Tax when you move to Spain, Portugal, France or Italy

The four countries side by side

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.

Sources: FIZ, IRS returns, MCS, online services, MyExpatTaxes, US and French taxes, TaxDown, advisers for expats, October 2026, Xolo, Spain pricing, Xolo, Italy