Internationally mobile individuals continue to face a fragmented tax-residency landscape in 2026. Preferential regimes may reduce tax in one country, but they do not automatically resolve residence conflicts, treaty questions, reporting duties or continuing United States tax obligations.

This overview highlights selected developments relevant to individuals considering a move within Europe or between the United States and Europe. Eligibility and results depend on the taxpayer’s complete facts and the law in force when residence changes.

Selected European Regimes in 2026

For a broader comparison, see our EU Tax Residency Guide.

Portugal: IFICI

Portugal’s former Non-Habitual Resident regime is generally closed to new entrants, subject to transitional provisions. The Incentive for Scientific Research and Innovation, known as IFICI, is narrower and activity-based. Qualifying Portuguese employment or self-employment income may benefit from a 20% rate, while the treatment of foreign-source income depends on the statutory conditions, income category and source jurisdiction.

• The applicant generally must not have been Portuguese tax resident during the preceding five years.
• The taxpayer must perform an eligible activity and satisfy the relevant professional or employer requirements.
• Foreign pensions are not covered by the general foreign-income exemption.
• Income connected with listed low-tax jurisdictions may be subject to special treatment.

Italy: New-Resident Flat Tax

Italy’s Article 24-bis regime permits eligible new residents to elect a substitute tax on qualifying foreign-source income. For individuals transferring residence after the statutory change introduced in 2024, the annual substitute tax is now EUR 300,000. The election can generally apply for up to 15 tax years, subject to eligibility, revocation and termination rules.

The regime does not replace the need to determine Italian tax residence, classify each item of income or review inheritance, gift, reporting and treaty consequences. U.S. persons must separately consider continuing U.S. taxation and information reporting.

Professionals relocating to Italy should also compare the Italian Impatriati Regime, which applies to qualifying employment and professional income under a different framework.

Greece: Foreign Pension Regime

Greece continues to provide a 7% alternative tax regime for qualifying foreign pensioners who transfer tax residence, subject to statutory residence, prior-residence and country-cooperation requirements. Individual income composition and treaty treatment remain important.

Spain: Special Inbound Worker Regime

Spain’s inbound-worker regime, commonly called the Beckham Law, can apply to qualifying employees, remote workers and certain entrepreneurs or professionals. The eligibility route, application deadline, family position and income source must be reviewed individually.

The table is a high-level comparison only. It does not describe all exclusions, rates, filing deadlines or treaty interactions.

U.S. Persons Moving Abroad

Citizenship-Based Taxation Continues

U.S. citizens generally remain subject to U.S. federal income tax on worldwide income while living abroad. Green Card holders may also continue to be treated as U.S. residents for federal tax purposes unless their status ends under applicable law and any relevant treaty position is properly addressed.

For tax year 2026, the maximum foreign earned income exclusion is USD 132,900. The exclusion applies only to qualifying earned income and does not eliminate the requirement to file a return or address other categories of income, foreign tax credits and information returns.

Section 877A Expatriation Thresholds

A U.S. citizen relinquishing citizenship or a long-term resident ending covered residency may be a covered expatriate if one of the statutory tests applies. For expatriations in 2026:

• Net-worth test: USD 2 million or more.
• Average annual net income-tax liability test: more than USD 211,000 for the five preceding tax years.
• Certification test: failure to certify five years of federal tax compliance on Form 8854.

The 2026 mark-to-market exclusion amount is USD 910,000. Exceptions and special rules apply to certain dual citizens, minors, deferred compensation, specified tax-deferred accounts and trusts.

FBAR and FATCA Reporting

U.S. persons may have to file an FBAR when the aggregate maximum value of foreign financial accounts exceeds USD 10,000 at any point during the calendar year. Form 8938 has separate thresholds and definitions. Penalties depend on the applicable statute, facts and conduct; they should not be described as a fixed amount automatically charged for every account.

For a detailed comparison, read our FBAR vs FATCA Guide for Americans in Italy.

Planning Before the Move

1. Establish the residence timeline: document arrival, departure, registration, housing, family and habitual-presence facts.
2. Model both tax systems: include income, gains, pensions, entities, trusts, investments and reporting duties.
3. Review treaty residence: domestic residence and treaty residence are related but distinct analyses.
4. Examine entities before relocation: foreign corporations, LLCs and partnerships may be classified differently after the move.
5. Review succession exposure: residence and domicile can affect estate, inheritance and gift taxation.
6. Plan transactions before the residence change: timing may alter the treatment of gains, distributions, options or restructurings.

Remote workers may also review our Digital Nomad Tax Italy Guide.