Tax relocation advice: Portugal, Andorra, Georgia, Panama or Bahamas?
- 6 days ago
- 8 min read
Summary
Introduction
Dubai, Cyprus, Malta, Mauritius, and Singapore often garner attention, but five other jurisdictions deserve equally serious consideration in a wealth relocation project. Portugal, Andorra, Georgia, Panama, and the Bahamas offer very different frameworks, ranging from the structured European regime to the most flexible territorial taxation . It is essential to understand what each jurisdiction actually imposes.
We recently discussed the question of choosing a jurisdiction for a crypto trader . This article broadens the perspective to five additional destinations, while maintaining the same requirement: starting with a verifiable legal framework rather than simply a ranking of advertised rates .
Each country caters to a specific profile, depending on mobility, income type, and the desire to settle in Europe or further afield. The objective remains the same: to align the tax framework with a real lifestyle , while never neglecting the French rules of departure that determine the validity of the transfer.
Relocating your tax residence: a residence, not an address
Under French law, Article 4 B of the General Tax Code establishes three alternative residency criteria: the home or principal place of residence, the principal professional activity, and the center of economic interests . Meeting only one of these criteria is sufficient to maintain taxation in France on worldwide income.
Choosing Portugal or the Bahamas does not exempt one from planning a credible departure. As long as the family, home, or the bulk of productive assets remain in France, the tax authorities can reclassify French tax residency . The host country only truly matters once the break from French ties is established on solid grounds.
Three questions before comparing rates
Before any arbitration between these five jurisdictions, three questions determine most cases. Will your physical presence reach the required number of days on site? Will your family and household actually follow you? And can you relocate the center of your economic interests without maintaining a significant connection to France?
The responses naturally point towards a family of destinations. A fully mobile entrepreneur will not face the same constraints as a manager maintaining operations in France, and this framework structures the comparison that follows.
Portugal: The end of the NHR and the arrival of the IFICI
The famous non-habitual resident (NHR) scheme has closed its doors to new arrivals: since 2024, it is no longer possible to join it, and it was officially replaced on January 1, 2025. Portugal retains a strong European appeal, but the tax framework has changed profoundly .
The new scheme, IFICI, often nicknamed NHR 2.0, now targets highly qualified professionals in research, innovation, and technology. It offers a flat rate of 20% on certain eligible business income for ten years, provided that the individual is actually engaged in one of the targeted activities.
What the IFICI changes for rentiers
The break is clear for retirees and those with passive income. Unlike the former NHR, the IFICI no longer grants preferential treatment to pensions, dividends, or rental income, which are now subject to a progressive tax scale that can reach 53% nationally . Portugal remains a viable option for an active and skilled individual, but much less so for those simply seeking a passive income.
To secure a Portuguese investment, it's best to verify your actual eligibility for the Portuguese IFICI (French real estate wealth tax) and the exact nature of your income beforehand. We outline these conditions on our dedicated page for tax relocation advice in Portugal , to help you avoid any unpleasant surprises in your first year.
Andorra: Income tax capped at 10% in the heart of the Pyrenees
The principality applies a progressive but very low personal income tax (IRPF): 0% up to €24,000, 5% between €24,000 and €40,000, and then a cap of 10% above that . In addition, there is no wealth tax and no inheritance tax, which explains the country's attractiveness for those seeking to build wealth.
Corporate taxation is also capped at 10%, in a stable environment similar to that of France. Andorra thus combines a de facto European framework with a moderate tax burden , despite not being a member of the European Union.
Passive or active residence: two entry points
There are two main pathways. Passive residency, reserved for those whose income comes from abroad, requires a local investment, the threshold for which was raised to one million euros in 2026, combined with a minimum presence of 90 days per year . Active residency, linked to actual work activity on the ground, requires a presence of at least 183 days.
The choice depends directly on your life plans and the source of your income. We detail these criteria, as well as the substantive requirements, on the page dedicated to tax relocation advice in Andorra .
Georgia: Territoriality and status at 1% for entrepreneurs
Georgia applies a territorial principle for individuals: foreign-source income, including dividends, interest, or remuneration from a non-Georgian company, is generally not taxed locally . The standard rate remains a flat 20% on Georgian-source income.
The most discussed benefit is aimed at the self-employed: the small business status allows for a 1% tax on turnover up to 500,000 GEL per year, with the portion exceeding this being taxed at 3%. However, this scheme must be formally applied for and requires an eligible business activity.
Regarding residency, two options exist: a 183-day residency requirement or the program designed for high-net-worth individuals, which does not mandate it. This residency flexibility appeals to those already spread across multiple locations, as we explain in our tax relocation advice for Georgia .
Panama: Territorial taxation and Friendly Nations Visa
Panama operates under a strictly territorial tax system: only income from Panamanian sources is taxed, while income generated outside the country is generally exempt from local taxation. This system makes it a popular location for entrepreneurs with international business activities .
The pathways of the Friendly Nations Visa
Access to residency often involves the Friendly Nations Visa, available to citizens of many countries, including France. There are three main pathways: employment with a Panamanian company, the purchase of real estate worth at least $200,000, or an equivalent bank deposit held for several years. The visa initially grants temporary residency for two years before transitioning to permanent residency.
The US dollar serves as the de facto currency, and the banking sector remains well-developed. For a truly mobile executive, Panama combines territorial stability with a strong presence in the Americas , something we facilitate through tax relocation consulting in Panama .
Bahamas: Zero tax, residency through real estate
The archipelago levies no income tax, no capital gains tax, and no inheritance tax. Public revenue relies primarily on VAT and customs duties, resulting in residents facing an almost complete absence of direct taxation .
The downside lies in the initial cost and the distance. Permanent residency through real estate investment now requires a minimum investment of one million dollars, which has been raised since 2025, in local real estate or eligible securities. It's a destination tailored for those with existing wealth and a genuine desire to settle down.
For those seeking a prime residence without direct taxation, the equation can be very favorable, provided they anticipate the financial burden and lifestyle there. We detail the steps involved on our tax relocation advice page for the Bahamas .
The comparison in a table
The table below summarizes the rationale for each destination. It does not replace a personalized study , as the presence threshold and the treatment of foreign income are just as important as the displayed rate.
Jurisdiction | Income tax | Residence | Key point |
Portugal | IFICI 20% eligible activity | 183 days | EU framework, qualified profiles |
Andorra | Progressive, capped at 10% | 90 or 183 days | No wealth tax or inheritance tax |
Georgia | Territorial, 1% small business | 183 days or HNWI | Foreign income exempt from tax |
Panama | Territorial | Friendly Nations Visa | Income from outside Panama is exempt. |
Bahamas | 0% | Real estate starting at $1 million | No direct tax |
Exit tax, conventions and CRS: the French foundation
Regardless of the destination, several French regulations govern departures. The first is the exit tax, which can be levied on unrealized capital gains from significant shareholdings at the time of the transfer of tax residence . Anticipating this tax avoids unpleasant surprises and, in some cases, grants a deferral of payment.
Agreements and information exchange
A tax treaty often binds France to the host country to avoid double taxation and resolve cases of dual residency. In parallel, the CRS standard organizes the automatic exchange of banking information between countries, making transparency essential . The arrangement must therefore fully comply with it.
One final point to note: the breach of the criteria in Article 4B must be genuine and documented. Maintaining one's family home or the center of one's economic interests in France is sufficient to regain French residency , regardless of the attractiveness of the chosen country.
We had maintained our primary residence and operational management in France; as long as this link remained, my move to Panama remained precarious. By restructuring this connection before departure, the transition became solid and defensible in the long term , testifies an executive who received support in 2025.
Conclusion
Portugal, Andorra, Georgia, Panama, and the Bahamas are not all equal: some have a more focused European tax regime, others a 10% cap, some have a 1% territorial status, and some have territorial taxation or no direct tax at all. The right choice depends first and foremost on your actual mobility and assets , never solely on the advertised rate.
Before making any decisions, it's wise to compare your project with residency requirements, exit tax, and applicable tax treaties. You can assess your tax relocation options with Coreway Consulting .
Frequently Asked Questions
Does the Portuguese NHR scheme still exist?
Not for newcomers. The traditional NHR has been closed since 2024 and replaced by the IFICI. The latter targets qualified profiles in research and innovation, but no longer provides benefits for pensions or passive income.
Is Andorra really a low-tax country?
Andorran personal income tax (IRPF) is progressive and capped at 10%, with no wealth tax or inheritance tax. However, passive residency requires significant local investment and minimal presence, making it a project that needs careful planning.
How does the 1% status work in Georgia?
The small business status allows for a 1% tax rate on turnover up to 500,000 GEL per year, and 3% thereafter. It must be formally applied for and applies to eligible activities carried out on a self-employed basis.
Does Panama tax foreign income?
No, in principle. Panama applies a territorial tax system: only income from Panamanian sources is taxed, while income generated outside the country escapes local tax, provided that a properly established residence is maintained.
Do you need a large budget to settle in the Bahamas?
Since 2025, permanent residency through real estate investment has required a minimum investment of approximately one million dollars. In return, the archipelago levies no income tax, capital gains tax, or inheritance tax.
How do I know which jurisdiction applies to my case?
Based on your mobility, the nature of your income, and your ability to establish a real life there, a personalized study objectively compares these five destinations according to your financial situation.
