Lump-Sum Tax Regimes by Country: How Flat Annual Tax Deals Work

Source: https://nomadlayer.com/articles/lump-sum-tax-regimes-by-country

October 10, 2026
Nomad Tax
Lump-Sum Tax Regimes by Country: How Flat Annual Tax Deals Work

A lump-sum tax regime lets a qualifying resident pay a fixed, capped or minimum amount of tax each year instead of normal income tax on some or all of their income. The best-known versions are in Europe: Italy's flat tax for new residents, Greece's non-dom regime, Switzerland's expenditure-based taxation and the tax caps of Jersey, Guernsey, the Isle of Man and Gibraltar.

The amounts range from a few thousand dollars to several hundred thousand euros a year. What you get for the money also varies. Some regimes cover only foreign income, some cap tax on everything, and some simply set a floor under a low flat rate.

This guide groups the regimes by design, compares the numbers as of October 2026, and covers the conditions that tend to decide whether a regime is usable at all.

Key takeaways

  • Lump-sum regimes come in four designs: a fixed charge on foreign income, a tax based on living expenses, a cap on total tax, and a minimum tax combined with a low flat rate.
  • Italy raised its charge to €300,000 a year for people who move from 1 January 2026, and Malta's minimum rises to €35,000 for new applicants from 1 January 2027.
  • Local income is almost always taxed normally on top of the lump sum.
  • Most regimes require a genuine move, a minimum absence from the country beforehand, and often a property purchase or investment.
  • The regime only deals with the new country. Whether you stop being taxable where you lived before depends on that country's rules.

Four designs behind the label 'lump sum'

Fixed charge on foreign income. You pay a set amount each year, and in exchange your foreign income and gains are not taxed further. Italy and Greece use this model.

Expenditure-based tax. Switzerland taxes a notional income calculated from your living costs and housing, not your actual income. The result is a predictable bill that is not directly tied to what you earn abroad.

Tax caps. Jersey, Guernsey and the Isle of Man tax income at normal rates but stop at a maximum figure. Gibraltar's Category 2 status taxes only a set slice of income.

Minimum tax with a flat rate. Malta taxes foreign income remitted to Malta at 15% under its special programs but requires a minimum annual payment. Cyprus offers a lump-sum extension of its non-dom benefits for long-term residents.

Lump-sum tax regimes compared

JurisdictionDesignAnnual amount (as of October 2026)Main conditions
ItalyFixed charge on foreign income€300,000, plus €50,000 per added family member, for moves from 1 January 2026Not Italian tax resident in 9 of the previous 10 years; up to 15 years
GreeceFixed charge on foreign income€100,000, plus €20,000 per added relativeNot Greek tax resident in 7 of the previous 8 years; €500,000 investment; up to 15 years
SwitzerlandExpenditure-basedTax at ordinary rates on a base of at least CHF 435,000 (federal) or 7 times rentNot Swiss; first arrival or 10 years away; no work in Switzerland
Malta (from 2027)15% on remitted income, minimum tax€35,000 minimum for Global Resident statusProperty of €700,000 or rent of €14,000 a year; 5-year renewable status
JerseyRate structure for high-value residents20% on the first £1.25 million, 1% above; at least £250,000Income above £1.25 million; wealth above £10 million; property purchase expected
GuernseyTax capUp to £160,000 on non-Guernsey income or £320,000 overall; £60,000 open market cap for up to 4 yearsOpen market cap needs a large property purchase
Isle of ManTax cap£220,000 per individual, £440,000 for a coupleElection for a set number of years
GibraltarTaxed income limitTax on the first £118,000 of income: £37,000 minimum, £42,380 maximum (2025/26)Category 2 certificate, approved housing, wealth test
Honduras (Próspera ZEDE)Fixed annual taxUS$5,0007 days per year inside Próspera

Italy: a charge that keeps rising

Italy's regime under Article 24-bis of its income tax code replaces Italian tax on all foreign income with a single annual payment. Italian-source income is taxed normally. The option can last up to 15 years, and it can be extended to family members who also move.

The price has gone up twice. People who opted in early pay €100,000. Those who moved after 10 August 2024 pay €200,000. The 2026 Budget Law set €300,000 for transfers of residence from 1 January 2026, with €50,000 for each family member, as noted in PwC's Italy tax summary. Each taxpayer keeps the amount in force when they opted in. Our guide to the Italy flat tax for new residents covers the procedure.

A rough comparison shows who the regime is built for. Italy's top income tax rate is 43%, before regional and municipal surcharges. At that rate, €300,000 equals the ordinary tax on about €700,000 of income. Below that level, normal taxation may cost less.

Greece: lower price, investment required

Greece offers a fixed €100,000 a year on foreign income, plus €20,000 for each relative included. The conditions, as summarized in PwC's Greece tax summary, are that the person was not Greek tax resident in 7 of the 8 years before the move and invests at least €500,000 in Greek real estate, businesses, securities or shares within three years. The regime runs for up to 15 years. Greek inheritance and gift tax does not apply to foreign assets of people in the regime.

Greek-source income is taxed at normal progressive rates. Greece also has separate regimes for pensioners, who can pay 7% on foreign income, and for relocating workers, who can exempt half of their Greek employment income for seven years.

Switzerland: tax based on how you live

Swiss lump-sum taxation, often called the forfait fiscal, calculates tax on deemed income. That base is the higher of your worldwide living expenses, seven times your annual rent or the rental value of your home, and a federal minimum of CHF 435,000 for the 2026 tax year, according to the Swiss Federal Tax Administration. The base is then taxed at the ordinary rates of your canton and municipality, and many cantons set their own higher minimums. A yearly control calculation can raise the bill if certain Swiss-source income is large.

According to KPMG Switzerland, the regime is open to foreign nationals taking up Swiss residence for the first time or after at least ten years away, who do not work in Switzerland. Both spouses must qualify. Zurich, Basel-Stadt, Basel-Landschaft, Schaffhausen and Appenzell Ausserrhoden have abolished it at cantonal level. Unlike Italy and Greece, there is no fixed end date.

Malta: from minimum tax to a new program

Malta taxes resident non-domiciled people only on Maltese income and on foreign income brought into Malta. Under the Global Residence Programme, remitted foreign income is taxed at 15% with a €15,000 annual minimum.

Legal Notice 195 of 2026 replaces the existing programs with a single Individual Tax Programme from 1 January 2027. PwC's Malta summary lists a €35,000 minimum for Global Resident and EU/EEA/Swiss Resident status, a property purchase of at least €700,000 or rent of at least €14,000 a year, an €8,500 application fee, and five-year renewable status. People granted status, or who apply, by 31 December 2026 stay on the old terms until 31 December 2031. See our news piece on Malta's new tax programme.

The Crown Dependencies and Gibraltar: capped tax

Jersey, Guernsey and the Isle of Man all tax income at a flat or near-flat rate and offer caps to wealthy residents.

  • Jersey. High-value residents pay 20% on the first £1.25 million of worldwide income and 1% above that, which means at least £250,000 a year. Locate Jersey lists wealth above £10 million and an expected property purchase of at least £3.5 million for a house. Income from Jersey property stays at 20%.
  • Guernsey. Residents can cap tax on non-Guernsey income at £160,000, or total tax at £320,000 where they also have Guernsey income. New arrivals who buy open market property with at least £50,000 of document duty can cap tax at £60,000 for up to four years.
  • Isle of Man. Individuals can elect to cap income tax at £220,000 a year, or £440,000 for a jointly assessed couple. KPMG reported the cap unchanged in the 2026 budget.
  • Gibraltar. Category 2 individuals are taxed only on the first £118,000 of assessable income, which, according to EY's 2025/26 tax facts, means tax of at least £37,000 and at most £42,380. Gibraltar has been reviewing entry criteria for new applicants, so the conditions are worth checking with its Income Tax Office.

Cyprus: a lump sum to extend non-dom status

Cyprus non-doms pay no Special Defence Contribution on dividends and interest. After 17 years of tax residence in the last 20, a person is treated as domiciled for that purpose. Cyprus's 2026 tax reform added an option for people without a Cypriot domicile of origin to pay €250,000 for each five-year period to keep the exemption, available for up to two periods. It is a niche rule for long-term residents, not an entry route.

Outside Europe: Próspera

One option some nomads look at is Honduras tax residency through Próspera, a ZEDE (special economic zone) on the island of Roatán with its own regulatory framework. The Próspera Lump Sum Tax Regime is a flat $5,000 per year tax, residents spend 7 days per year inside Próspera, and onboarding is remote. As with every regime on this page, leaving a previous tax system depends on that country's own rules. Our explainer on the Próspera lump sum tax and the Honduras tax residency page have the details.

What the headline numbers leave out

Local income is extra. In Italy, Greece, Jersey, Guernsey and most other regimes, income from the host country is taxed normally on top of the lump sum.

Treaty access can be limited. Some tax treaty partners restrict benefits for people taxed on a lump-sum basis. Switzerland offers a modified calculation for this reason, and advisers usually check treaty positions before a move.

The price can change. Italy has tripled its charge since the regime began. Malta more than doubles its minimum from 2027. Most regimes protect people already inside, but new applicants face the new terms.

The old country still has a say. A lump-sum certificate in a new country does not end residence elsewhere. The UK, for example, applies its Statutory Residence Test, and some countries charge exit taxes. Comparing regimes side by side, as in our overview of non-dom regimes in Europe, is only the first step.

Frequently asked questions

What is a lump-sum tax regime?

It is a special tax status in which a qualifying resident pays a fixed, capped or minimum amount each year instead of ordinary income tax on some or all income. Most versions apply only to income from abroad and only to people who recently moved.

Which countries offer lump-sum taxation in 2026?

The main ones are Italy, Greece, Switzerland, Malta (through minimum tax programs), Jersey, Guernsey, the Isle of Man and Gibraltar. Cyprus has a lump-sum option for long-term non-doms, and Próspera in Honduras has a fixed annual tax.

Is Swiss lump-sum taxation still available?

Yes, in most cantons. Zurich, Basel-Stadt, Basel-Landschaft, Schaffhausen and Appenzell Ausserrhoden have abolished it at cantonal level. The federal minimum tax base is CHF 435,000, and cantons can set higher figures.

Does a lump-sum tax cover income from the new country?

Usually not. Italy, Greece and the Channel Islands tax local income separately, and Switzerland runs a control calculation on certain Swiss-source income. The fixed amount mainly covers foreign income.

How much is Italy's flat tax for new residents in 2026?

For people who transfer their tax residence to Italy from 1 January 2026, the annual charge is €300,000, plus €50,000 for each family member included. Earlier arrivals keep the amount that applied when they opted in.

Important: This article is general information, not tax, legal or financial advice. Rules change often and depend on your personal circumstances. Speak with a qualified professional in each relevant country before you act.

Nomad Layer Team

Digital nomad expert and contributor to the Nomad Layer community.