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The Fixed Tax Loophole for Global Millionaires · IMI Podcasts

• 0:00
  SPEAKER_00: Whether you earn 500,000 euros or 50 million euros, your tax bill stays exactly the same in these four countries.
• 0:08
  SPEAKER_00: That's the promise of lump sum taxation.
• 0:11
  SPEAKER_00: These countries each offer programs that replace your entire income tax obligation with a single fixed annual payment.
• 0:18
  SPEAKER_00: In this video, we'll walk you through all four, compare costs and requirements, and show you how to take advantage starting in 2026.
• 0:26
  SPEAKER_00: But first, what even is lump sum taxation?
• 0:29
  SPEAKER_00: Most tax systems around the world are progressive.
• 0:32
  SPEAKER_00: The more you earn, the more you pay.
• 0:34
  SPEAKER_00: The higher share of your income you give to the government.
• 0:36
  SPEAKER_00: Lump sum taxation replaces that system with a fixed annual amount.
• 0:41
  SPEAKER_00: Your earnings don't matter.
• 0:43
  SPEAKER_00: For someone pulling in$2 million or more a year, the savings can be enormous.
• 0:48
  SPEAKER_00: But of course, the lump sums aren't tiny, and each country structures its program differently.
• 0:54
  SPEAKER_00: Minimum costs range from$75,000 to over a million dollars.
• 0:59
  SPEAKER_00: Switzerland.
• 1:00
  SPEAKER_00: Switzerland pioneered lump sum taxation for wealthy foreigners.
• 1:04
  SPEAKER_00: The Swiss call it the forfait fiscal, and it works differently from every other program on this list.
• 1:10
  SPEAKER_00: Rather than charging a single fixed number, Switzerland calculates your annual tax based on your spending.
• 1:16
  SPEAKER_00: The tax base equals the highest of these three measures, seven times your annual rent, three times your housing costs if you live in temporary accommodations, or the federal minimum of 434,700 Swiss francs, roughly$560,000.
• 1:34
  SPEAKER_00: Standard cantonale and federal rates then apply to that base.
• 1:38
  SPEAKER_00: In practice, minimum annual tax bills land between$250,000 and 1,000 Swiss francs, depending on where you live.
• 1:46
  SPEAKER_00: The first question one might ask about this Swiss setup is about the cantons.
• 1:51
  SPEAKER_00: Geneva hosts one quarter of all lump sum tax residents and draws the largest share of new applicants.
• 1:58
  SPEAKER_00: Valais follows at 12%, Ticino at 11%, and Vaux at 9%.
• 2:03
  SPEAKER_00: Obwalden offers the lowest entry point at around 250,000 francs per year.
• 2:09
  SPEAKER_00: Zoog, on the other hand, demands a million.
• 2:12
  SPEAKER_00: And not every canton participates.
• 2:14
  SPEAKER_00: Zurich abolished the program in 2010 after a public referendum, and Basil followed two years later.
• 2:20
  SPEAKER_00: To qualify, you need to meet these requirements.
• 2:23
  SPEAKER_00: You must hold foreign citizenship.
• 2:25
  SPEAKER_00: You must take up Swiss residence for the first time or be returning after at least 10 years abroad.
• 2:31
  SPEAKER_00: And finally, you cannot work in Switzerland.
• 2:34
  SPEAKER_00: Any employment or business activity on Swiss soil disqualifies you immediately.
• 2:39
  SPEAKER_00: As of March 2025, 496 non-EU nationals held Swiss lump sum tax residence permits, a 22% increase from the prior year.
• 2:50
  SPEAKER_00: Russians make up the largest group at 20%, followed by Chinese and British nationals at 10% each and Americans at 8%.
• 2:58
  SPEAKER_00: The cost of entry put Switzerland firmly in ultra-high net worth territory.
• 3:03
  SPEAKER_00: But in return you get Swiss stability, infrastructure, and top-notch lifestyle.
• 3:08
  SPEAKER_00: Now to Italy.
• 3:09
  SPEAKER_00: Italy launched its lump sum tax in 2017, and it quickly became one of Europe's most popular options for relocating millionaires.
• 3:18
  SPEAKER_00: You pay a flat annual substitute tax on all foreign sourced income, and the structure is simpler than Switzerland's.
• 3:24
  SPEAKER_00: But the price has climbed considerably.
• 3:26
  SPEAKER_00: Italy originally set the flat tax at 100,000 euros per year.
• 3:31
  SPEAKER_00: In August 2024, it doubled to€200,000.
• 3:35
  SPEAKER_00: Then in December 2025, with the approval of the budget law, it rose again to€300,000.
• 3:42
  SPEAKER_00: Family members can join for€50,000 per person, up from 25,000 euros under the same reform.
• 3:50
  SPEAKER_00: Italy has consistently applied grandfathering provisions with each increase.
• 3:54
  SPEAKER_00: So if you transferred your tax residence before a rate hike took effect, you keep paying the old rate for the full 15-year duration.
• 4:01
  SPEAKER_00: That means those who moved before August 2024 still pay€100,000.
• 4:07
  SPEAKER_00: Only new applicants from January 2026 onward face€300,000.
• 4:13
  SPEAKER_00: But this could mean major savings compared to what future applicants owe.
• 4:17
  SPEAKER_00: To qualify, you must not have been an Italian tax resident for at least nine of the previous 10 years.
• 4:24
  SPEAKER_00: Any nationality can apply, including Italian citizens returning from extended periods abroad.
• 4:30
  SPEAKER_00: The program covers dividends, capital gains, interest, rental income, and pensions all from outside Italy.
• 4:37
  SPEAKER_00: Income earned within Italy falls outside the flat tax and faces standard progressive rates up to 43%.
• 4:44
  SPEAKER_00: Beyond income tax, participants are exempt from Italian wealth taxes on foreign real estate, and financial assets face no reporting obligations on overseas holdings and owe no gift or inheritance tax on foreign asset transfers.
• 4:59
  SPEAKER_00: For families engaged in intergenerational wealth planning, all those exemptions can prove more valuable than the income tax savings alone.
• 5:07
  SPEAKER_00: The program works best when nearly all your income originates abroad.
• 5:11
  SPEAKER_00: Of€300,000 per year, the math favors individuals or families earning roughly 1.5 million euros or more from foreign sources.
• 5:21
  SPEAKER_00: Below that, standard Italian taxation might cost less.
• 5:25
  SPEAKER_00: Greece.
• 5:25
  SPEAKER_00: Greece has taken a different approach with its non-DOM regime for investors and attracted such celebrities as Novak Djokovic in 2025.
• 5:35
  SPEAKER_00: The annual flat tax is€100,000 on all foreign sourced income, the lowest among the European options, running for up to 15 years.
• 5:44
  SPEAKER_00: Family members can participate for an additional€20,000 per adult per year, and everyone included is exempt from Greek inheritance and gift taxes on foreign assets.
• 5:56
  SPEAKER_00: The trade-off is the entry requirement.
• 5:58
  SPEAKER_00: You need to make a minimum€500,000 investment in Greek assets like real estate, businesses, securities, or shares of Greek companies.
• 6:07
  SPEAKER_00: The annual tax is considerably lower than Italy's, but the upfront capital commitment is obviously higher.
• 6:13
  SPEAKER_00: You must not have been a Greek tax resident for seven of the eight years before your relocation, and you need to transfer your tax residence from a country with a tax treaty or administrative cooperation agreement within Greece.
• 6:27
  SPEAKER_00: For someone with substantial foreign income who also wants to deploy capital into Greek real estate or businesses, perhaps the Greece Golden Visa, which requires at least 400,000 euros in residential property outside of tourist areas and 800,000 euros anywhere in the country, this program pairs annual tax certainty with an investment position in a growing European market.
• 6:50
  SPEAKER_00: Anguilla.
• 6:51
  SPEAKER_00: Finally, Anguilla offers the most straightforward structure on this list.
• 6:55
  SPEAKER_00: Pay$75,000 annually on worldwide income, invest at least$400,000 in Anguilan real estate, and spend 45 days per year on the island.
• 7:06
  SPEAKER_00: Boom, that's it.
• 7:08
  SPEAKER_00: The high value resident program comes with one condition.
• 7:11
  SPEAKER_00: You cannot spend more than 183 days in any other single jurisdiction.
• 7:16
  SPEAKER_00: This prevents you from establishing tax residence elsewhere while maintaining Anguilla's favorable treatment.
• 7:22
  SPEAKER_00: Meet those terms, and Anguilla imposes no income tax, corporate tax, capital gains tax, or inheritance tax beyond the annual$75,000 payment.
• 7:33
  SPEAKER_00: At the lowest annual cost on this list and with minimal physical presence requirements, Anguilla appeals to genuinely mobile individuals who don't want to anchor themselves in one place.
• 7:44
  SPEAKER_00: So how do you choose between these programs?
• 7:47
  SPEAKER_00: What makes each unique?
• 7:48
  SPEAKER_00: Switzerland costs between$250,000 and$1 million per year, requires no investment, and targets ultra-high net worth passive income earners who value Swiss lifestyle and predictability.
• 8:01
  SPEAKER_00: Italy costs 300,000 euros per year for new applicants, requires no investment, and covers the widest range of tax exemptions, including wealth, inheritance, and gift taxes on foreign assets.
• 8:14
  SPEAKER_00: It works best for families earning over 1.5 million euros from abroad.
• 8:18
  SPEAKER_00: Greece's lump sum tax costs€100,000 per year, but requires a€500,000 investment in Greek assets as well.
• 8:27
  SPEAKER_00: It's the most affordable annual option in Europe for investors comfortable deploying capital there.
• 8:32
  SPEAKER_00: Anguilla's lump sum tax regime costs$75,000 per year plus a$400,000 real estate investment, demands only 45 days of presence and suits highly mobile individuals who want flexibility.
• 8:46
  SPEAKER_00: Keep in mind that governments can change these programs at any time.
• 8:50
  SPEAKER_00: For instance, Italy has raised its flat tax twice in two years, and multiple cantons in Switzerland have eliminated the option through public referendums.
• 8:59
  SPEAKER_00: On imidaly.com, you can find qualified tax advisors and immigration experts who can help you understand the financial and legal implications of a potential move to one of these destinations.
• 9:11
  SPEAKER_00: If you'd like a more thorough deep dive on Europe and the potentially single-digit tax regimes that surprise most investors there, tap on the video on your screen now.
• 9:21
  SPEAKER_00: You won't regret it.