Tax impatriation webinar
04. Juni 2026
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
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
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