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Guias de tributação

12 países com sistemas tributários territoriais para segunda residência

Published on
Oct 28, 2024

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While completely tax-free countries offer obvious appeal, territorial tax systems present an intelligent alternative for international residents. These jurisdictions only tax income earned within their borders, leaving worldwide income untouched. This approach to taxation has gained recognition as one of the fairest systems, respecting the principle that income should be taxed where it's earned.

Understanding territorial taxation is crucial for anyone considering international residency options. Unlike tax-free jurisdictions, these countries maintain functional tax systems but limit their reach to domestic income sources. This means that income from foreign investments, overseas businesses, or international services typically remains untaxed, creating significant opportunities for those with international income streams.

The key to successfully utilizing a territorial tax system lies in proper structuring of your income sources. It's essential to clearly distinguish between local and foreign-source income, and in many cases, to ensure that foreign income isn't remitted to the country of residence in ways that could trigger local taxation. Professional tax advice is often valuable in navigating these distinctions and ensuring compliance with local regulations.

These territorial tax jurisdictions often offer additional advantages beyond their tax policies. Many feature strong banking systems, stable governments, and high standards of living. Some provide easy paths to residency, while others maintain more stringent requirements. The choice of jurisdiction often depends on factors like investment requirements, lifestyle preferences, and geographical location.

For those seeking to optimize their international tax situation while maintaining a comfortable lifestyle, territorial tax countries offer a practical middle ground between high-tax and tax-free jurisdictions. Let's explore twelve of the most attractive options currently available.

1. Costa Rica

Costa Rica employs a territorial tax system that only taxes income generated within its borders. This means that foreign-source income, whether from investments, business operations, or other sources, remains untaxed, making it particularly attractive for those with international income streams.

Becoming a resident in Costa Rica is relatively straightforward, though requirements have tightened in recent years. The basic program requires proof of US$2,500 in monthly income, or alternatively, applicants can qualify by making a US$60,000 investment in a Costa Rican bank.

Living in Costa Rica offers a combination of natural beauty and modern amenities. The country is known for its stable democracy, high-quality healthcare system, and incredible biodiversity. Despite some bureaucratic challenges, the combination of beautiful beaches, tropical jungles, and a welcoming atmosphere makes it a popular choice, particularly among American retirees.

2. Georgia

Georgia has emerged as one of the world's freest economies, with a territorial tax system that exempts foreign-sourced income from taxation. The government has dramatically simplified its tax structure, reducing the number of taxes from 21 to just 5, making it increasingly attractive for international residents.

The country offers remarkably accessible residency options. Most foreigners can enter on a 360-day tourist visa, and residency can be obtained through either establishing a Georgian company or purchasing real estate. For those who do conduct business locally, corporate taxes are set at a flat 15%.

Georgia's strategic location between Europe and Asia, combined with its rich cultural heritage, makes it an increasingly popular choice for international residents. The country offers a low cost of living, stunning landscapes ranging from mountains to coastline, and a rapidly modernizing infrastructure.

3. Guatemala

Guatemala operates a territorial tax system that keeps foreign-earned income outside its tax net. This Central American nation offers one of four territorial taxation systems in the region, making it an attractive option for those seeking to optimize their international tax position.

Obtaining permanent residence in Guatemala is straightforward for those who can demonstrate a monthly income of US$1,000. While this requirement is relatively modest, residents must maintain a substantial physical presence in the country to maintain their permit. Alternatively, temporary residence can be secured through a US$100,000 investment, though permanent residence is available for less through other routes.

The country offers a rich cultural heritage, stunning natural beauty, and a relatively low cost of living. After five years of full-time residence, citizenship becomes available, providing an additional long-term option for committed residents. The combination of favorable tax treatment and authentic Central American lifestyle makes Guatemala an interesting choice for adventurous expatriates.

4. Hong Kong

Hong Kong maintains a sophisticated territorial tax system that primarily targets locally-sourced income while leaving foreign earnings untaxed. While recent years have seen some policy changes, the special administrative region continues to offer significant tax advantages, particularly for entrepreneurs with overseas operations.

Residency options in Hong Kong have evolved, with the territory now focusing on attracting entrepreneurs and significant investors. The startup visa program enables residence for those who can demonstrate substantial contribution to the local economy. As of March 2024, the Capital Investment Entrant Scheme (CIES) provides residency for those able to invest HKD$30 million (approximately US$4 million).

Despite recent changes, Hong Kong remains one of Asia's most dynamic cities. Its world-class infrastructure, excellent healthcare system, and position as a global financial hub make it an attractive destination for those who can meet the investment requirements. The city offers a unique blend of Eastern and Western cultures, exceptional public transportation, and a vibrant international community.

5. Macau

Macau offers a territorial tax system that exempts foreign earnings from taxation, making it particularly attractive for those with international income sources. While often overshadowed by neighboring Hong Kong, Macau maintains its own distinct tax advantages and banking system.

The path to residency in Macau has evolved since the closure of its official residence-by-investment program in 2007. Current options focus on business creation, requiring an investment of MOP$500,000 (approximately US$62,700) and self-employment as a manager. This requires proving that the managerial position couldn't be filled locally. Initial residency is temporary and valid for seven years, with corporate taxes only applying to local income over MOP$600,000.

Living in Macau offers a unique blend of Portuguese and Chinese influences, creating a distinctive cultural environment. Just an hour from Hong Kong by ferry, residents enjoy excellent banking services, world-class entertainment options, and a strategic location within the Greater Bay Area. The territory's compact size and efficient infrastructure make it an convenient base for those doing business in the region.

6. Malaysia

Malaysia implements a territorial tax system that primarily focuses on locally-sourced income, making it an attractive option for those with international income streams. The country's tax policies are designed to attract foreign investment while maintaining reasonable rates on domestic earnings.

The MM2H (Malaysia My Second Home) program offers one of Asia's most comprehensive residency options. For applicants under 50, requirements include proving monthly income of RM40,000 (US$8,400) and depositing approximately RM500,000 (US$105,000) in a Malaysian bank. Additionally, applicants must demonstrate liquid assets of RM1.5 million (US$316,000). The program offers three tiers - silver, gold, and platinum - with the option to utilize 50% of the deposit after one year for real estate, medical expenses, domestic travel, or education.

Malaysia provides an exceptional quality of life with modern infrastructure, excellent healthcare, and a multicultural environment. The country offers everything from modern cities to tropical islands, with English widely spoken and a welcoming attitude toward foreign residents. The combination of favorable tax treatment and high living standards makes Malaysia particularly attractive for long-term residence in Asia.

7. Nicaragua

Nicaragua employs a territorial tax system that excludes foreign-source income from taxation, though careful planning is necessary to maintain tax advantages. The country has positioned itself as an emerging alternative to Costa Rica, offering similar benefits at a more affordable price point.

Residency options in Nicaragua are notably accessible, particularly for retirees and pensioners who need only prove monthly income of US$600. Alternatively, investors can qualify through a US$30,000 investment in a Nicaraguan Sociedad Anónima (limited company) with majority control. Residents must maintain a physical presence of six months annually to preserve their status and tax benefits.

The country offers an authentic Central American experience with growing infrastructure and development. While not suitable for everyone, Nicaragua provides beautiful beaches, colonial cities, and a low cost of living. The combination of easy residency requirements and territorial taxation makes it an interesting option for those seeking an adventurous lifestyle change.

8. Panama

Panama's territorial tax system is complemented by one of Latin America's strongest banking sectors, making it a particularly attractive option for international residents. The country only taxes income generated within its borders, providing significant advantages for those with foreign income sources.

The Friendly Nations visa program offers an efficient path to permanent residence for citizens of specific countries. Qualification requires demonstrating professional or economic ties through employment, real estate ownership, or certified deposits. The program requires either ownership of Panamanian property valued at minimum US$200,000 or equivalent fixed-term deposits in a national bank.

Panama offers a high quality of life with excellent weather and modern infrastructure. Its strategic location, use of the US dollar, and strong financial services sector make it particularly attractive for international business. The combination of favorable tax treatment, stable government, and high standard of living has made Panama a preferred choice for expatriates from around the world.

9. Paraguay

Paraguay maintains a simple territorial tax system with a low 10% rate on local-source income and typically no taxation of foreign-source income. This straightforward approach to taxation has made it increasingly popular among international residents seeking tax efficiency.

The country offers one of the most accessible residency programs in South America. Permanent residence can be obtained with a modest US$4,500 bank deposit, while investors can qualify through a capital contribution of US$70,000. The program is particularly attractive as it offers a path to citizenship after just three years of residence.

While less developed than some alternatives, Paraguay offers a low cost of living and growing opportunities. The country's stable economy, improving infrastructure, and welcoming attitude toward foreigners make it an interesting option for those seeking a simple path to residency with favorable tax treatment.

10. Singapore

Singapore's territorial tax system combines with its position as a global financial hub to create an attractive package for international residents. The country doesn't tax overseas income received in Singapore, while maintaining a competitive 17% corporate tax rate on local earnings.

The Global Investor Program provides residency for substantial investors, requiring a minimum investment of SGD$10 million (approximately US$7.4 million) in either new or existing local businesses. The investment must be maintained for eight years and can be directed toward various approved sectors including aerospace, automotive, healthcare, and medical technology.

Singapore offers one of the world's highest standards of living, with exceptional infrastructure, healthcare, and education systems. The city-state's strategic location, political stability, and efficient business environment make it particularly attractive for high-net-worth individuals seeking a premium residence in Asia.

11. Thailand

Thailand's territorial tax system focuses primarily on locally-sourced income, creating opportunities for those with international income streams. The country's tax policies are designed to attract foreign investment while maintaining reasonable rates on domestic earnings.

Multiple residency options are available, including business visas, investor visas, retirement visas, and the Thai Elite Visa program. Business visas require company formation, though foreign ownership is limited to 50%. The investment visa requires approximately US$270,000 in Thai investments. Retirees aged 50 or older can qualify through various financial means, including a THB800,000 deposit (US$22,000) or monthly income of THB65,000 (US$1,700). The Thai Elite Visa program offers various tiers, starting at THB900,000 (US$24,500) for a five-year visa.

Thailand combines modern amenities with rich cultural heritage and natural beauty. The country offers excellent healthcare, modern infrastructure in major cities, and a high quality of life at reasonable cost. The variety of visa options and established expatriate communities make Thailand particularly attractive for those seeking an Asian base.

12. Philippines

The Philippines applies a territorial tax system that primarily targets domestic income, with special provisions for retirees. The country's tax structure is particularly favorable for those receiving pensions and annuities, which can be remitted tax-free under certain residency programs.

The Special Retiree Resident Visa (SRRV) offers one of the world's lowest age requirements for retirement residency at 35 years. For those between 35 and 49, qualification requires a US$50,000 bank deposit. Applicants over 50 with proven monthly income of US$800 (US$1,000 for couples) need only deposit US$10,000. After a 30-day holding period, deposits can be converted into active investments.

Living in the Philippines provides access to beautiful tropical landscapes, friendly people, and a low cost of living. The country offers modern amenities in major cities, excellent English language usage, and a welcoming attitude toward foreign residents. The combination of favorable tax treatment for retirees and accessible residency requirements makes it particularly attractive for those seeking an early retirement option in Asia.

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