The measures in force

Greece and Malta on the hunt for pensioners

Besides the super-rich, several countries have measures for young managers and the elderly

by An.Lo. and A.Tom.

(Adobe Stock)

2' min read

2' min read

In addition to the schemes for very high wealth and income earners - for whom much is at stake on the end of the English 'res-non-dom' scheme, its replacement and the related transitional regime - there are many countries that have favourable schemes of the type of our 'impatriate' and 'pensioner' schemes.

Impatriate schemes

In Italy, since January, the benefits and persons eligible for the impatriate relief have been reduced. Today, these are highly professional individuals who have been resident abroad for at least three years (except in the case of intra-group transfers where the period abroad is longer, see factsheet). These individuals, if they undertake to work and reside in Italy for at least four years, see their tax base for earned income reduced by 50%, up to a maximum income of €600,000 per year.

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Spain has an impatriate regime that has similarities with Italy. It provides for the application of a 24% substitute tax on income earned in Spain up to EUR 600,000 and an exemption for income earned abroad (in this more similar to our impatriate regime). The Netherlands, on the other hand, incentivises highly qualified foreign employees who are temporarily 'assigned' to the Netherlands, who can claim a tax exemption of 30% of their earned income.

The measures for pensioners

On the pensioner front, Italy incentivises, with a 7% substitute taxation of Irpef and additional taxes on foreign income, persons resident abroad in the previous five periods who transfer their residence to one of the municipalities in southern Italian regions with a population of no more than 20,000 inhabitants, or to one of the municipalities affected by seismic events specifically identified by law. Here the State with a similar scheme was mainly Portugal, which totally exempted foreign pensions, but then backtracked and provided for a 10% substitute taxation for 10 years and finally repealed the scheme.

Particularly favourable regimes for pensioners today are Greece (which also has a new-resident style regime), which provides for a 7% substitute tax on all foreign-source income for 15 years, and Malta, which provides for a fixed rate of 15% on any foreign-source income received in Malta, for pensioners from the EU, non-EU states, Switzerland and the See who receive a foreign pension constituting at least 75% of their taxable income.

Malta has a further and different favourable regime for persons from the EU, Switzerland or EEA who own or rent real estate in Malta and establish tax residence there. The property must have a minimum value of EUR 220,000-275,000 and, if rented, the annual rent must be at least EUR 8,750-9,600, depending on the location of the property. The regime provides for a 15% taxation for income received in Malta and an exemption for income received abroad (and not remitted to Malta).

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