Tax Overview By Region
Nothing on this page or website should be construed as personal tax advice in any of the countries listed and specifically not in the US or the UK. We are not tax advisors and not regulated as such. We will endeavour to update the information on this page but you cannot rely on it being up to date, and current regulations are subject to change.
Please see our dedicated website on the USA: aisa-international.com
Pensions- UK pensions transferred out of the UK to third countries may not be treated for tax as rollovers and could generate a tax charge on transfer.
UK pensions- taxed in the USA, subject to Double Tax Treaty. Pension commencement lump sums not taxable in the US.
The United States levies tax on its citizens and residents on their worldwide income. Non-resident aliens are taxed on their US-source income.
Top individual income tax rate of 39.6% ( over $418,400 pa income ) and a top rate of 20% for capital gains and qualified dividends.
Capital Gains: tax for properties held for more than a year is 5%; otherwise the tax is 15%.
Inheritance: Federal estate tax is progressive with rates at 18% to 45% and an exemption of up to US$2,000,000. A Generation-Skipping Transfer Tax is also being levied on transfers to beneficiaries who are more than one generation younger than the transferor.
According to the ATO, if you transfer your overseas pension savings to an Australian super fund within 6 months of becoming a resident of Australia, or within 6 months of terminating your foreign employment, then no tax is payable on your transferred super benefits in Australia.After that 15% tax will be payable on the assessable part of the transfer.
A yearly Non-Concessional Contribution (NCC) cap of $100,000 for individuals less than 75 years but not below 65 years and a three year bring forward NCC ($300,000) for individuals less than 65 years.
Superannuation benefits are made up of two components, taxable and tax-free( Included transfers from foreign pensions ), which are taxed differently when withdrawals are made either as income streams or on a lump sum basis once you are eligible to access the funds.
|Taxable income (AUD)||Tax on column 1 (AUD)||Income tax on excess (%)|
Note: A Medicare levy of an additional 2% of taxable income applies to most residents. An additional Medicare levy surcharge of between 1% and 1.5% applies to certain higher income taxpayers not covered by health insurance for private patient hospital cover. Special rates apply to unearned income of children below the age of 18 years at year end where that income is more than AUD 416.
Capital Gains: Individuals are subject to a 50% reduction of the taxable gain if the asset is held for at least 12 months. Capital Gains follow the individual income tax rates, at rates from 32.50% to 45% for nonresidents.
Inheritance: There are no direct taxes on inheritance.
Please see our dedicated website on South Africa: aisainternational.co.za
Rental Income: All property owners are subject to a flat tax of 19% on gross rental income
Property and Wealth: A special annual 3% tax is levied on the cadastral value of real estate owned by non-residents.
Capital Gains: Realised by non-residents are subject to flat rate of 19%.
Inheritance: Each beneficiary’s inheritance is taxed at progressive rates, from 7.65% to 34%, after certain tax-free amounts have been deducted.
Residents: Are liable to tax on their worldwide income and assets at progressive rates, from 19% to 45% for 2012 and 2013.
Personal income tax rates
Savings taxable income is taxed at the following rates:
• 19% for the first EUR 6,000 of taxable income.
• 21% for the following EUR 6,000 to EUR 50,000 of taxable income.
• 23% for any amounts over EUR 50,000.
Progressive tax rates are applied (which are the sum of the applicable rate approved by the state and the applicable rate approved by each autonomous region of Spain in their progressive tax rate scales). For this reason, tax liability may differ from one autonomous region to another.
The following tables show the tax scale for withholdings approved by the state. This scale can be used as a guideline of the progressive tax rates applicable for the general taxable base. For the reasons stated above, the scale applicable in the corresponding autonomous region of Spain should always be consulted to calculate the total progressive tax rate.
Tax scale for withholdings applicable in 2017:
(up to EUR)
|Tax liability (EUR)||Excess of taxable base
(up to EUR)
|Tax rate (%)|
Non-resident income tax (NRIT) rates
For non-residents, income obtained without a PE is taxed at the following rates:
• General rate: 24%. For residents in other EU member states or European Economic Area (EEA) countries with which there is an effective exchange of tax information, the rate is 19% from 2016.
• Capital gains generated from transfers of assets: 19% from 2016.
• Interest: 19% from 2016. Interest is tax exempt for EU residents. Double taxation treaties (DTTs) normally establish lower rates.
• Dividends: 19% from 2016 (DTTs normally establish lower rates).
• Royalties: 24% (DTTs normally establish lower rates).
• Pensions are taxed at progressive rates (between 8% and 40%).
Pensions: Individuals can make contribution based on age up to the earnings limit of €150,000
Lump Sums from Pension – first €200,000 is tax free, next €300,000 at the standard rate of income tax ( 20%)
Capital Gains Tax: 30%. Lower rates, 15% for a partnership / individual and 12.5% for a company. Annual exemption €1,270. For married couples or civil partners the exemption is €1,270 each (non-transferable).
Inheritance: is taxed at a flat rate of 33%, with certain non-taxable amounts deductible before the tax is levied.
Income Tax- 2 main bands of 20% and 40%. Allowance of €18,000 per person with the 20% band of € 33,800 applied before 40% is charged.
Pensions and Trusts: France does not recognise Trusts and will look though them for tax purposes. UK pensions are deemed acceptable bona fide pensions. This could for instance apply to US Individual Retirement Accounts or to 401(k) plans recognized as “Qualifying Recognised Overseas Pension Schemes” by the UK tax authorities. A case by case analysis should be carried out in order to ensure that a trust could benefit from this exemption.
Trusts must be declared each year in any of the following cases:
• the settlor is French resident
• any beneficiary is French resident
• any trustee is French resident
• any asset is “located in France”
with a fine of 20000€ or 12.5% of the total trust assets for non-declaration (and the authorities can go back up to 10 years).
The declaration must be made (in French) using form 2181 TRUST 2 and submitted by June 15 (extended to August 31 for non-resident settlors & beneficiaries).
Rates are progressive from 0% to 45%, plus a surtax of 3% on the portion of income that exceeds EUR 250,000 for a single person and EUR 500,000 for a married couple and of 4% for income that exceeds EUR 500,000 for a single person and EUR 1 million for a married couple.
The inbound assignee regime applies to employees assigned to France by their foreign employer or to employees directly recruited abroad by a French company as of 1 January 2008. In both cases, the individuals must not have been French tax resident during five calendar years preceding the year of beginning their assignment/employment in France. In addition, the individuals need to fulfil specific residence/domicile conditions.
Under this regime, individuals assigned to France by their foreign employer can benefit from a French income tax exemption in relation to salary supplements connected with their assignment.
For employees directly recruited abroad, the regime offers the following options:
• exemption of the actual amount of salary supplements received, or
• a flat rate exemption of 30% of the total remuneration.
Capital Gains: are generally taxed at 19%. Capital gains tax is levied at 33.33% for non-EU citizens.
Inheritance: French private international law uses the standard double rule on inheritance: the law of the deceased’s domicile applies to moveable assets, and the law of the location of the property applies to immoveable assets.
Pensions from UK- Not possible to transfer to QROPS in Canada
2017 federal tax rates are as follows:
|Federal taxable income (CAD*)||Tax on first column (CAD)||Tax on excess (%)|
* Canadian dollars
Only half of the final capital gains are taxed as part of income. Capital gains are computed by deducting the costs incurred in selling and purchasing the property, capital expenditures, and such costs as additions and improvements in the property.
Cyprus Income Tax is imposed on the worldwide income of individuals who are tax residents in Cyprus. Individuals who are not tax residents of Cyprus are taxed only on certain types of income accrued or derived from sources in Cyprus.
The following table lists the rates and bands currently applicable to individuals:
|Chargeable income for the tax year (EUR)||Tax rate (%)||Accumulated tax (EUR)|
Capital Gains: realized from the sale of immovable property are taxed at 20%, with a lifetime exemption of 85,430 if the property was owner-occupied for at least 5 years.
Inheritance: There are no inheritance taxes or estate duties in Cyprus.
Does not tax pension Income remitted into the country.
Residents: A resident individual’s taxable income (after setoff of personal allowances) is subject to income tax at progressive rates. Current rates for years of assessment 2015 to 2017 (income years 2014 to 2016) are shown below.
|Taxable income (SGD*)||Years of assessment 2015 and 2016||Year of assessment 2017|
|Over (column 1)||Not over||Tax on column 1 (SGD)||Percentage on excess (%)||Tax on column 1 (SGD)||Percentage on excess (%)|
* Singapore dollars
For the year of assessment 2015, resident individuals received a one-off tax rebate of 50%, capped at SGD 1,000.
Non-residents: Non-resident individuals are taxed at 20%, except that Singapore employment income is taxed at a flat rate of 15% or at resident rates with personal reliefs, whichever yields a higher tax. A non-resident director’s remuneration does not qualify for the reduced rate, and tax at 20% must be deducted from remuneration paid to a non-resident director. With effect from year of assessment 2017 (income year 2016), the non-resident individual tax rates will increase to 22%.
Capital Gains: There is no capital gains tax.
Inheritance: There is no estate duty.
Pension paid in consideration of past employment is not taxed twice.
The following rates are applicable to resident individual taxpayers for YA 2016:
|Taxable income (MYR*)||Tax on column 1 (MYR)||Tax on excess (%)|
* Malaysian Ringgit
A non-resident individual is taxed at a flat rate of 28% on total taxable income
Capital Gains: For non-citizens and non-residents, real property gains tax (RPGT) is levied on disposals of properties held for more than five years at a flat rate of 5%. As of 2014, different RPGT rates apply for citizens, non-citizens, and companies.
Inheritance: No inheritance or gift taxes are levied in Malaysia.
Tax brackets for income year 2017 are applicable to net taxable income after the deduction of social security charges and professional expenses.
|Taxable income (EUR)||Rate (%)||Tax on bracket (EUR)||Cumulative tax (EUR)|
For residents of Belgium, communal taxes are levied at rates varying from 0% to 9% of the income tax due. The average rate being 7%. For non-residents, a flat surcharge of 7% is due. In some cases, communal taxes may also be levied on exempted foreign-source income.
Capital Gains: tax of 16.5% is payable on gains on developed property held for less than five years. After a holding period of five years, no Capital Gains Tax is payable.
Inheritance: tax rates in Belgium are progressive and vary according to the degree of kinship, region where the inheritance is opened, and the share inherited by each of the heirs.
Non-residents are taxed at a flat rate of 25% on their taxable remuneration in 2017.
|Taxable income (EUR*)||Tax rate (%)||Deductible amount (EUR)|
Capital Gains: Net gains are taxed at a flat rate of 28% in Portugal. Acquisition costs are deducted from the gross selling price of the property.
Inheritance: There are no inheritance and gift taxes in Portugal.
Britons with non-habitual residency can currently receive most UK pension income or lump sums without attracting tax for their first ten years in Portugal. This is because NHR offers tax exemptions for many types of foreign-source income that is taxed or taxable in another country under the terms of a double tax treaty.
As the UK-Portugal tax treaty gives Portugal the taxing rights on UK private pensions, company pensions and the UK State Pension, most UK pensions qualify. As a result, it is currently possible to withdraw UK pension funds (lump sums or income) completely tax-free during your first ten years here.
The basic exemption limit for resident individuals who are 60 years of age or more but less than 80 years of age at any time during the tax year is INR 300,000, and for resident individuals who are 80 years of age or more it is INR 500,000.
The following types of residential status are envisaged for an individual:
• Resident in India, which is further divided into the following two categories:
o Resident and ordinarily resident (ROR).
o Resident but not ordinarily resident (RNOR).
• Non-resident in India (NR).
• The slab rates applicable to individuals for the tax year 2017/18 are as follows:
|Taxable income (INR)||Tax on column 1 (INR)||Percentage on excess (%)|
Those resident, but not ordinarily resident, are only taxed on Indian-source income, income accrued or having arisen in India, income received within India or income received outside India that is a result of the activities of an Indian controlled business.
Capital Gains: are taxed at the standard income tax rates.
Inheritance: No inheritance or gift tax is levied in India. But a wealth tax of 1% is imposed if the net wealth exceeds INR10 million (US$147,059).
QROPS: recently removed Hong Kong from HMRC recognised list.
|Net taxable income (HKD)||Tax on column 1 (HKD)||Percentage on excess (%)|
|Over (column 1)||Not over|
The maximum tax for 2017/18, however, will be limited to tax at the standard rate (15%) on the net assessable income (after any business deductions) less concessionary deductions and charitable donations but without the deduction of personal allowances.
Capital Gains: No capital gains tax exists in Hong Kong.
Inheritance: estate duty was abolished.
There is currently no personal income tax law enacted in the United Arab Emirates.
As there is no personal income tax in the United Arab Emirates, there are no individual tax registration or reporting obligations.
There is a new Double Tax Treaty between the UK and the UAE
Capital Gains: There is none taxable in Dubai.
Nothing on this page or website should be construed as personal tax advice in the US or the UK. We are not tax advisors and not regulated as such but we do understand taxation of pension funds in the UK. This page is not designed to give you personal Tax Advice but is designed to provide information that will help people understand the type of Tax Advice they should be seeking.
Aisa International is registered with the FSB as Aisa International (PTY) Ltd – No. 47638 and authorised for provision of intermediary services in South Africa. We also have a US registered company with the SEC. Aisa Financial Planning, a UK limited corporation, is authorised and regulated by the FCA – Reg.189652, for provision of intermediary services through the EEA under both the IMD and MiFID, including a branch called Aisa International.
Trading Names: TailorMade is a registered trading name, but does not provide expat pension advice in that name. This website is aimed at individuals not resident in the UK or USA. Please see www.aisagroup.org in order to ensure that you are dealing with the most appropriate group company.