A US high earner considering international relocation typically evaluates eight to ten destinations by the time they finish researching. This is the comparison matrix that walks the ones actually worth considering — Puerto Rico (as a US territory alternative), Portugal, Malta, the UAE, Singapore, Switzerland, the UK, Panama, and Costa Rica — against the US baseline. Every row is a real decision variable: rule type, corporate rate, individual rate, capital gains treatment, wealth tax, US treaty coverage.
The comparison walks ten jurisdictions against the US baseline. The first table maps each jurisdiction's rule type (worldwide, residence, territorial, or hybrid). The second table lays out the headline rates side-by-side. Practitioner notes on each country follow below.
| Country | Rule type |
|---|---|
| United States | Worldwide (citizenship-based) |
| Puerto Rico (US territory) | US territorial + Act 60 (bona fide resident) |
| Portugal | Residence-based; NHR (Non-Habitual Resident) closed to new applicants 2024 |
| Malta | Residence & domicile; Global Residence Programme for non-EU/EEA nationals |
| United Arab Emirates | Territorial; corporate tax introduced 2023 |
| Singapore | Territorial (foreign-source income generally not taxed until remitted) |
| Switzerland | Residence-based; lump-sum taxation available to non-Swiss nationals |
| United Kingdom | Residence & domicile; remittance basis for non-doms (reformed 2024/25) |
| Panama | Territorial (foreign-source income exempt for residents) |
| Costa Rica | Territorial (foreign-source income exempt for residents) |
| Country | Corp rate | Individual top | Capital gains | Wealth tax | US treaty |
|---|---|---|---|---|---|
| United States | 21% | 37% | 20% + 3.8% NIIT | None federal | N/A |
| Puerto Rico | 4% (Act 60) | 33%; 0% on qual. gains | 0% qual. gains (Act 60) | None | PR outside US treaty net |
| Portugal | 21-31.5% eff. | 48% + 5% solidarity | 28% flat | AIMI 0.4-1.5% >€600k RE | US-Portugal (1994) w/ LOB |
| Malta | 35%; 5-10% eff. | 35% | 35% MT-source | None | US-Malta (2010) |
| UAE | 9% >AED 375k | 0% | 0% | None | None |
| Singapore | 17% | 24% (>S$1M) | 0% | None; prog. property tax | None |
| Switzerland | 12-21% | 40-45% | 0% priv. gains | Cantonal 0.1-1% | US-Switzerland |
| United Kingdom | 25% | 45% (>£125,140) | 24% RE; 20% other | None; council tax | US-UK (2001); savings cl. |
| Panama | 25% PA-source | 25% (prog.) | 10% PA; 0% foreign | None | None |
| Costa Rica | 30% | 25% CR-source | 15% CR; 0% foreign | None; property 0.25% | None |
Effective rates after credits, exemptions, and local mechanics can vary substantially from these headline figures — see the practitioner notes below. “LOB” = Limitation on Benefits article; “RE” = real estate.
The United States and Eritrea are the only two countries in the world that tax on citizenship rather than residence. Every other country on this list taxes based on residence. The consequence for a US citizen is that no matter which foreign country you move to, you remain subject to US federal income tax on your worldwide income. The foreign country's tax regime layers on top, and the interaction is mediated by the foreign tax credit and (where available) tax treaties.
This is why the country comparison starts from a different question for US persons than for a UK citizen or a German citizen doing the same research. A UK citizen moving to Malta escapes UK residence tax immediately upon severing UK residence. A US citizen moving to Malta continues to file a US 1040 every year for the rest of their life, until they expatriate under §877A (which itself carries a mark-to-market exit tax — see the §877A page).
The default baseline. Every other row in this table is compared back to the US. Citizenship-based taxation is the outlier feature globally — the US and Eritrea are the only two countries that tax on citizenship rather than residence.
Not a foreign country from a US tax perspective — a US territory with its own tax code plus a specific decree framework (Act 60) that offers dramatic incentives for bona fide residents who move from the mainland. Does not require citizenship renunciation. See the dedicated Puerto Rico page.
The NHR regime that made Portugal the retirement destination of choice for high-earning US professionals closed to new applicants in 2024. New IFICI (Incentive for Scientific Research and Innovation) opened 2024 with narrower criteria targeting researchers and specific sectors. Practitioners considering Portugal in 2026 should model the standard residence regime, not NHR.
Malta's full-imputation corporate tax system produces an effective 5% rate on qualifying non-domiciled trading income through a refundable credit mechanism. Popular for iGaming, fund management, and IP holding companies. The US-Malta treaty was reformed in 2010 to close specific abuse cases; practitioners should verify current treaty coverage before relying on withholding relief.
The UAE introduced federal corporate tax in June 2023 at 9% above the AED 375k threshold, ending the pure zero-tax narrative for corporate income. Personal income remains untaxed. No US tax treaty means US persons cannot claim treaty-based withholding relief on US-source income. The Golden Visa and freelance/entrepreneur visa programs are the primary residency vehicles for individuals.
Singapore's territorial system means foreign-source income is generally not taxed until remitted, which enables significant deferral for individuals with foreign passive income. No US tax treaty. The Global Investor Programme (GIP) is the primary permanent residence path for high-net-worth individuals; the ONE Pass targets highly-compensated professionals earning above S$30k per month.
Private capital gains untaxed for individuals is a distinctive Swiss feature that materially changes portfolio planning versus other high-income jurisdictions. Wealth tax is cantonal but universal for residents. Lump-sum taxation (“forfait fiscal”) available to non-Swiss nationals who do not work in Switzerland — taxed on a deemed expenditure base rather than actual income, and negotiated with the canton. Not available in every canton and increasingly politically contested.
The non-dom remittance basis regime was substantially reformed in 2024/25, moving to a four-year foreign income and gains regime for new arrivals and phasing out the historic remittance basis for existing non-doms. Any US practitioner working with UK-resident clients should verify which transitional rule applies. The US-UK treaty savings clause preserves US taxing rights over US citizens regardless of UK residence, which limits treaty benefits.
Panama’s territorial tax system is one of the cleanest in Latin America: foreign-source income is exempt for Panama residents, and Panama-source income is taxed at moderate rates. The Friendly Nations Visa program (open to nationals of 50+ countries including the US) is the primary path to permanent residency. No US tax treaty means US persons cannot claim treaty-based withholding relief. The dollarized economy (Panamanian balboa pegged 1:1 to USD, and US dollars circulate freely) removes FX friction for US movers. A common Latin America outbound destination for US persons who want territorial taxation without giving up US citizenship — but citizenship-based US taxation continues to apply.
Costa Rica’s territorial system exempts foreign-source income for residents, similar to Panama. The Pensionado residence program (requiring $1,000/month permanent pension income) and the Rentista program (requiring $2,500/month for two years, or $60,000 bank deposit) are the two primary paths for retirees and non-employed movers. No US tax treaty. Costa Rica’s environmental and political stability, developed medical system, and expat community make it a common destination for US retirees seeking territorial taxation. As with Panama, citizenship-based US taxation continues to apply unless the taxpayer also expatriates under §877A.
Puerto Rico specifically: Puerto Rico Act 60 & Act 22 — the individual investor decree.
Expatriation cost: §877A expatriation tax.
The applied companion: The Baratelli International Tax & Cross-Border Wealth guide walks each of these destinations at greater depth with worked founder-liquidity-event and retirement scenarios.
Print edition: Download the country-comparison print PDF.