Expat Compass ยท Tax Reference

Destination Tax Comparison Guide

17 popular expat destinations: income tax rates, territorial/worldwide rules, UK DTA status and residency visa thresholds.

๐Ÿ“„ 5 pages ยท reference guide ๐Ÿ—“๏ธ Updated January 2025 ๐ŸŒ 17 countries โš ๏ธ Educational only โ€” always verify current rules
17
Countries covered
10
Have UK DTA
7
Territorial tax (0% on foreign income)
3
Flat-rate tax regimes

1. Key Concepts You Need to Know

๐ŸŒ Territorial taxation

Only income sourced in that country is taxed. Foreign income (e.g. your UK pension, rental, dividends) is tax-free locally. Examples: Panama, Malaysia, Costa Rica, Singapore.

๐ŸŒ Worldwide taxation

All your income, wherever it arises, is taxed by your new country of residence. UK pension and rental income would be taxed locally (though DTA relief may apply). Examples: France, Germany, Australia.

๐Ÿ“„ Double Taxation Agreement (DTA)

A treaty between the UK and destination country that prevents double-taxation. May give exclusive taxing rights on certain income to one country only. Always check the specific DTA article for each income type.

DTA priority: When UK and destination both want to tax the same income, the DTA decides who gets priority. Many DTAs give the UK the exclusive right to tax UK Government Service pensions (e.g. NHS, Civil Service, military). State Pension is often taxable in both countries, with relief via foreign tax credit.

2. Country-by-Country Tax Summary

Country Tax system Income tax rates UK DTA? Residency visa threshold Key notes for UK expats
๐Ÿ‡ต๐Ÿ‡นPortugal Worldwide 14.5โ€“48%
(NHR: flat 20% for qual. income)
Yes D7 passive income visa: โ‚ฌ820/mo minimum. NHR2.0: โ‚ฌ760/mo NHR (Non-Habitual Resident) regime: 10-year tax benefit. UK State Pension may be taxed in UK only under DTA Art.17. UK Govt. pension: exclusively UK-taxed. Popular retirement destination.
๐Ÿ‡ช๐Ÿ‡ธSpain Worldwide 19โ€“47% progressive
(Beckham Law: flat 24% for workers)
Yes Non-lucrative visa: โ‚ฌ2,400/mo; Digital Nomad: โ‚ฌ2,646/mo Spain taxes worldwide income. UK pension taxable in Spain (with UK credit). Wealth tax applies in some regions. "Modelo 720" foreign asset declaration โ€” โ‚ฌ600k threshold (reduced). Costa del Sol popular for retirees.
๐Ÿ‡ซ๐Ÿ‡ทFrance Worldwide 0โ€“45% + social charges (7.5โ€“17.2%) Yes Passive income visa: no fixed minimum; demonstrate self-sufficiency High social charges apply. UK DTA: State Pension taxable in UK only; occupational pension taxable in France. Healthcare via CPAM after 3 months. No specific retirement visa โ€” use long-stay visa.
๐Ÿ‡ฉ๐Ÿ‡ชGermany Worldwide 14โ€“45% + solidarity surcharge (5.5%) Yes Freizรผgigkeit (EU nationals). Non-EU: substantial income demonstration needed High tax jurisdiction. UK pension generally taxed in Germany under DTA. Strong healthcare system. Not typically chosen for tax efficiency.
๐Ÿ‡ฎ๐Ÿ‡นItaly Worldwide 23โ€“43%
(Pensionati: flat 7% in certain south regions)
Yes Elective residence visa: โ‚ฌ31,000/yr min. or โ‚ฌ103,000 for non-EU Southern Italy (Sicily, Calabria, Sardinia) offers flat 7% tax for foreign-source pension income for 10 years if you settle in a village under 20,000. Bureaucracy can be complex.
๐Ÿ‡ฌ๐Ÿ‡ทGreece Worldwide 9โ€“44%
(Retiree regime: flat 7%)
Yes Digital Nomad Visa: โ‚ฌ3,500/mo. Pension transfer: โ‚ฌ1,000/mo+ 7% flat tax for foreign retirees transferring pension income to Greece โ€” 10-year regime. Attractive for UK pensioners. Golden Visa investment route also available.
๐Ÿ‡จ๐Ÿ‡พCyprus Worldwide 0โ€“35%
(Non-dom: 60-day rule + exemptions)
Yes Cat F (non-working): โ‚ฌ2,000/mo provable income Low flat tax option: dividends and interest exempt from income tax for non-doms. UK pension: 5% flat rate or regular scale (taxpayer's choice). English widely spoken. Good for retirees and remote workers.
๐Ÿ‡ฒ๐Ÿ‡นMalta Worldwide 0โ€“35%
(Global Residence Programme: 15% on remittances)
Yes GRP: โ‚ฌ100k property or โ‚ฌ75k rental min. โ‚ฌ15k remittance Global Residence Programme: 15% flat on foreign income remitted to Malta; min. tax โ‚ฌ15,000/yr. English-speaking, EU member. Popular with UK retirees. No CGT on most assets.
๐Ÿ‡น๐Ÿ‡ญThailand Territorial* 0โ€“35% on Thai-source income
(*2024 rule: foreign income remitted same year now taxed)
Yes Retirement visa: THB 800k in bank, or THB 65k/mo pension. LTR: $80k/yr income 2024 rule change: foreign income remitted to Thailand in the same tax year it was earned is now taxable. LTR (Long Term Resident) Visa for high earners: foreign income exempt. No CGT. No inheritance tax for residents.
๐Ÿ‡ฒ๐Ÿ‡พMalaysia Territorial 0โ€“30% on Malaysia-source income
Foreign income: exempt
Yes MM2H: RM40k/mo income or RM1.5M liquid assets. Off-shore income exempt. True territorial system โ€” your UK pension, rental and dividends are tax-free in Malaysia. MM2H (My Second Home) visa: renewals paused 2024, check latest. Low cost of living. No CGT. No inheritance tax.
๐Ÿ‡ธ๐Ÿ‡ฌSingapore Territorial 0โ€“24% on Singapore-source income
Foreign income: generally exempt
Yes EP/PR: employment-based. Global Investor: S$2.5M investment Foreign-sourced income generally exempt unless received through a Singapore partnership. No CGT, no inheritance tax. Very high cost of living. Not typically a retirement destination due to visa restrictions.
๐Ÿ‡ฆ๐Ÿ‡ชUAE / Dubai No income tax 0% personal income tax
(9% corporate tax from 2023)
Yes Golden Visa: 2M AED investment or property. Freelance: sponsor arrangement No personal income tax. UK pension received in UAE: UK retains right to tax under DTA (check Art.17/18). Dubai popular with UK professionals. UK CGT still applies on UK assets. 5% VAT applies locally.
๐Ÿ‡ต๐Ÿ‡ฆPanama Territorial 0โ€“25% on Panama-source income
Foreign income: 0%
No DTA Pensionado: $1,000/mo pension income. Friendly Nations Visa: various Very popular retirement destination. Foreign income completely exempt โ€” UK pension, rental, investment income: 0% local tax. Strong Pensionado visa with significant discounts. No DTA with UK โ€” UK tax on UK-source income still applies under UK rules.
๐Ÿ‡จ๐Ÿ‡ทCosta Rica Territorial 0โ€“27.5% on Costa Rica-source income
Foreign income: 0%
No DTA Pensionado: $1,000/mo pension. Rentista: $2,500/mo stable income Territorial: UK-sourced income (pension, rental, dividends) is 0% taxable locally. Pensionado visa: $1,000/mo minimum โ€” popular with retirees. Stable democracy, good healthcare. No DTA with UK.
๐Ÿ‡ฟ๐Ÿ‡ฆSouth Africa Worldwide 18โ€“45% progressive Yes Retirement Annuity Visa: R37,000/mo provable income Worldwide taxation applies. UK DTA: State Pension taxable in UK only; occupational pension may be taxed in SA. Financial emigration required to crystallise pension funds. High crime; medical aid (private health) essential.
๐Ÿ‡ฒ๐Ÿ‡บMauritius Flat 15% Flat 15% on local income
Foreign income: generally exempt if remitted from abroad
Yes Premium Visa: $2,000/mo bank statement evidence. Retire Mauritius: $1,500/mo Attractive flat 15% rate. Foreign income remitted: may benefit from partial exemption. UK DTA: comprehensive agreement. Growing digital nomad community. No CGT, no inheritance tax. Good infrastructure.
๐Ÿ‡ฆ๐Ÿ‡บAustralia Worldwide 0โ€“45% + 2% Medicare levy
(non-resident rate: flat 32.5% on first A$135k)
Yes Contributor Subclass 143/864: A$690kโ€“755k. Sponsored: 410 visa Worldwide taxation, high rates for non-residents initially. UK State Pension is a "frozen pension" โ€” annual increases frozen on date you leave UK. Complex superannuation rules. Check residency status carefully: full resident rates apply once you establish domicile.

3. Destination Spotlights โ€” UK Pension Treatment

How your UK pension income is typically treated under key DTAs. Always verify the specific DTA article โ€” UK government service pensions (NHS, Civil Service, armed forces) are almost always taxable only in the UK.

Country UK State Pension UK Occupational Pension UK Government Service Pension DTA Article (pension)
๐Ÿ‡ต๐Ÿ‡น PortugalTaxable in UK only (DTA Art.17 โ€” pensions paid by UK state)Taxable in Portugal (NHR: may be exempt or 20% flat)Taxable in UK onlyArt. 17 & 18
๐Ÿ‡ช๐Ÿ‡ธ SpainMay be taxable in both; UK credit applied in SpainTaxable in Spain; credit for any UK tax deductedTaxable in UK onlyArt. 17 & 19
๐Ÿ‡ซ๐Ÿ‡ท FranceTaxable in UK only (DTA Art.23)Taxable in France; withholding in UK โ€” claim refundTaxable in UK onlyArt. 18 & 23
๐Ÿ‡จ๐Ÿ‡พ CyprusTaxpayer's choice: 5% flat or scale rate (whichever lower)Cyprus 5% flat or scaleTaxable in UK onlyArt. 18
๐Ÿ‡น๐Ÿ‡ญ ThailandTaxable in UK; if remitted to Thailand, credit availableMay be taxable in Thailand if remitted same yearTaxable in UK onlyArt. 21 & 22
๐Ÿ‡ฒ๐Ÿ‡พ MalaysiaTaxable in UK (territorial: not taxed in Malaysia)Territorial: not taxed in MalaysiaTaxable in UK onlyArt. 16 & 17
๐Ÿ‡ฆ๐Ÿ‡ช UAEUK retains right to tax (no personal tax in UAE)UK retains right to tax under Art. 17/18Taxable in UK onlyArt. 17 & 18
๐Ÿ‡ฆ๐Ÿ‡บ AustraliaTaxable in Australia; credit for UK tax. NOTE: frozen pension appliesTaxable in Australia; UK may also withhold โ€” claim refundTaxable in UK onlyArt. 17 & 18
๐Ÿ‡ต๐Ÿ‡ฆ PanamaNo DTA โ€” UK taxes at source; Panama territorial (0%)No DTA โ€” UK taxes at source under domestic rulesNo DTA โ€” UK taxes at sourceNo DTA

4. Tax Efficiency for UK Retirees โ€” Quick Ranking

๐ŸŒŸ Most tax-efficient

Malaysia, Panama, Costa Rica โ€” territorial taxation means UK pension and investment income attract 0% local tax. No CGT. Low overall tax burden.

โœจ Very tax-efficient

Cyprus, Malta, Greece, Italy (south), Portugal (NHR) โ€” flat/reduced rate regimes for qualifying expats. CGT often nil or low. Strong DTAs with UK.

โš–๏ธ Moderate

UAE/Dubai, Mauritius, Thailand (LTR) โ€” zero/low local income tax but UK pension may still be taxed in UK under DTA rules. Ideal if you have investment income rather than UK pension.

๐Ÿ“‹ Higher tax / complex

Spain, France, Germany, Australia, South Africa โ€” worldwide tax systems with relatively high rates. DTA relief important. Get specialist advice.

Important: Tax laws change frequently. Rates in this guide reflect January 2025 information. Always verify current rules with local tax authorities or a qualified cross-border tax adviser. This guide is educational only.

How to save as PDF: Press Ctrl+P (โŒ˜+P on Mac) โ†’ "Save as PDF" โ†’ margins: Minimum โ†’ Save. Set to Landscape for wide tables.

โ† Back to downloads ๐Ÿงฎ Tax Calculator