Tax impatriation webinar


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We are pleased to share a summary of the session, along with access to the video recording and presentation slides. Key themes Increasing global mobility, remote work, and geopolitical factors are driving cross border relocations Tax is a critical factor in choosing where to relocate, especially for executives, entrepreneurs and high net worth individuals Each jurisdiction offers different incentives, regimes and compliance requirements, making early planning essential Country highlights Switzerland Straightforward immigration for EU and EFTA citizens, more restrictive for others Progressive tax system across federal, cantonal and communal levels with overall rates around 20 to 45 percent Key advantages: Tax free capital gains on private movable assets Lump sum taxation based on expenditure for wealthy individuals No federal inheritance tax and generally favourable family exemptions Italy Highly competitive for inbound individuals through: Flat tax regime covering foreign income via a fixed annual payment (recently increased up to €300,000) Impatriate regime offering up to 50 to 60 percent exemption on employment income Designed to attract entrepreneurs, investors and professionals relocating post Brexit 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 The materials on the Eversheds Sutherland website are for general information purposes only and do not constitute legal advice. While reasonable care is taken to ensure accuracy, the materials may not reflect the most current legal developments. Eversheds Sutherland disclaims liability for actions taken based on the materials. Always consult a qualified lawyer for specific legal matters. To view the full disclaimer, see our Terms and Conditions or Disclaimer section in the footer. 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In our recent webinar on Wednesday, 3 June, we provided a high level overview of tax impatriation rules and considerations across key jurisdictions for tax professionals, private client advisers and global mobility specialists.

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

Key themes

Increasing global mobility, remote work, and geopolitical factors are driving cross border relocations
Tax is a critical factor in choosing where to relocate, especially for executives, entrepreneurs and high net worth individuals
Each jurisdiction offers different incentives, regimes and compliance requirements, making early planning essential

Country highlights

Switzerland

Straightforward immigration for EU and EFTA citizens, more restrictive for others
Progressive tax system across federal, cantonal and communal levels with overall rates around 20 to 45 percent
Key advantages:

Tax free capital gains on private movable assets
Lump sum taxation based on expenditure for wealthy individuals
No federal inheritance tax and generally favourable family exemptions

Italy

Highly competitive for inbound individuals through:

Flat tax regime covering foreign income via a fixed annual payment (recently increased up to €300,000)
Impatriate regime offering up to 50 to 60 percent exemption on employment income

Designed to attract entrepreneurs, investors and professionals relocating post Brexit

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

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

The materials on the Eversheds Sutherland website are for general information purposes only and do not constitute legal advice. While reasonable care is taken to ensure accuracy, the materials may not reflect the most current legal developments. Eversheds Sutherland disclaims liability for actions taken based on the materials. Always consult a qualified lawyer for specific legal matters. To view the full disclaimer, see our Terms and Conditions or Disclaimer section in the footer.