Taxes are an important subject with citizenship by investment . It is important to understand taxes is not based on citizenship. In most countries, taxation is based on residence (183 days a year) and not based on citizenship. Tax laws in most countries are extremely complex and varies for dual citizens.
We did a quick study on taxes that apply for CBI programs. Our findings are below with a quick summary…
- St Kitts and Antigua are only three countries that have no personal income taxes on both local and foreign income. If you pursue a passport that comes with no personal income tax, these tax free countries are the most desirable ones.
- Vanuatu has zero corporate taxes.
- Caribbean countries do not levy taxes on capital gains, wealth or inheritance. If you are a HNWI it is important to pick a country that has no wealth taxes
- Montenegro has the lowest taxes in Europe.
- Some of these countries are very appealing for fintech and cryptocurrency investors for giving them tax free perks
St Kitts and Antigua has no personal income tax on both local and foreign income. It is important to note many countries in the Caribbean will exempt you from personal income taxes ONLY if you are a non-resident citizen (residents are taxed). The other countries are ok and not as bad as you think.
Many of these countries have double taxation treaties and also a member of OECD
Here is a quick comparison of how taxes apply in CBI jurisdictions
| CBI | Corporate Tax | Personal Income Tax | Wealth Tax | Capital Gains | Inheritance or Estate Tax | Tax Treaties |
| Antigua | 25.00% | 0% | 0 | 0 | 0 | Caricom, UK |
| St Kitts | 33.00% | 0 | 0 | 0% (< 1yr) | 0 | CARICOM, Monaco, Switzerland, UK |
| Dominica | 25.00% | Residents only | 0 | 0 | 0 | Caricom |
| St Lucia | 30.00% | Residents only (upto 30%) | 0 | 0 | 0 | Caricom, Switzerland |
| Grenada | 28.00% | Resident/Non-residents income within Grenada (15%) | 0 | 0 | 0 | Caricom,UK |
| Vanuatu | 0.00% | Upto 17% | 0 | 0 | 0 | 19 countries |
| Turkey | 22.00% | 15-35% | yes | 22.00% | 1-30% | 94 countries |
| Malta | 35.00% | Upto 35% | 0 | 12.00% | 0 | 76 countries |
| Cyprus | 12.50% | Upto 35% | 0 | 20.00% | 0 | 65 countries |
| Bulgaria | 10.00% | 10-18% + SS | 0 | 0 | 0.4-0.8% | 86 countries |
| Moldova | 12.00% | 12% + SS | 0.80% | 10.00% | 0 | 50 countries |
| Montenegro | 9.00% | 9-12% | 0 | 9.00% | 5.00% | 42 countries |
| Egypt | 22.50% | Upto 22.5% | 0 | 0 | 2.50% | 50 countries |
| Jordan | 20.00% | Upto 14% | 0 | 0 (except company share sale or depreciable assets) | 0 | 32 countries |
Note: SS is social security
Sources: Deloitte and other sources
Important: Please seek a tax advice from a qualified expert before you consider citizenship planning. The above information is general compiled for knowledge purpose only.
