Tax impatriation webinar

We are pleased to share a summary of the session, along with access to the video recording and presentation slides.

Video recording

Presentation slides

Key themes

US

• Taxation based on residency status:
  • Citizens and residents taxed on worldwide income
  • Non residents taxed only on US sourced income
• Determined via green card or substantial presence tests
• Complex system with:
  • Federal, state and local taxes
  • Extensive reporting obligations
• Key planning needed before relocation to mitigate global tax exposure

UK

• Major reforms have reduced attractiveness:
  • End of the long term non dom regime
  • Introduction of a shorter four year foreign income exemption window
• Progressive tax rates up to 45 percent and capital gains up to 24 percent
• Increasingly complex system with stricter inheritance tax rules based on residence rather than domicile

Germany

• Generally regarded as a high tax jurisdiction
• Key features:
  • Progressive income tax up to 45 percent
  • Flat 25 percent tax on certain investment income
  • Strong controlled foreign company rules
• Some reliefs exist, including exemptions for long held real estate and treaty protections
• Significant inheritance and gift taxes, requiring pre relocation planning

Luxembourg

• Positioned as highly attractive for inbound talent:
  • No net wealth tax, no exit tax, and no CFC rules for individuals
• Key incentives:
  • Impatriate regime with 50 percent income exemption
  • Favourable tax treatment for investment income
  • Potential zero percent taxation on qualifying carried interest
• Widely used by asset managers and high net worth individuals

Key takeaways

• Early planning is essential before relocation to optimise tax outcomes
• Jurisdiction choice significantly impacts taxation of income, wealth and succession
• Countries are increasingly competing to attract talent through targeted tax regimes
• There is no one size fits all solution, outcomes depend on personal circumstances, income type and asset structure