Most international-tax coverage of 2026 focuses on three or four headline changes: the UK ending its non-dom regime in April 2025, Italy raising its HNWI flat tax from €100,000 to €200,000 and then to €300,000, Portugal closing NHR to new applicants in 2024, and the global Pillar Two minimum tax rolling out. These are real and matter, but they are not the whole picture.
Several genuinely material 2026 tax changes have been under-covered relative to their planning impact. Some of them — like the US TCJA sunset that didn’t happen and Canada’s cancelled capital-gains hike — are stories about what didn’t change, which is often the bigger planning fact than what did. Others — like Uruguay’s Law 20.446, Bahrain’s DMTT, and Mauritius’s new sectoral AMT — represent quieter but structural shifts in jurisdictions where the regime used to be the entire appeal.
This piece walks through each one with citations and explains why each matters for real planning decisions. All figures verified June 2026 against PwC, KPMG, EY, government tax authorities, and the TaxAtlas dataset. Verify with a qualified tax adviser before acting.
1. Uruguay Law 20.446: 11-year holiday turned into a tougher 10-year election
Uruguay’s tax-holiday regime for new residents was one of the most generous in Latin America for over a decade. New tax residents could elect an 11-year exemption on all foreign-source income — passive, active, capital gains — with no qualifying-investment or physical-presence requirement beyond ordinary tax-residence rules.
That changed materially on 1 January 2026 under Law N° 20.446. The 11-year blanket exemption was replaced with a 10-year election that requires meeting one of:
- Physical presence: 184 days per calendar year in Uruguay, OR
- Real-estate investment: approximately USD 2 million in qualifying Uruguayan real estate, OR
- Innovation fund: approximately USD 100,000 per year for 11 years to a government-approved innovation fund.
Additional eligibility requirements: applicants must not have been Uruguayan tax residents in the prior 2 years, and must not have previously benefited from the holiday regime.
For tax residents who do not use the holiday election, foreign-source capital and investment income (dividends, interest, foreign rentals, foreign capital gains) is now taxable at 12% from 2026 onward.
Why it matters: Uruguay was the standard recommendation for Latin-America-curious HNWIs who didn’t want the friction of Panama or Paraguay. The new requirements are still navigable, but the "no qualifying investment, no presence test" appeal is gone. For someone with USD 2M of investible capital and a willingness to put it into Uruguayan property, the regime is still attractive. For someone with passive income but no interest in physical relocation, the path is much narrower.
See the full Uruguay tax guide.
2. The TCJA sunset that didn’t happen (OBBBA, July 2025)
For several years, the international-tax conversation has included an assumption that the US would face a 2026 cliff: the Tax Cuts and Jobs Act (TCJA) individual provisions were scheduled to sunset at the end of 2025, returning top marginal rates from 37% to 39.6%, halving the standard deduction, slashing the estate exemption back to roughly $7M per person, and eliminating Section 199A QBI for pass-through business owners.
None of that happened.
The One Big Beautiful Bill Act (OBBBA) was signed on 4 July 2025 and made most TCJA individual provisions permanent. Specifically:
- Brackets: 10/12/22/24/32/35/37% structure preserved; no return to 39.6%.
- Standard deduction: doubled framework preserved (2026: $16,100 single / $32,200 MFJ).
- Section 199A QBI deduction: 20% pass-through deduction made permanent.
- Estate exemption: raised to $15M per individual ($30M per couple) from 2026, indexed thereafter, rather than reverting to ~$7M.
- SALT cap: raised to approximately $40,400 for 2026, increasing about 1%/year through 2029, then reverting to $10,000 in 2030.
Why it matters: Several years of pre-emptive planning was based on the assumption that 2026 would be a high-tax cliff. Many people accelerated gains into 2024–2025 to lock in TCJA-era rates, executed large gifts before the estate exemption supposedly halved, and structured deferred-comp accelerations into earlier years. Most of that activity is now unnecessary in retrospect — though the SALT cap reverting in 2030 means there is still a planning horizon at the back end. For US citizens considering moves abroad, the post-OBBBA picture is materially less punishing than the 2024 expected state.
See the US citizen’s complete moving-abroad guide for the full post-OBBBA playbook.
3. Canada cancels the capital-gains inclusion-rate hike
The Trudeau government’s 2024 budget proposed raising the Canadian capital-gains inclusion rate from 50% to 66.67% on annual gains above CAD 250,000 for individuals (and on all gains for corporations and most trusts). Effective date: 25 June 2024, with retroactive application for transactions earlier in the year.
The proposal was politically divisive, immediately challenged on retroactivity grounds, and ultimately deferred to 2026. Then, in March 2025, the Carney government — having taken power earlier that year — formally cancelled the increase entirely. The capital-gains inclusion rate stays at 50%.
One piece of the original 2024 proposal was kept: the Lifetime Capital Gains Exemption (LCGE) bump from CAD 1.016M to CAD 1.25M on qualified small-business corporation shares and qualified farming/fishing property.
Why it matters: Many Canadian business sellers, family-business succession plans, and large-portfolio realizations had been timed against an assumed 2026 cliff. Those who accelerated sales in 2024 to lock in the 50% inclusion rate did so unnecessarily in retrospect. Those who deferred sales or restructured for the assumed-higher-rate future now have planning flexibility back. For Canadians considering relocation for tax reasons, the marginal benefit of leaving Canada is meaningfully lower than the 2024 expectation.
See the full Canada tax guide.
4. Bahrain becomes the first GCC country to legislate Pillar Two
Bahrain enacted a 15% Domestic Minimum Top-up Tax (DMTT) effective for financial years starting on or after 1 January 2025, under Decree Law 11/2024. The DMTT applies to Bahrain entities that are part of MNE groups with consolidated annual revenue ≥ €750 million.
This is the first GCC country to legislate Pillar Two. The UAE’s broader CIT regime (9% headline, 0% Free Zone for qualifying activities, 15% DMTT for in-scope MNEs from 2025) gets more press, but Bahrain’s move is notable precisely because Bahrain had been a pure-zero-tax jurisdiction for non-oil business until the DMTT.
A separate development worth tracking: in January 2026, Bahrain referred draft legislation for a general 10% corporate income tax to legislative authorities. If enacted, this would make Bahrain the second GCC country (after the UAE’s 9% rate in 2023) to introduce general CIT outside the oil sector. As of mid-2026 the bill is still under consideration.
Why it matters: Bahrain has historically been a quiet alternative to Dubai for regional headquarters — smaller market, lower cost base, English-language jurisdiction. The DMTT closes the headline-rate gap for large MNEs. A general 10% CIT would close it for everyone else. Founders evaluating Bahrain as a UAE alternative need to plan on the new tax reality, not the pre-2025 picture.
See the full Bahrain tax guide and the Pillar Two implementation tracker.
5. Singapore’s Not Ordinarily Resident (NOR) scheme officially ended
Announced in Singapore’s 2019 Budget but with a long phase-out tail: the Not Ordinarily Resident (NOR) scheme’s last cohort had its final year of benefits in YA 2024. The scheme is now fully closed; no new entrants and no further benefits.
NOR was the closest Singapore equivalent to a non-dom regime. It let qualifying foreign nationals with regional roles exempt the portion of their Singapore employment income spent working abroad. For executives splitting time between Singapore and other regional markets, NOR could materially reduce Singapore tax exposure during the first five years of residency.
The scheme’s closure is not new news, but the practical impact only fully landed in mid-2026 as the last cohort came off. The Singapore guide has been updated; the Global Investor Programme (GIP) remains as the principal high-net-worth residency route.
Why it matters: Anyone evaluating Singapore as a regional base in 2026 should not factor in NOR — it’s gone. The standard 0–24% progressive personal income tax applies fully. Singapore’s competitiveness as a base for senior regional executives is materially lower than it was during the NOR window. For tax-driven moves, Dubai (UAE) and Hong Kong are now the more permissive Asian / Middle Eastern alternatives.
6. Mauritius introduces Alternative Minimum Tax on selected sectors
Mauritius is best known internationally for the 80% partial exemption regime — a Global Business Company qualifying for the exemption pays an effective rate of 3% (15% headline × 20% taxable base) on qualifying foreign-source income (foreign dividends, interest, IP royalties, capital gains on foreign participations), subject to economic-substance requirements.
From the year of assessment commencing 1 July 2026, Mauritius introduced an Alternative Minimum Tax (AMT) applicable to companies operating in five sectors:
- Hotels and tourism
- Insurance
- Financial intermediation
- Real estate
- Telecommunications
The AMT ensures these sectors pay a minimum tax level regardless of deductions or exemptions. The 80% partial exemption regime for Global Business Companies in non-AMT sectors remains in place — substance-compliant GBCs continue to benefit from the effective 3% rate on qualifying foreign-source income.
Why it matters: Mauritius has been a steady incorporation choice for African-focused and Asian-focused investment funds, holding companies, and tech businesses. The sectoral AMT does not affect those use cases. But Mauritius’s broader regulatory direction is toward narrowing the historical zero-effective-rate options, even outside the Pillar Two perimeter. Plan for continued tightening in subsequent years.
See the full Mauritius tax guide.
7. Estonia cancels its planned 24% rate hike
Estonia’s legislated tax-rate package for 2026 included raising personal income tax from 22% to 24% and the corporate distributed-profits tax (the famous Estonian model where retained earnings aren’t taxed) from 22% to 24%. As of late 2025, that increase was cancelled to support economic growth. Rates remain at 22% (the corporate distribution rate effective is 22/78 = 28.2%).
One earlier piece of the package did happen: VAT rose to 24% from 1 July 2025 (from 22%) as part of the original security-tax legislation. The associated 2% individual security tax — a separate planned levy on individuals to fund defence spending — was scrapped before taking effect.
Why it matters: Estonia’s combination of low personal income tax (22%), distributed-profits-only corporate tax (you don’t pay anything on retained earnings), and the e-Residency programme make it a destination for small, lean digital-first businesses. The cancellation of the 24% hike keeps the proposition exactly as before — a meaningful relief for founders who had factored in the higher rate when modelling 2026+ cash flows.
See the full Estonia tax guide.
8. Spain raises the Digital Nomad Visa income threshold
Spain’s Digital Nomad Visa (DNV) was introduced in 2023 as part of the Startup Law. It allows qualifying remote workers to obtain Spanish residency, and crucially, opens a path to the Beckham Law special tax regime (24% flat on Spanish-source employment income up to €600,000 for 6 years).
From 1 January 2026, the DNV minimum-income threshold rose to €2,849 per month — equivalent to 225% of the 2026 Spanish minimum wage (SMI). Dependants add 75% SMI per adult (€949) and 25% SMI per minor (€317).
The Beckham Law itself was not changed. The 24% flat / 47% above €600,000 / 6-year structure / 2023 Startup Law extension to qualifying entrepreneurs and highly-qualified DNV-route applicants all remain in place.
Why it matters: Spain DNV is still one of the most attractive EU paths for remote workers wanting genuine residency rather than tourist-stay rotations. The threshold raise is meaningful but not disqualifying — most location-independent professionals earning above ~USD 35,000/year qualify. For applicants in lower-earning specialisations or supporting family members, the new thresholds need to be planned around.
See the full Spain tax guide.
9. Paraguay launches direct-to-permanent-residency Investor Pass
Paraguay had long been a "quiet" residency destination — its territorial 10% personal tax, no general wealth tax, no inheritance tax, and center-of-economic-interests residency test (no strict day-count) made it attractive for HNWIs who wanted a Latin-American tax base without the friction of full physical relocation. The standard route was a 2-stage temporary-then-permanent residency programme.
From April 2026, Paraguay added a direct-to-permanent Investor Pass:
- Direct permanent residency, no temporary-visa phase.
- Investment threshold: USD 200,000+.
- Qualifying investments: real estate, securities, or tourism investments. Must be tangible business assets (equipment, infrastructure, real estate). Operational costs do not count.
- No job-creation requirement.
Why it matters: Paraguay’s appeal has always been the combination of low tax + light residency requirements + Mercosur access. The Investor Pass removes the multi-stage application friction that previously required at least one extended in-country visit. For HNWIs evaluating "diversified-citizenship" residency portfolios, Paraguay just became materially easier.
See the full Paraguay tax guide.
10. Georgia’s Small Business Status (1%) becomes effective on submission date
Georgia’s Small Business Status (SBS) is one of the most attractive freelancer / individual-entrepreneur regimes globally: 1% income tax on turnover up to 500,000 GEL/year (~USD 180,000), 3% on excess. The 1% rate functions like a very low gross-receipts tax — no need to track expenses, deductions, or quarterly estimated payments.
The administrative change in March 2026: SBS now becomes effective on the date the request is submitted to the Revenue Service, rather than the first day of the following month. This may sound minor, but the prior "first-of-next-month" rule meant new entrepreneurs starting work in mid-month had a guaranteed period of 20% (standard) personal income tax before the 1% rate kicked in.
Why it matters: For freelancers and consultants relocating to Georgia mid-year, the new rule eliminates the awkward fractional-month overhang. Combined with Georgia’s ongoing visa-friendly approach (1-year visa-free for most passports), low cost of living, and territorial foreign-income exemption, Georgia is one of the strongest digital-nomad+SBS combinations available globally.
See the full Georgia tax guide.
11. Netherlands reverses the 30/20/10 expat-scheme scaleback
The Dutch 30% ruling — which lets qualifying inbound skilled workers receive up to 30% of their gross salary tax-free for up to 5 years — went through a Kafkaesque legislative roundtrip in 2024–2025.
The 2024 Budget initially proposed scaling the ruling down to a 30/20/10% phased reduction (30% for years 1–2, 20% for years 3–4, 10% for year 5). This was passed into law. After significant pushback on the Dutch business climate, the scaleback was reversed in the 2025 legislative cycle: the 30% remains in place through 2026, then drops to a flat 27% from 1 January 2027 for the remaining term of any active ruling.
Two related tightenings did stick:
- Minimum salary thresholds raised: €48,013 for 2026 (€36,497 for under-30s with a qualifying Master’s degree).
- Partial foreign tax liability abolished for 30%-ruling holders from 1 January 2025. (Transitional rule for the 2023-grant cohort runs through end of 2026.)
Why it matters: The Netherlands is still attractive for high-earning expats arriving for finance, tech, and biotech roles. The 30% (now 27% from 2027) effectively reduces the top marginal rate from ~49.5% to ~35%, making the Netherlands competitive with mid-range tax jurisdictions for the 5-year window. Anyone planning a move to Amsterdam or Eindhoven for a senior role should plan on the post-reversal 30%/27% reality, not the dead-on-arrival 30/20/10 framework.
See the full Netherlands tax guide.
The unifying theme: stabilization versus tightening
What ties these eleven changes together is not a single trend — they pull in different directions. Some jurisdictions tightened (Uruguay, Singapore NOR closure, Bahrain DMTT, Mauritius AMT). Others stabilized after threatened changes (US OBBBA, Canada CG, Estonia 24% cancellation, Netherlands 30% reversal). One added flexibility (Paraguay Investor Pass).
The honest summary: 2026 was a year of regime crystallization. Most planning conversations in 2022–2024 were dominated by "what will change," with uncertainty around US TCJA, Canada CG, EU Pillar Two transposition, Dutch 30%, and various GCC corporate-tax proposals. By mid-2026, most of those are settled. Some changes happened, some didn’t, but the picture is now clear enough to plan against.
Practical implications by reader type:
- US-citizen HNWIs: OBBBA is the biggest non-event of the decade. Most pre-2026 acceleration planning was unnecessary in retrospect; current-state planning is more relevant. Estate exemption at $15M/individual gives meaningful gifting headroom. SALT cap reverting to $10k in 2030 is the remaining cliff to plan around.
- Founder considering Singapore vs Dubai vs Hong Kong: NOR closure makes Singapore meaningfully less appealing for senior executives splitting regional time. Dubai (UAE) is the better choice on tax, Hong Kong on cost. Pillar Two now applies to all three for MNE-scale groups — pick on substance and treaty network.
- Digital nomad seeking residency: Spain DNV threshold raise is the only material change. Georgia SBS continues to be the strongest tax outcome for sub-USD-180K turnovers. Portugal IFICI is restricted to scientific research; most nomads won’t qualify.
- HNW considering Latin America: Uruguay tightened materially. Paraguay added direct-to-permanent residency. Panama’s Friendly Nations Visa remains the most flexible mid-tier option. Mexico RESICO continues at the MXN 3.5M threshold.
- Canadian considering relocation for tax: The biggest motivator (the 66.67% inclusion rate) is gone. For those still considering Portugal, the post-NHR-closure IFICI regime is much narrower; Cyprus may be the better EU base now (see the Cyprus 2026 reform deep dive).
- Dutch-bound skilled worker: Plan on 30% through 2026, then 27% from 2027 for the remaining term. Don’t plan on the 30/20/10 framework that was reversed.
What to watch in late 2026 and 2027
Several stories are mid-flight as of June 2026 that will matter in coming planning cycles:
- Bahrain general 10% CIT: draft legislation referred Jan 2026; not yet enacted. If passed, Bahrain becomes the second GCC country with general CIT.
- Hong Kong Pillar Two finalization: announced QDMTT and IIR effective 1 Jan 2025 but legislative passage still in progress.
- EU ATAD 3 (anti-shell-company directive): in final negotiation. Will affect Malta / Cyprus / Luxembourg holding-company structures.
- CARF (Crypto-Asset Reporting Framework): phased global rollout for crypto reporting parallel to CRS for traditional financial accounts.
- Mauritius next-phase reform: AMT was the first 2026 piece; broader corporate-tax restructuring under consultation.
- Singapore Pillar Two UTPR: QDMTT and IIR effective 2025, UTPR consultation pending — likely 2026 or 2027.
The TaxAtlas 2026 tax changes feed tracks each of these as they evolve. The Pillar Two implementation tracker covers the corporate-side rollout in detail.
Bottom line
The 2026 international tax landscape is dominated by what changed (Italy €300k, UK FIG, Cyprus reform, Bahrain DMTT) and by what almost-but-didn’t change (US TCJA, Canada CG, Estonia 24%, Netherlands 30/20/10). Both stories matter for planning.
If your tax planning for 2026 still rests on assumptions from 2022 or 2023, much of it is likely wrong by now — sometimes more permissive than expected, sometimes meaningfully tighter. Verify against current law before acting; the cost of getting it wrong on a relocation or restructuring move is high.
For situation-specific guidance — Uruguay holiday-vs-investment route comparison, Bahrain DMTT exposure analysis, US OBBBA gift-and-estate replanning, Cyprus vs Italy vs UK FIG modelling — request a response and TaxAtlas will point to relevant research or refer to a specialist.