Is there an advantageous tax regime for individuals who have recently arrived in or are only partially connected with the jurisdiction?
Individuals who have recently transferred their tax residence in France benefit from a five-year exemption of ISF on assets located abroad (up to January 1st 2017) and of IFI (as from January 1st 2018) on real estate properties located abroad.
They also benefit from an exemption of gift tax on gifts they receive during the first six years of their residence in France.
Finally exit tax is not due when new resident individuals transfer their tax residence abroad less than six years after their arrival.
1. Forfait tax regime
Individuals that have been non-resident of Italy in at least 9 of the last 10 years can move to Italy and opt for the forfait tax regime, which provides that:
i. All foreign-source income and gains are subject to a substitute tax equal to 100,000 Euro per year;
ii. Foreign assets are not subject to wealth taxes;
iii. Foreign assets are not subject to inheritance and gift tax;
iv. Foreign assets are not subject to reporting obligations;
v. As an exception, foreign-source capital gains on substantial shareholdings realized in the first 5 years of Italian tax residence are subject to income tax according to general rules. As a consequence, during such 5-year period, substantial shareholdings are subject to reporting obligations.
The option for the substitute tax regime is effective up to a maximum period of 15 years. The option can be revoked by the individual, but, if revoked, is no longer available.
2. Impatriate tax regime
The impatriate regime provides, under specific conditions, for a 50% exemption from income tax for Italian-source income from employment and self-employment for the first year of Italian tax residence and the subsequent four tax years.
New Immigrants and Veteran Returning Residents (individuals who have returned to Israel after being foreign residents for at least 10 years) are entitled to a 10-year tax exemption on their foreign sourced income (passive income and capital gains arising from the transfer of assets located outside of Israel) and certain foreign earned income (such as employment and business income), while residents returning to Israel after having lived at least 6 years and less than 10 years abroad, may also be eligible to a 5-year tax exemption on certain foreign source income and capital gains on their assets located outside of Israel.
Individuals that are tax residents in a foreign jurisdiction are not subject to taxable presumed living expenses, provided certain criteria apply.
There are no special tax rules for arrivers.
Foreign executives, specialised foreign staff or foreign research staff that are appointed to work temporarily in Belgium can apply for a special expatriate tax regime. Eligible persons must prove that they perform activities which require a special knowledge and responsibility, thus executive functions. If approved, they are treated as non-residents and are therefore only taxable on their Belgian source income. The benefits are two-fold: (i) certain expatriate allowances or reimbursements of expenses and (ii) the so-called 'foreign business travel exclusion' are excluded from the taxable basis.
British Virgin Islands
The BVI is a low tax jurisdiction and this applies across the board. The tax advantages are set out in the answers to questions 2 to 5 above.
The transitional resident exemption which enables persons who become resident in New Zealand to receive the majority of their overseas sourced income tax-free for 48 months from the date they become tax resident. In most cases, this will enable domestic and overseas planning and structuring to take place over this transitional period. Care must be taken to ensure that overseas structures, such as trusts, that could be taxable in New Zealand on an individual becoming fully tax resident are not used.
The New Zealand transitional residence rules are available to New Zealand residents who have been absent from New Zealand for ten years. The rules do not apply to income derived from active business activities in New Zealand and provision of services overseas.