Irish Revenue

Cyprus

Europe 路 rates for 2025

12.5 percent company tax, and 17 years of no tax on dividends and interest for new non domiciled residents.

Personal income tax
0 to 35 percent income tax, with the first EUR 19,500 free.
Company tax
12.5 percent corporate income tax.
Capital gains
Only on Cyprus immovable property. Share and fund gains are generally free.
Dividends
Non domiciled residents pay no defence contribution on dividends and interest for 17 years.
Inheritance
No inheritance tax.
What being there costs
Company running costs are modest. Social insurance and a general health contribution still apply on earnings.
Days and residence test
183 days, or the 60 day rule if you are not tax resident anywhere else and have a home, a business or a job there.
Reporting to your tax office
EU exchange of information plus the Common Reporting Standard.

Genuinely suits

  • Investors living on dividends
  • Consultants and fund managers
  • Company owners who want an EU base and low personal tax

Not for: Someone who wants to keep living in the UK. Cyprus residence needs you actually there.

The catch: The 60 day rule is strict. You must not be tax resident anywhere else, and you must not spend 183 days in another country.

Cyprus Tax Department

Malta

Europe 路 rates for 2025

A 35 percent headline company rate with refunds that can bring the real cost near 5 percent, plus a 15 percent flat rate for some residents.

Personal income tax
Progressive to 35 percent, with a remittance basis for resident non domiciled people.
Company tax
35 percent, reduced by shareholder refunds that commonly bring the effective rate to about 5 percent on qualifying distributed trading profit.
Capital gains
Taxed as income on Maltese assets. Foreign gains not remitted are generally outside the charge for resident non domiciled people.
Dividends
Refund system applies on distribution.
Inheritance
No inheritance tax, but a stamp duty applies on property and share transfers.
What being there costs
Two company layers, audits and advisers make Malta more expensive to run than its headline suggests. The Global Residence Programme has a minimum tax and a property requirement.
Days and residence test
183 days for ordinary residence. Programme residents have their own conditions.
Reporting to your tax office
EU exchange of information plus the Common Reporting Standard.

Genuinely suits

  • Trading groups with proper advice
  • Aviation, gaming and shipping businesses
  • People wanting a remittance basis inside the EU

Not for: Small one person businesses. The professional cost eats the saving.

The catch: The refund arrives after tax is paid, so you need cash to fund the 35 percent in the meantime.

Malta Commissioner for Revenue

Portugal

Europe 路 rates for 2026

The old non habitual resident scheme is closed. The replacement is narrower but still 20 percent for qualifying work.

Personal income tax
Progressive to 48 percent normally. The IFICI incentive gives a 20 percent flat rate on qualifying Portuguese employment or self employment income, with exemptions on most foreign income, for ten years.
Company tax
20 percent standard corporate tax, with a reduced rate on the first slice of profit for small companies, plus municipal surcharges.
Capital gains
28 percent on securities for residents, with an option to be taxed at scale rates. Property has its own rules.
Dividends
28 percent flat, or scale rates by election.
Inheritance
No inheritance tax between close family. A 10 percent stamp duty applies to others.
What being there costs
You must qualify for IFICI through a listed research, innovation or highly skilled role. Ordinary remote workers usually do not.
Days and residence test
183 days, or a home in Portugal used as your habitual residence.
Reporting to your tax office
EU exchange of information plus the Common Reporting Standard.

Genuinely suits

  • Researchers and skilled professionals in listed roles
  • Startup employees in certified companies
  • Retirees who accept normal rates for the lifestyle

Not for: Anyone still quoting the old non habitual resident 10 percent pension deal. That door shut for new arrivals.

The catch: Portugal replaced the old scheme in 2024. Old blog posts are the single biggest source of bad advice here.

Autoridade Tributaria e Aduaneira

Bulgaria

Europe 路 rates for 2025

A flat 10 percent on personal income and company profit, inside the EU.

Personal income tax
Flat 10 percent income tax.
Company tax
Flat 10 percent corporate tax.
Capital gains
Taxed as income at 10 percent. EU regulated market share sales are exempt.
Dividends
5 percent final tax.
Inheritance
Low local inheritance tax, with close family generally exempt.
What being there costs
Social security contributions on earnings are real and capped. Company running costs are low.
Days and residence test
183 days, or your centre of vital interests being in Bulgaria.
Reporting to your tax office
EU exchange of information plus the Common Reporting Standard.

Genuinely suits

  • Owner managers who will really live there
  • Software and services businesses
  • People who want simple numbers

Not for: Someone who needs a prestigious address for clients.

The catch: 10 percent plus 5 percent on dividends is still a real bill, and social security adds to it.

Bulgarian National Revenue Agency

Estonia

Europe 路 rates for 2026

No company tax until profit leaves the company.

Personal income tax
Flat personal income tax, with a tax free allowance.
Company tax
0 percent on retained profit. Tax arrives on distribution at 22/78 of the net amount paid out.
Capital gains
Taxed as income when realised by an individual.
Dividends
Taxed on distribution through the company charge.
Inheritance
No inheritance tax.
What being there costs
Accounting and payroll filings every month. Company cars, personal purchases and loans to yourself can all count as distributions.
Days and residence test
183 days in a 12 month period, or a permanent home there.
Reporting to your tax office
EU exchange of information plus the Common Reporting Standard.

Genuinely suits

  • Businesses reinvesting everything for years
  • Digital businesses that want clean EU paperwork

Not for: Anyone who needs to take the money out each year. Then it is an ordinary rate.

The catch: The famous 0 percent is a delay, not a gift. It ends the moment value leaves the company in any form.

Estonian Tax and Customs Board

Georgia

Europe 路 rates for 2025

1 percent turnover tax for small businesses, and a territorial slant on foreign income.

Personal income tax
Flat 20 percent income tax, with a small business status charging 1 percent of turnover up to a yearly limit.
Company tax
15 percent, taxed on distribution in the Estonian style.
Capital gains
Generally taxed as income, with exemptions for property and shares held over two years.
Dividends
5 percent withholding.
Inheritance
No inheritance tax between close relatives.
What being there costs
Very low. Registration is quick and banking is simple for residents with substance.
Days and residence test
183 days in any rolling 12 month period.
Reporting to your tax office
Common Reporting Standard participant since 2023.

Genuinely suits

  • Freelancers and small consultancies
  • People who will really move outside the EU

Not for: Anyone needing EU market access or a European banking passport.

The catch: Small business status has activity exclusions, including consulting in some readings. Get local confirmation before relying on 1 percent.

Georgia Revenue Service

Switzerland

Europe 路 rates for 2025

Company tax from about 12 percent depending on canton, and a lump sum deal for some wealthy arrivals.

Personal income tax
Federal, cantonal and communal tax combined, from roughly 22 to over 40 percent depending on where you live.
Company tax
Around 12 to 21 percent in total depending on canton, with Zug and Lucerne at the low end.
Capital gains
No tax on private capital gains on movable assets for individuals who are not trading professionally.
Dividends
Taxed as income, with relief for qualifying holdings.
Inheritance
Cantonal, and usually nothing between spouses and children.
What being there costs
High cost of living, and the lump sum arrangement needs a minimum annual tax agreed with the canton.
Days and residence test
A permit and a home, plus intention to stay, rather than a simple day count.
Reporting to your tax office
Common Reporting Standard participant. Banking secrecy no longer blocks reporting.

Genuinely suits

  • Owners selling shareholdings
  • Wealthy families wanting stability
  • Trading and commodity businesses

Not for: Someone on a modest income. Living costs cancel out the tax saving.

The catch: No capital gains tax on private assets is the real prize, not the income tax rate.

Swiss Federal Tax Administration

Monaco

Europe 路 rates for 2025

No personal income tax for residents, unless you are French.

Personal income tax
No personal income tax, except for French nationals under the 1963 treaty.
Company tax
33.33 percent business profits tax where more than 25 percent of turnover comes from outside Monaco.
Capital gains
No personal capital gains tax.
Dividends
No personal tax on dividends.
Inheritance
0 percent in the direct line, rising to 16 percent between unrelated people.
What being there costs
You must rent or buy a home in Monaco and deposit a substantial sum with a Monaco bank, typically several hundred thousand euros, and property is among the most expensive in the world.
Days and residence test
You must keep the home and normally live there, with cards renewed periodically.
Reporting to your tax office
Common Reporting Standard participant.

Genuinely suits

  • Very high net worth individuals
  • Sports professionals and traders

Not for: Almost everyone else, on cost alone.

The catch: The tax is zero and the rent is not. Run the total cost, not the tax rate.

Government of Monaco

Andorra

Europe 路 rates for 2025

A 10 percent cap on personal and company tax in the Pyrenees.

Personal income tax
0 percent to EUR 24,000, 5 percent to EUR 40,000, then 10 percent.
Company tax
10 percent corporate tax.
Capital gains
10 percent, with exemption for holdings under 25 percent held over ten years.
Dividends
Andorran source dividends are exempt in the hands of residents.
Inheritance
No inheritance tax.
What being there costs
Passive residence needs an investment in Andorra, commonly EUR 600,000, plus a deposit with the regulator and private health cover.
Days and residence test
90 days for passive residence, 183 days for active residence.
Reporting to your tax office
Common Reporting Standard participant.

Genuinely suits

  • Business owners wanting low tax with European life
  • Investors and retirees

Not for: People who need an airport on the doorstep or EU membership benefits.

The catch: It is not in the EU, so EU VAT and free movement rules do not apply to your business.

Govern d'Andorra

Isle of Man

British Isles and small island states 路 rates for 2025

0 percent company tax on most trading, sterling banking, and a cap on personal tax.

Personal income tax
10 and 21 percent income tax, with a yearly tax cap of around GBP 220,000 per person by election.
Company tax
0 percent on most income, 10 percent on banking and retail above a threshold, 20 percent on Manx land and property.
Capital gains
No capital gains tax.
Dividends
Taxed as income for residents.
Inheritance
No inheritance tax.
What being there costs
Real presence expected. Directors, offices and economic substance rules apply to relevant activity.
Days and residence test
Six months in a year, or an average of three months across four years.
Reporting to your tax office
Common Reporting Standard participant reporting to HMRC.

Genuinely suits

  • Owner managers who genuinely relocate
  • E gaming, shipping and aircraft businesses
  • Families wanting sterling and UK proximity

Not for: Anyone staying UK resident. HMRC will still tax you in full.

The catch: A Manx company controlled from the UK can be UK tax resident by management and control. Where the decisions are made is what counts.

Isle of Man Government Income Tax Division

Jersey

British Isles and small island states 路 rates for 2025

0 percent company tax on most trading, 20 percent personal, and a high value residence route.

Personal income tax
20 percent flat, or the 2(1)(e) high value residence route with a large minimum annual tax contribution.
Company tax
0 percent standard, 10 percent for financial services, 20 percent for utilities and property income.
Capital gains
No capital gains tax.
Dividends
Taxed as income for residents.
Inheritance
No inheritance tax, but probate fees apply.
What being there costs
High value residence needs an expensive home purchase and an agreed minimum tax bill each year.
Days and residence test
Presence and a place of abode, with a 183 day and three month average test.
Reporting to your tax office
Common Reporting Standard participant reporting to HMRC.

Genuinely suits

  • Funds and holding structures
  • High net worth families
  • Trust and estate planning

Not for: Small businesses who cannot fund the professional cost.

The catch: Jersey is excellent for holding assets and poor for pretending your UK work happens there.

Government of Jersey Revenue

Guernsey

British Isles and small island states 路 rates for 2025

0 percent company tax on most income, with a personal tax cap.

Personal income tax
20 percent flat, with caps on total tax for new residents and on non Guernsey income.
Company tax
0 percent standard, 10 percent for regulated finance, 20 percent for property and utilities.
Capital gains
No capital gains tax.
Dividends
Taxed as income for residents.
Inheritance
No inheritance tax.
What being there costs
Housing market is restricted by licence categories, which makes moving there harder than it looks.
Days and residence test
91 days, or 35 days a year averaged over four years.
Reporting to your tax office
Common Reporting Standard participant reporting to HMRC.

Genuinely suits

  • Insurance and fund businesses
  • Investors and retirees with capital

Not for: Anyone needing quick, cheap housing.

The catch: Open market housing is far more expensive than local market housing, and that decides who can actually move.

States of Guernsey Revenue Service

Gibraltar

British Isles and small island states 路 rates for 2025

15 percent company tax, sterling, English law, and a capped tax status for wealthy residents.

Personal income tax
Two systems, allowance based or gross income based, with an effective top rate near 25 percent, plus Category 2 status capping tax on a limited slice of income.
Company tax
15 percent corporate tax on income accrued in and derived from Gibraltar.
Capital gains
No capital gains tax.
Dividends
No tax on dividends from a Gibraltar company for non residents, and relief for residents.
Inheritance
No inheritance tax.
What being there costs
Category 2 status needs approved residential accommodation and a minimum net worth, and there is a minimum and maximum annual tax.
Days and residence test
183 days in a year, or 300 days over three years.
Reporting to your tax office
Common Reporting Standard participant reporting to HMRC.

Genuinely suits

  • Insurance, gaming and shipping businesses
  • Wealthy individuals wanting English law and sterling

Not for: Someone wanting EU market access post Brexit.

The catch: Accrued in and derived from Gibraltar is a narrow test. Work done elsewhere is often taxed elsewhere.

Gibraltar Income Tax Office

Singapore

Asia 路 rates for 2025

17 percent company tax with generous start up exemptions, no capital gains tax, and a first class banking system.

Personal income tax
0 to 24 percent for residents, territorial in practice for most foreign income.
Company tax
17 percent, with partial exemption and a start up exemption on early profit.
Capital gains
No capital gains tax.
Dividends
One tier system, so Singapore dividends are tax free in the shareholder's hands.
Inheritance
No estate duty.
What being there costs
Directors resident locally, real office, high salaries, and employment pass criteria that are getting stricter.
Days and residence test
183 days in a calendar year.
Reporting to your tax office
Common Reporting Standard participant and FATCA partner.

Genuinely suits

  • Asian trading and holding companies
  • Fund managers and family offices
  • Businesses selling into the region

Not for: Anyone hoping for a cheap shell. Substance requirements and costs are high.

The catch: No capital gains tax is the real advantage. The corporate rate is not the lowest around.

Inland Revenue Authority of Singapore

Hong Kong

Asia 路 rates for 2025

8.25 percent on the first slice of company profit, and tax only on Hong Kong sourced income.

Personal income tax
2 to 17 percent progressive, or 15 percent standard rate, whichever gives less.
Company tax
8.25 percent on the first HKD 2 million of profit, 16.5 percent above, with a territorial source rule.
Capital gains
No capital gains tax.
Dividends
No tax on dividends.
Inheritance
No estate duty.
What being there costs
Company setup is cheap. Bank account opening is the hard part and often needs a visit and real trade evidence.
Days and residence test
Presence based, with 180 days in a year or 300 days over two years for treaty purposes.
Reporting to your tax office
Common Reporting Standard participant.

Genuinely suits

  • Trading with mainland China and Asia
  • Holding intellectual property with real management there

Not for: Someone who cannot travel there to open banking.

The catch: Offshore profits claims are examined closely, and getting one wrong is expensive.

Hong Kong Inland Revenue Department

Cayman Islands

Caribbean and Atlantic 路 rates for 2025

No income, company, capital gains or inheritance tax at all.

Personal income tax
None.
Company tax
None.
Capital gains
None.
Dividends
None.
Inheritance
None.
What being there costs
Government fees, a registered office and, for residence, a substantial investment in local property plus a minimum annual income requirement.
Days and residence test
Residence certificates carry their own presence and investment conditions.
Reporting to your tax office
Common Reporting Standard participant, plus economic substance filings and a beneficial ownership register.

Genuinely suits

  • Investment funds
  • Group holding vehicles
  • Insurance and reinsurance

Not for: A working person's income. A Cayman company does not change where you pay tax on your own work.

The catch: For a UK, US or Australian resident owner, anti avoidance rules commonly tax the profit at home anyway, so the zero rate delivers nothing.

Cayman Islands Government

British Virgin Islands

Caribbean and Atlantic 路 rates for 2025

No corporate or capital gains tax, and the world's most used holding company.

Personal income tax
No income tax, but a payroll tax on employment.
Company tax
No corporate income tax.
Capital gains
None.
Dividends
None.
Inheritance
None.
What being there costs
Annual government fees, registered agent fees, economic substance filings and beneficial ownership reporting.
Days and residence test
Residence is separate and rarely the point of a BVI company.
Reporting to your tax office
Common Reporting Standard participant with a beneficial ownership register accessible to authorities.

Genuinely suits

  • Joint venture and holding vehicles
  • Property holding for multi country investors

Not for: Trading businesses run from a home country.

The catch: Banks are cautious with BVI companies, so opening an account is often harder than forming the company.

BVI Government

Bermuda

Caribbean and Atlantic 路 rates for 2025

No income tax, and the global centre for insurance and reinsurance.

Personal income tax
No income tax. A payroll tax applies to employers and employees.
Company tax
No corporate income tax historically, with a 15 percent corporate income tax from 2025 for large multinational groups.
Capital gains
None.
Dividends
None.
Inheritance
None. Stamp duty applies on local estates.
What being there costs
High cost of living and government fees, plus real staff for insurance licences.
Days and residence test
Work permits govern presence.
Reporting to your tax office
Common Reporting Standard participant.

Genuinely suits

  • Insurance and reinsurance
  • Large group holding structures

Not for: Small businesses.

The catch: The new 15 percent charge for large groups shows that zero rates are being closed off worldwide.

Government of Bermuda

Bahamas

Caribbean and Atlantic 路 rates for 2025

No income tax, and residence available through property investment.

Personal income tax
No income tax. VAT and property taxes are the main charges.
Company tax
No corporate income tax, with a business licence fee on turnover.
Capital gains
None.
Dividends
None.
Inheritance
None.
What being there costs
Permanent residence normally follows a substantial property purchase, with accelerated consideration above a higher figure.
Days and residence test
Residence permits set the conditions rather than a day count.
Reporting to your tax office
Common Reporting Standard participant.

Genuinely suits

  • Retirees and investors with capital
  • Family offices

Not for: People needing a European time zone workday or cheap living.

The catch: No income tax does not remove the UK, US or Australian charge until you have properly ceased residence at home.

Government of the Bahamas

Panama

The Americas 路 rates for 2025

Territorial tax, so foreign income of residents is generally untaxed.

Personal income tax
0 to 25 percent on Panama source income only.
Company tax
25 percent on Panama source profit. Foreign source profit is outside the charge.
Capital gains
10 percent on local share sales, with withholding rules.
Dividends
5 to 10 percent withholding on local distributions.
Inheritance
None.
What being there costs
Residence routes include the friendly nations visa with a local economic tie or property purchase, plus legal fees.
Days and residence test
183 days for tax residence certification, plus permit conditions.
Reporting to your tax office
Common Reporting Standard participant.

Genuinely suits

  • Location independent business owners who really move
  • Latin America facing trade

Not for: Anyone who wants EU or UK banking to stay simple. Panama raises questions with banks.

The catch: Reputation matters. Panama on a bank form triggers extra checks even when everything is correct.

Direccion General de Ingresos

Puerto Rico (for US citizens)

The Americas 路 rates for 2025

The one route where a US citizen can legally cut US federal tax without giving up the passport.

Personal income tax
Act 60 individual resident investor decree gives 0 percent Puerto Rico tax on interest, dividends and certain capital gains accrued after moving, and Puerto Rico source income is excluded from US federal tax under section 933.
Company tax
4 percent fixed income tax rate for qualifying export services businesses under Act 60.
Capital gains
0 percent on gains accruing after becoming a bona fide resident. Pre move gains stay taxable in the US.
Dividends
0 percent on qualifying Puerto Rico sourced distributions under a decree.
Inheritance
US federal estate tax still applies to US citizens.
What being there costs
Annual filing fees, a charitable donation requirement, a property purchase requirement, and you must genuinely move: presence, closer connection and no tax home elsewhere.
Days and residence test
The bona fide residence test: 183 days presence, no tax home outside, and no closer connection elsewhere.
Reporting to your tax office
Inside the US system. The IRS audits Act 60 claims actively.

Genuinely suits

  • US business owners with export service income
  • US investors sitting on future gains

Not for: Non US people, and any US person unwilling to actually live there.

The catch: Gains that built up before you moved remain US taxable. Only future growth benefits.

IRS bona fide residence rules

Delaware and Wyoming (for non US owners)

The Americas 路 rates for 2025

A US company with no US federal tax where the owner and the work are both outside the US.

Personal income tax
No US personal tax for a non resident with no US trade or business and no US source income.
Company tax
A single member LLC is disregarded, so profit is taxed to the owner where the owner is resident. Wyoming and Delaware charge no state income tax on out of state activity.
Capital gains
Taxed where the owner is resident.
Dividends
No withholding on a disregarded LLC's distribution to its owner in most cases.
Inheritance
US estate tax can catch US situs assets held by non residents.
What being there costs
Registered agent, franchise or annual report fee, and Form 5472 with a pro forma 1120 every year, with a USD 25,000 penalty for missing it.
Days and residence test
Not applicable. The point is that you are not there.
Reporting to your tax office
The US does not join the Common Reporting Standard but exchanges under FATCA and bilateral agreements.

Genuinely suits

  • Non US freelancers and e commerce sellers wanting USD banking
  • Software businesses selling to US customers

Not for: UK, US or Australian residents hoping the LLC hides profit. Your home country taxes it in full.

The catch: For a UK resident owner, an LLC can be taxed twice through mismatched treatment. Get specific advice before using one.

IRS Form 5472 instructions

What your own country still charges you

This is the part that decides whether any of the above saves you a penny. Until you have properly left, your home country taxes your worldwide income whatever your company's address says.

United Kingdom

  • The statutory residence test decides whether HMRC taxes your worldwide income. Days, homes, work and family ties all count.
  • Split year treatment can apply in the year you leave, but only if you meet one of the specific cases.
  • Temporary non residence rules claw back dividends and gains if you return within five full tax years.
  • A company controlled from the UK can be UK tax resident wherever it is registered, through central management and control.
  • Transfer of assets abroad and controlled foreign company rules tax offshore profit back to a UK owner.
  • Inheritance tax follows long term residence, so it can still apply after you leave.
HMRC RDR3 statutory residence test

United States

  • US citizens and green card holders file on worldwide income wherever they live.
  • The foreign earned income exclusion and foreign tax credits reduce double tax but do not end filing.
  • FBAR and Form 8938 report foreign accounts, with heavy penalties for missing them.
  • Giving up citizenship or a long held green card can trigger the expatriation tax on unrealised gains.
  • Controlled foreign corporation and GILTI rules tax a US owner on a foreign company's profit.
  • Puerto Rico is the one route that reduces federal tax without renouncing.
IRS international taxpayers

Australia

  • The residency tests look at where you ordinarily live, your domicile and the 183 day rule.
  • Leaving Australia triggers a deemed disposal of most assets other than Australian property, unless you elect otherwise.
  • Non residents lose the tax free threshold and pay a higher first rate on Australian income.
  • Controlled foreign company rules attribute offshore company profit to Australian owners.
  • The Australian Taxation Office receives foreign account data automatically under the Common Reporting Standard.
ATO work out your residency

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