Recent shifts in territorial taxation worldwide
Published at: 12/03/2026 08:48 am
Increasingly, countries are abolishing the right to opt out of paying taxes on foreign-sourced income. Let’s take a look at the latest changes.
The United Kingdom abolished its "non-dom regime" in April 2025. Previously, non-domiciled residents could pay taxes only on the foreign income remitted into the country. Now, there is a short four-year "grace period" for recently arrived residents. Everyone else must pay taxes on their worldwide income.
Italy has a "lump-sum" or "flat-tax" system; however, the government has doubled the minimum annual tax from 100,000 euros to 200,000 euros.
Guernsey and Jersey have reformed their traditional offshore tax systems, and restructuring is still ongoing in 2026. Both Channel Islands are reforming their fiscal frameworks to comply with international standards.
Thailand has changed its remittance-based territorial tax solution. If you stay more than 180 days per year in Thailand, you are considered a tax resident and must pay taxes on your foreign-sourced income (specifically on amounts earned after 2023). LTR (Long-Term Resident) visa holders, however, remain exempt from these new tax rules on foreign-sourced income.
Uruguay has surprised new residents with updated regulations on foreign-sourced passive income. From 2026, only high-net-worth investors can be exempted from taxes on foreign-sourced income for eleven years, provided they invest at least two million dollars in real estate or $100,000 into an innovation/research fund. Other newcomers must pay the local 12% flat tax.
Colombia moved aggressively to tax the worldwide income. The highest tax rate for residents is now 41%.
Taxes are only one - though significant - issue when deciding to obtain a new residency or citizenship. Freedom of travel, a territorial tax system, and a secure future for the family have always been the most important drivers. If you need to structure your taxes, reduce your tax burden, or become internationally tax-compliant, you should seek our advice.
We have more than three decades of experience at Discus Holdings Ltd. Contact us today, and let’s plan your new physical residency or citizenship and tax structure together.