The rule changes most likely to affect cross-border planning in 2026 — regime replacements (Portugal NHR, UK non-dom), Pillar Two implementations, and jurisdiction-specific reforms in UAE, Thailand, Italy, and others.
Many individual provisions of the 2017 Tax Cuts and Jobs Act (reduced brackets, higher standard deduction, increased estate exemption, QBI deduction) sunset at the end of 2025 absent congressional action. Watch 2025/2026 legislation closely — extensions or modifications likely but not guaranteed.
Source: IRSFrom 6 April 2025 the UK ended the remittance-basis tax regime for non-domiciled residents. New arrivals can use a 4-year exemption on foreign income; longer-term residents transition to worldwide taxation. Existing non-doms have transitional relief for 2025–2028.
Source: HMRC — Changes to taxation of non-UK domiciled individualsCayman introduced a Qualified Domestic Minimum Top-up Tax of 15% applicable to in-scope multinationals (consolidated revenues ≥€750M) effective 1 January 2025. Smaller entities and individuals remain in the 0% regime.
Source: Cayman Islands Tax Information AuthorityThe BVI implemented a 15% QDMTT for large multinationals from 1 January 2025. Designed to keep top-up tax revenue in the BVI rather than ceding it to other jurisdictions under Pillar Two. Does not affect individuals or smaller entities.
Source: BVI Government — International Tax AuthorityThe Italian flat tax for new high-net-worth residents (formerly €100k per year on foreign income) doubled to €200,000 for individuals taking up residency from 11 August 2024 onward. Pre-existing electors stay at €100,000.
Source: Agenzia delle EntrateThe original NHR regime closed to new applicants at end of 2023 (transitional acceptance through March 2025). The replacement — Incentivo Fiscal à Investigação Científica e Inovação (IFICI / NHR 2.0) — narrows eligibility to qualifying scientific, technology, and innovation roles, retaining 20% on Portuguese-source professional income for 10 years.
Source: Portuguese Tax AuthorityPillar Two (GloBE rules) imposes a 15% effective minimum tax on multinationals with consolidated revenues ≥€750M. EU members, UK, Australia, Canada, Korea, Japan, and most major economies implemented during 2024. SMEs and most founders are unaffected; targets are large MNEs.
Source: OECD — Pillar TwoFrom 1 January 2024 Thailand began taxing foreign-source income remitted into Thailand by tax residents in the year that income was earned (previously only income remitted in the same tax year was caught — a loophole many expats relied on). LTR visa holders retain exemption on foreign income.
Source: Thai Revenue DepartmentGreece's 7% flat-rate regime for foreign pensioners (originally introduced 2019) was extended and clarified. Available to foreign retirees who haven't been tax resident in Greece in 5 of the previous 6 years, for 15 years from election. Specific residence and reporting requirements apply.
Source: Greek Independent Authority for Public RevenueSpain's special regime for inbound workers ("Beckham Law", 24% flat on Spanish-source income up to €600k) was expanded to include certain remote workers, entrepreneurs, and qualifying digital-nomad-visa holders from 2023. Significant change for foreign workers relocating to Spain.
Source: Agencia TributariaThe Federal Ministry of Finance reconfirmed that crypto held over 1 year by individuals is exempt from German capital gains tax. Shorter holds are taxed at progressive rates up to 45% plus solidarity surcharge.
Source: Bundesministerium der FinanzenUAE corporate tax of 9% on taxable income above AED 375,000 took effect for financial years starting on/after 1 June 2023. Personal income tax remains 0%. Qualifying free-zone activities can still access 0% with substance requirements. Large MNEs subject to 15% Pillar Two top-up from 2025.
Source: UAE Federal Tax AuthorityOne email per quarter, max — only when a tracked jurisdiction materially changes its rules. Plus the 2026 cheat sheet.
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TaxAtlas covers the rates and rules. For the personal side — exit planning, residency strategy, business structure, or filings — request a response and we'll point you to relevant research or a vetted specialist.
TaxAtlas is research — not tax or legal advice. The summaries above are condensed for readability; consult primary sources and a qualified professional before relying on any item for planning decisions.