The rule changes most likely to affect cross-border planning in 2026 — Cyprus’s comprehensive tax reform, Italy raising the HNWI flat tax to €300,000, the UK replacing non-dom with the new FIG regime, and the continued global rollout of Pillar Two minimum taxation.
From the year of assessment commencing 1 July 2026, an Alternative Minimum Tax applies to companies operating in hotels, insurance, financial intermediation, real estate, and telecommunications. The 80% partial exemption on qualifying foreign-source income (effective 3% rate) for Global Business Companies remains in place subject to substance requirements.
Source: Chambers — Mauritius Corporate Tax 2026From April 2026 Paraguay offers permanent residency directly through real-estate, securities, or tourism investments of USD 200,000+, with no temporary-visa phase and no job-creation requirement. The investment must be in tangible business assets (equipment, infrastructure, real estate); operational costs do not qualify. Layers on top of the existing territorial 10% personal tax and center-of-economic-interests residency test.
Source: Lincoln Global Partners — Paraguay residency 2026From 7 March 2026, individual entrepreneurs applying for Small Business Status (the 1% turnover regime up to 500,000 GEL/year) benefit from the rate immediately upon submission to the Revenue Service rather than from the first day of the following month. Turnover thresholds (500,000 GEL standard, 700,000 GEL agritourism, 3% on excess) unchanged.
Source: ExpatHub.GE — 2026 SBS updatesFrom 1 January 2026, Law 20.446 replaced the prior 11-year blanket exemption on foreign-source income with a 10-year election that requires meeting one of: (a) 184 days/year of physical presence, (b) a real-estate investment of approximately USD 2 million, or (c) approximately USD 100,000/year contribution to a government-approved innovation fund for 11 years. Foreign-source capital and investment income for residents not using the holiday is now taxable at 12%. Applicants must not have been Uruguayan tax resident in the prior 2 years and must not have used the holiday before.
Source: IMI Daily — Uruguay tax holiday threshold updateThe legislated jump from 22% to 24% for personal income tax and corporate distributed-profits tax in 2026 was cancelled to support growth. Rates remain at 22% (22/78 for corporate distributions). VAT did rise to 24% from 1 July 2025 as part of the earlier security-tax package, but the 2% individual security tax was scrapped before taking effect.
Source: EY — Significant tax changes in Estonia 2025-2026From 1 January 2026 the Spanish Digital Nomad Visa minimum-income threshold rose to €2,849/month (225% of the 2026 SMI). Dependants add 75% SMI/adult (€949) and 25%/minor (€317). Beckham Law itself unchanged — 24% on Spanish-source employment income up to €600,000 for 6 years, with the 2023 Startup Law extension to highly-qualified DNV-route applicants.
Source: VisaHQ — Spain DNV threshold updateEffective 1 January 2026 (gazetted 31 Dec 2025), Cyprus raised the corporate income tax rate from 12.5% to 15% to align with the OECD global minimum, cut the Special Defence Contribution (SDC) on dividends to Cyprus-domiciled individuals from 17% to 5% on profits earned from 2026, abolished the Deemed Dividend Distribution provisions on 2026+ profits, and extended the tax-loss carry-forward period from 5 to 7 years. The non-dom regime (17-year SDC exemption on foreign dividends and interest) remains intact.
Source: KPMG — Cyprus tax reform enacted, effective 1 Jan 2026Italy's 2026 Budget Law (approved 30 December 2025) raised the lump-sum tax for new HNWI residents from €200,000 to €300,000 per year on foreign-sourced income, and from €25,000 to €50,000 per additional family member. The change applies only to individuals transferring tax residency after the law took effect — those who opted in earlier remain grandfathered at €100,000 (pre-Aug 2024) or €200,000 (Aug 2024 to end of 2025). 15-year maximum duration unchanged.
Source: IMI Daily — Italy raises flat tax to €300,000Many 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: IRSAfter significant pushback on the Dutch business climate, the 2024-introduced 30/20/10 phased reduction of the 30% expat ruling was reversed. The full 30% applies through 2026; from 1 January 2027 the percentage drops to a flat 27% for the remaining term of the ruling. Minimum salary thresholds raised: €48,013 for 2026 (€36,497 for under-30s with a qualifying Master's degree). Partial foreign tax liability for 30%-ruling holders ended 1 January 2025 (transitional rule for 2023 cohort runs through end of 2026).
Source: Business.gov.nl — 30% ruling compensation down to 27%The One Big Beautiful Bill Act signed 4 July 2025 made most TCJA individual provisions permanent — the seven-bracket 10-37% structure (no reversion to 39.6%), doubled standard deduction ($16,100 single / $32,200 MFJ for 2026), Section 199A QBI deduction, and the doubled estate exemption (raised to $15M/individual from 2026, indexed). SALT cap raised to ~$40,400 for 2026 (was $10k), increasing ~1%/year through 2029 before reverting to $10k in 2030. Major planning relief versus the legislated 2026 sunset.
Source: CRS — Expiring TCJA provisions (P.L. 115-97)From 6 April 2025 the UK ended the remittance basis for non-domiciled residents. Qualifying new residents (10+ prior consecutive non-resident years) can claim the new Foreign Income & Gains (FIG) regime, exempting qualifying foreign income and gains for their first 4 UK tax years. Existing non-doms can use the Temporary Repatriation Facility (TRF) to designate pre-April-2025 foreign income/gains at a 12% flat rate during 2025-26 and 2026-27, rising to 15% in 2027-28. Inheritance tax also moved to a residence-based system (long-term residents in scope on worldwide assets after 10 of last 20 UK tax years).
Source: GOV.UK — HS266 FIG regime 2026The Carney government formally cancelled the proposed increase of the capital-gains inclusion rate from 50% to 66.67% on annual gains above CAD 250,000 for individuals. The rate stays at 50% for 2026 and beyond. The Lifetime Capital Gains Exemption (LCGE) bump to CAD 1.25M on qualified small-business and farming/fishing property was kept.
Source: Canada.ca — Capital gains inclusion rate deferralDecree Law 11 of 2024 introduced a 15% Domestic Minimum Top-up Tax effective for financial years starting on or after 1 January 2025. Applies to Bahrain entities that are part of MNE groups with consolidated annual revenue ≥ €750M in at least two of the prior four years. Tops up the effective tax rate to 15% where Bahrain ETR falls short. A general 10% corporate income tax law was referred to legislative authorities in January 2026 but is not yet enacted.
Source: EY — Bahrain DMTT legislationCayman 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 AuthorityAnnounced in Budget 2019 and fully phased out as planned: the last cohort of Singapore NOR status holders saw benefits expire at the end of YA 2024. The scheme — which let qualifying foreign nationals with regional roles exempt the portion of their Singapore employment income spent working abroad — is no longer available to new entrants. The Global Investor Programme (GIP) remains as the principal high-net-worth residency route.
Source: IRAS — NOR SchemeRA 12066 (CREATE MORE Act), signed 11 November 2024, introduced a 20% Corporate Income Tax rate for Registered Business Enterprises under the Enhanced Deductions Regime on income from registered projects/activities (reduced from 25%). Alternative: 5% Special Corporate Income Tax (SCIT) on gross income. SCIT/EDR incentive durations extended to 17 or 27 years depending on impact tier. Power-expense additional deduction raised from 50% to 100%.
Source: Grant Thornton — CREATE MORE Act (RA 12066)The 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.
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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.