Tax
Tax when you move to Spain, Portugal, France or Italy
When you become tax resident, the special regimes for newcomers and who really qualifies, income tax rates, wealth taxes, reporting money you hold abroad, and what the UK and US tax treaties mean for your pension and pay.
Checked on 17 October 2026. Mostly from each country's tax authority and laws, with some figures from PwC, RSM and legal and tax publications where we couldn't read the official text (named in each source list). Rates change with every budget, and the regimes have conditions we can only summarise. This is general information, not tax advice: take local advice before you move.
The short version
- Spain and Italy have regimes open to remote workers. Spain's Beckham law covers remote workers on the telework visa, and Italy's tax authority says its impatriate regime can apply to someone working remotely for a foreign employer. Agencia Tributaria, Modelo 149 instructions, June 2026, Agenzia delle Entrate, ruling 2/2026 (copy)
- Portugal's old NHR has closed. Its replacement, IFICI, is tied to qualifying Portuguese employers and activities, so an ordinary remote job for a UK or US company is unlikely to fit. Portal das Finanças, NHR registration leaflet, May 2024, Portal das Finanças, EBF art. 58-A (IFICI), Portuguese tax authority, IFICI leaflet, March 2025
- France's regime is unlikely to fit remote workers. For employees, its impatriate regime needs a company established in France. BOFiP, impatriate regime, August 2025
- Declare what you hold abroad. Spain's Modelo 720 (above €50,000), France's form 3916 and Italy's RW section all ask about your UK or US accounts and investments, and France fines €1,500 per account you leave out. Agencia Tributaria, Modelo 720 FAQ, March 2022, impots.gouv.fr, form 3916 notice, MySolution, Redditi PF 2026 guide, section RW, May 2026
- UK government pensions usually stay taxed in the UK. Under the Spanish, French and Italian treaties (and Portugal's old one), unless you're a national of the country you move to and, in France and Portugal, not also British. Americans keep filing US returns whatever the treaty says. HMRC manual DT17552, Spain treaty, August 2026, GOV.UK, 1968 UK-Portugal convention, GOV.UK, UK-France convention (synthesised text), UK-Italy double taxation convention (GOV.UK), IRS, tax treaties can affect your income tax, August 2026
The four countries side by side
| Country | You become resident if | Regime for newcomers | Top income tax rate | Wealth taxes | Reporting assets abroad |
|---|---|---|---|---|---|
| Spain | More than 183 days in the calendar year, or your main economic interests there; the whole year counts, so there's no split year | Beckham law: 24% on work income up to €600,000 for 6 years, including remote workers on the telework visa | Around 47% combined, up to 54% in some regions (PwC) | Yes: wealth tax set by region, plus a national tax above €3 million | Modelo 720 above €50,000 per type of asset |
| Portugal | More than 183 days in any 12 months, or a home you intend to keep as your habitual residence; residence starts on your first day there | IFICI ("NHR 2.0"): 20% for 10 years on qualifying work for recognised Portuguese employers or activities | 48%, plus a solidarity surcharge of up to 5% | No general wealth tax; AIMI on residential property with a taxable value above €600,000 | Worldwide income goes on the annual return (we didn't research a separate assets form) |
| France | Any one of: your home or main place of stay, your main work, or your centre of economic interests is in France | Impatriate regime: for employees, needs a company established in France to hire you from abroad or have you sent there | 45% (2025 income scale) | IFI on property above €1.3 million; newcomers taxed only on French property for 5 years | Form 3916 for every foreign account; €1,500 fine per account missed |
| Italy | Residence, domicile or physical presence in Italy for most of the tax year (counting part days); registering as resident is a presumption you can rebut | Impatriates: 50% of work income exempt (60% with a minor child) for 5 years, and remote workers can qualify; €300,000 flat tax on foreign income; 7% for pensioners in small southern towns | 43% (per a tax news site), plus regional and municipal surcharges | Taxes on foreign property (1.06%) and foreign financial assets (0.2%), per RSM | Section RW of the tax return |
Sources: Agencia Tributaria, tax residence (IRPF 2024 manual), Agencia Tributaria, resident individuals, July 2026, Agencia Tributaria, special regime for workers moving to Spain (2025 manual), Spanish government, income tax, Agencia Tributaria, Modelo 151 instructions, June 2026, PwC, Spain personal income tax, June 2026, Agencia Tributaria, wealth tax 2025 manual, Agencia Tributaria, solidarity tax (Modelo 718), Agencia Tributaria, Modelo 720 FAQ, March 2022, Portal das Finanças, IRS code art. 16, Portal das Finanças, EBF art. 58-A (IFICI), Portuguese tax authority, tax rates 2026, gov.pt, personal income tax in Portugal, BOFiP, tax residence (BOI-IR-CHAMP-10), BOFiP, impatriate regime, August 2025, BOFiP, income tax scale for 2025 income, April 2026, impots.gouv.fr, IFI for non-residents and newcomers, impots.gouv.fr, form 3916 notice, Normattiva, D.Lgs. 209/2023 (consolidated, July 2026), D.Lgs. 209/2023 as published (copy), Agenzia delle Entrate, ruling 2/2026 (copy), Budget law 199/2025 (copy), PwC Italy, August 2024, Agenzia delle Entrate, circular 21/E/2020 (copy), InformazioneFiscale, September 2026, RSM Italy, March 2024, MySolution, Redditi PF 2026 guide, section RW, May 2026
Spain
- Becoming resident
- You're resident for a calendar year if you spend more than 183 days in Spain (short trips away count as days in Spain unless you prove tax residence elsewhere), or your main economic interests are there. You're presumed resident, unless you prove otherwise, if your spouse (not legally separated) and dependent minor children live there. Residence covers the whole year: Spanish law has no split year, though a tax treaty can change the answer. Agencia Tributaria, tax residence (IRPF 2024 manual), Agencia Tributaria, resident individuals, July 2026
- Beckham law
- If you haven't been resident in Spain in the previous 5 years and move for a job, remote work (including on the international telework visa), a directorship or an entrepreneurial activity, you can choose to pay 24% on work income up to €600,000 (47% above) for the year you arrive and the next 5. All your work income is taxed, wherever earned; other income only if it comes from Spain. You mustn't earn income through a Spanish permanent establishment. Your spouse, children under 25 (any age if disabled) and their other parent can join. Agencia Tributaria, special regime for workers moving to Spain (2025 manual), Spanish government, income tax, Agencia Tributaria, Modelo 149 instructions, June 2026, Agencia Tributaria, Modelo 151 instructions, June 2026
- Applying
- File Modelo 149 within 6 months of the start date on your Spanish Social Security registration, then Modelo 151 each year instead of the normal return. Agencia Tributaria, Modelo 149 instructions, June 2026, Agencia Tributaria, Modelo 151 instructions, June 2026
- Normal income tax
- The state scale runs from 9.5% to 24.5%, and each region adds its own; PwC puts the typical combined top rate at 47%, and up to 54% in some regions. Savings income is taxed from 19% to 30%. Agencia Tributaria, state income tax scale (2025 manual), PwC, Spain personal income tax, June 2026, Agencia Tributaria, Modelo 151 instructions, June 2026
- Wealth tax
- Set by each region, with a state allowance of €700,000 where the region sets none (Catalonia €500,000, Valencia €1 million, for example); PwC says a main home is exempt up to €300,000. A national solidarity tax on fortunes above €3 million is charged each year. In Madrid, people with net wealth under €3 million pay no wealth tax. Agencia Tributaria, wealth tax 2025 manual, PwC, Spain other taxes, June 2026, Agencia Tributaria, solidarity tax (Modelo 718), Agencia Tributaria, wealth tax 2025 changes, Comunidad de Madrid, wealth tax, May 2026
- Assets abroad
- Residents report foreign bank accounts, investments and property on Modelo 720 when a category is worth more than €50,000, and again when it rises by more than €20,000. In 2022 the EU Court of Justice struck down its harshest penalties, which Spain replaced with ordinary ones; the duty to report remains. Agencia Tributaria, Modelo 720 FAQ, March 2022, Court of Justice of the EU, C-788/19, January 2022
Portugal
- Becoming resident
- More than 183 days, consecutive or not, in any 12-month period, or a home in conditions that suggest you mean to keep it as your habitual residence. You become resident from your first day there. You declare your worldwide income each year between 1 April and 30 June. Portal das Finanças, IRS code art. 16, gov.pt, personal income tax in Portugal
- NHR has closed
- The non-habitual resident regime closed to new applicants: people registered by 1 January 2024 keep it, and a transition covered some who became resident by the end of 2024. Since 2020, holders have generally paid 10% on foreign pensions; earlier rules differed, so check yours. Portal das Finanças, NHR registration leaflet, May 2024, Portal das Finanças, IRS code art. 72 (2020 wording), Portuguese tax authority, tax rates 2026
- IFICI
- The replacement taxes qualifying Portuguese work income at 20% for 10 years, and generally exempts foreign income except pensions. You must not have been resident in the previous 5 years, and anyone who has had NHR can't use it. It covers teaching and research, certified start-ups, R&D, recognised investment projects and listed highly qualified jobs in qualifying companies. Apply by 15 January of the year after you become resident. Portal das Finanças, EBF art. 58-A (IFICI), Portaria 352/2024/1, December 2024, Portuguese tax authority, Ofício Circulado 20276/2025, Portuguese tax authority, IFICI leaflet, March 2025
- Remote workers
- None of the official texts we read says an ordinary remote job for a foreign employer qualifies: every route depends on a qualifying Portuguese employer or activity, and the 20% applies to income earned in Portugal. Assume it won't apply unless an adviser confirms it. Portal das Finanças, EBF art. 58-A (IFICI), Portuguese tax authority, Ofício Circulado 20276/2025, Portuguese tax authority, IFICI leaflet, March 2025
- Normal income tax
- 2026 rates run from 12.5% to 48% (above €86,634), with a solidarity surcharge of 2.5% from €80,000 and 5% above €250,000. Under the simplified regime for the self-employed, 75% of income from listed professional services is taxed, or more if your documented expenses are under 15% of it. Portuguese tax authority, tax rates 2026, Portal das Finanças, IRS code art. 31
- Wealth
- No general wealth tax. An extra property tax (AIMI) applies above €600,000 of residential property at its taxable value: 0.7%, 1% from €1 million and 1.5% above €2 million, with the limits doubled for married couples. Portuguese tax authority, tax rates 2026
France
- Becoming resident
- Meeting any one test makes you resident: your home (foyer) or main place of stay is in France, your main work is there, or your centre of economic interests is there. More than six months a year points to a main stay, but the tax authority says it isn't an absolute test. BOFiP, tax residence (BOI-IR-CHAMP-10)
- Impatriate regime
- For people recruited from abroad by a company established in France, or sent by a foreign company to one, who weren't resident in the previous 5 years. The impatriation bonus is tax-free (or 30% of pay by option), within a 50% cap, until 31 December of the 8th year after you start, and certain foreign passive income gets a 50% income tax exemption (social charges still apply in full). Both routes need a company established in France, so it is unlikely to fit someone working remotely for a foreign employer. BOFiP, impatriate regime, August 2025, impots.gouv.fr, notice 2074-IMP
- Income tax
- For 2025 income (the latest scale): 0% up to €11,600 per part, then 11%, 30%, 41% and 45% above €181,917. Income is divided by household "parts" (two for a married or PACS couple), with the benefit capped at €1,807 per extra half-part. The scale for 2026 income isn't set yet. BOFiP, income tax scale for 2025 income, April 2026, BOFiP, quotient familial cap, April 2026
- Social charges on investments
- A legal publication reports that they rose from 17.2% to 18.6% on most investment income (from 2025 income for some types, 1 January 2026 for others), taking the flat tax to 31.4%; unfurnished rental income, property gains and life insurance stay at 17.2%. Actu-Juridique, February 2026
- Micro-entrepreneurs
- Bpifrance, the state investment bank, says the simplified regime for the self-employed applies up to €83,600 of turnover for services (€203,100 for sales and accommodation) in 2026 to 2028. Bpifrance Création, micro-entreprise thresholds, February 2026
- Wealth tax on property
- IFI applies when your net property is worth more than €1.3 million on 1 January. If you move to France after 5 years abroad, only your French property counts until the 5th year after you arrive. impots.gouv.fr, IFI for non-residents and newcomers
- Accounts abroad
- Declare every account opened, held, used or closed abroad on form 3916 with your return. The fine is €1,500 per account (€10,000 for some countries), plus up to 80% on tax due on money that passed through it. impots.gouv.fr, form 3916 notice
Italy
- Becoming resident
- Since 2024 you're resident if, for most of the tax year (counting part days), you have your legal residence or domicile in Italy, or are simply present there. Domicile means where your main personal and family relationships are. Being on the residents' register is a presumption you can disprove. Normattiva, D.Lgs. 209/2023 (consolidated, July 2026)
- Impatriate regime
- For moves from 2024: half of your Italian work income is exempt (60% if a minor child moves with you or is born or adopted during the period, and lives in Italy), up to €600,000 a year, for the year you move and the next 4. You must not have been resident in the previous 3 years (6 if you work for the employer or group you worked for before going abroad, 7 if you previously worked for it in Italy), be highly qualified, work mainly in Italy, and stay at least 4 years or repay the relief. D.Lgs. 209/2023 as published (copy)
- Remote workers
- The tax authority confirmed in January 2026 that someone working remotely for a foreign employer can qualify, if every condition is met. Agenzia delle Entrate, ruling 2/2026 (copy)
- Flat tax for new residents
- Instead of tax on foreign income, a fixed €300,000 a year plus €50,000 per family member for people moving from 2026 (before that, €200,000 for moves after 10 August 2024 and €100,000 earlier, with €25,000 per family member). PwC says it lasts up to 15 years and Italian income is taxed normally; a legal news site says you must not have been resident in 9 of the previous 10 years. Budget law 199/2025 (copy), PwC Italy, August 2024, Diritto.it, March 2026
- Pensioners in the South
- People with foreign pensions who move to a town of up to 20,000 people in Sicily, Calabria, Sardinia, Campania, Basilicata, Abruzzo, Molise or Puglia can pay 7% on all their foreign income for 10 years, if they weren't resident in the previous 5 years. Agenzia delle Entrate, circular 21/E/2020 (copy)
- Income tax
- The 2026 budget cut the middle rate from 35% to 33%; a tax news site gives the bands as 23% up to €28,000, 33% to €50,000 and 43% above, before regional and municipal surcharges. Budget law 199/2025 (copy), InformazioneFiscale, September 2026
- Assets abroad
- Declared in section RW of the return. RSM reports a 1.06% tax on foreign property, 0.2% on foreign financial assets, and €34.20 a year per foreign bank account. MySolution, Redditi PF 2026 guide, section RW, May 2026, RSM Italy, March 2024
If you're from the UK or the US
- UK government pensions
- Civil service, armed forces and other pensions paid for government service are taxed only in the UK under the Spanish, French and Italian treaties, unless you're a national of the country you live in (in France, only if you're not also British). Spain and France still count them when setting the rate on your other income. HMRC manual DT17552, Spain treaty, August 2026, HMRC manual DT17553, GOV.UK, UK-France convention (synthesised text), UK-Italy double taxation convention (GOV.UK)
- Other UK pensions
- Under the Spanish, French and Italian treaties, private and workplace pensions are taxed where you live. HMRC manual DT17552, Spain treaty, August 2026, GOV.UK, UK-France convention (synthesised text), UK-Italy double taxation convention (GOV.UK)
- Portugal's new treaty
- A new UK-Portugal treaty came into force on 29 December 2025 and applies in Portugal from 1 January 2026. The old treaty taxed UK government pensions only in the UK; we couldn't read the new text to confirm it does the same. GOV.UK, Portugal tax treaties, January 2026, GOV.UK, 1968 UK-Portugal convention
- Americans
- US tax treaties keep the US's right to tax its citizens on worldwide income, so you keep filing a US return and use foreign tax credits to avoid paying twice. There are exceptions; for example, under the US-France treaty, US Social Security paid to someone living in France is taxed only in the US. IRS, tax treaties can affect your income tax, August 2026, US Treasury, US-Portugal technical explanation, 1994, US Treasury, US-Italy technical explanation, US-France protocol, 2004
Getting help
Services in English that publish prices on their own pages, alphabetical. Most local accountants quote case by case, so this list is short.
| Service | Country | What it is | Price | Worth knowing | |
|---|---|---|---|---|---|
| FIZ | Portugal | Self-service tax return software, certified by the tax authority, in English | €49.99 per return, VAT included | Software, not an accountant. It loads NHR status and compares options | Go to FIZ |
| MCS | Portugal | Portuguese tax and accounting firm with an English site | Consultation from €165 including VAT; income analysis deposit €100 plus VAT | The full price for filing a return isn't published | Go to MCS |
| MyExpatTaxes | France (for US citizens) | US expat tax service that also files the French return through a local partner | French return €799 including VAT, on top of its US return (Premium $639) | Impatriate regime add-on €549. "Additional charges may apply" | Go to MyExpatTaxes |
| TaxDown | Spain | Online tax service with advisers | FULL plan from €65 a year (VAT not shown), including the Beckham forms (149 and 151); price confirmed before you pay | Its priced page is in Spanish; the English page has no prices | Go to TaxDown |
| Xolo | Spain and Italy | Online accounting for the self-employed in English, with partner accountants | Spain: €15 to €99 a month plus VAT (Premium includes the income tax return and Beckham help). Italy: €36 a month plus VAT (flat-rate regime), tax return €180 including VAT | Spain bills monthly only. In Italy there's a 6-month minimum, and Xolo says it "is not an accountant" | Go to Xolo |
Sources: FIZ, IRS returns, MCS, online services, MyExpatTaxes, US and French taxes, TaxDown, advisers for expats, October 2026, Xolo, Spain pricing, Xolo, Italy
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