Transfer of tax residence: Portugal, Andorra, Georgia, Panama or Bahamas?
- Jul 31
- 7 min read
Summary
Introduction
Moving abroad does not automatically transfer tax residency. The matter is primarily a legal one: objective criteria must be met, a schedule of presence must be maintained, and the ties that still bind the household to France must be credibly severed. Five destinations regularly appear in the wealth management projects we advise: Portugal, Andorra, Georgia, Panama, and the Bahamas .
We recently compared transferring your residence to Cyprus, Dubai, Malta, Mauritius, or Singapore . This new overview expands the scope to include Southern Europe, the Caucasus, and Latin America, each with very different tax regimes. The key issue remains the same: choosing a jurisdiction whose legal framework truly suits your situation , and not the other way around.
Each country imposes its own residency requirements, preferential treatment, and immigration procedures. We detail these below, before outlining the common elements for any departure from France : exit tax, tax treaties, and the automatic exchange of information. The aim is to provide you with a clear overview, without making unrealistic promises.
Transferring your tax residence: a legal change, not just a geographical one
Under French law, tax residency is based on the criteria set out in Article 4 B of the General Tax Code: 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 French tax residency , even while living abroad for several months.
A solid relocation therefore requires shifting these three centers of gravity simultaneously. Renting or buying a home there, establishing one's family and business there, and concentrating one's accounts and income there constitute the real substance that makes the departure legally binding on the authorities. A documented record of presence is far more valuable than a false address.
Three checks before any arbitration
Before comparing tax regimes, three points need clarification: the number of days to be spent in the host country, the existence of a tax treaty with France , and the treatment of your various sources of income. These factors determine the feasibility of the project well before the destination is chosen.
Portugal: The end of the NHR and the new IFICI regime
Portugal has long attracted expatriates thanks to its Non-Habitual Resident (NHR) scheme, which capped certain foreign income and applied a reduced rate to high-value-added professions. This long-standing scheme has been closed to new arrivals since 2024 , radically changing the equation for a project launched in 2026.
It was replaced by IFICI, a scheme refocused on research, innovation, and certain skilled activities, often referred to as "NHR 2.0." Outside of this framework, ordinary residents are subject to the Portuguese progressive tax scale, which can reach 48%. Residency is acquired through 183 days of presence or by having a property intended to become the resident's primary residence .
Portugal remains a relevant option for those seeking a European framework, a high quality of life, and transparent taxation, provided they are eligible for the IFICI (French wealth tax). We help secure a transfer of tax residence to Portugal by verifying eligibility for the scheme before any commitment is made.
Andorra: a favorable tax system on the doorstep of Europe
Nestled between France and Spain, Andorra applies an income tax capped at 10% , with no wealth tax or inheritance tax for direct descendants. This moderate tax rate, combined with its geographical proximity, makes it a popular choice for French entrepreneurs and families.
Passive residency requires an actual stay of at least 90 days per year, an investment in the country, and private health insurance; active residency, on the other hand, requires carrying out a genuine business activity there. In both cases, the administration expects a genuine residence , not just a mailbox.
Since Andorra is not a member of the European Union, access to the single market and certain procedures differ from those of an EU country. A transfer of tax residence to Andorra requires advance preparation, particularly regarding real estate and obtaining a residence permit.
Georgia: Territoriality and High Net Worth Individual Status
Georgia combines a flat 20% income tax on Georgian-sourced income with a largely territorial approach: much foreign-sourced income escapes local taxation. The country has also developed a tax residency status reserved for high-net-worth individuals.
This "High Net Worth Individual" status allows individuals, subject to certain asset or income requirements and provided they have a connection to the country, to obtain a residence permit without the usual 183-day residency requirement. The "small business" scheme offers a parallel, reduced tax rate of 1% of turnover for small, self-employed individuals , within certain limits.
This flexibility appeals to digital freelancers and mobile investors. However, it requires careful review of the agreements , as local exemption does not automatically translate into exemption on the French side. We tailor each transfer of tax residence to Georgia based on the specific nature of your income.
Panama: pure territoriality and the resident visa
Panama applies a strict territorial system : only income from Panamanian sources is taxed, while income earned abroad is generally exempt locally. This principle makes the country a classic destination for international assets and export-oriented businesses.
Obtaining residency: visas and physical presence
Several residency pathways exist, ranging from real estate investment and bank deposits to programs for citizens of partner countries. Obtaining resident status and, ultimately, a tax residency certificate , requires a genuine presence and tangible ties to the country, beyond simply establishing a company.
The US dollar is legal tender there, and the financial center is well-established, which simplifies wealth management. A transfer of tax residence to Panama should be carefully structured to ensure its enforceability against the French tax authorities .
Bahamas: Zero income tax and residency through real estate
The Bahamas archipelago levies no income tax, no capital gains tax , and no inheritance tax. Public revenue is based primarily on VAT and property taxes, a model radically different from the French tax system.
Residency is obtained primarily through the purchase of real estate, with affordable permanent residency becoming available beyond a certain investment threshold. The processing of the most substantial applications is generally expedited, but actual presence remains a factor in the assessment.
As an island destination, the Bahamas are particularly well-suited to those with already internationalized assets who are ready for a significant life change . We assist with the transfer of tax residency to the Bahamas by coordinating real estate, immigration, and overall wealth management.
The comparison in a table
The table below summarizes the main points for each jurisdiction. These are legal rates and public principles , which should be compared to your personal situation before making any decision.
Jurisdiction | Income tax | Tax logic | Indicative presence |
Portugal | Tax rate up to 48% (IFICI if eligible) | Global residency, targeted plans | 183 days or usual home |
Andorra | Up to 10% | Global residency, capped rate | 90 days (passive residence) |
Georgia | 20% local source; 1% small business | Extended territory | HNWI status without 183 days |
Panama | On local source income | Pure territoriality | Physical presence required |
Bahamas | None | No income tax | Residence by investment |
A client, a digital entrepreneur whose anonymity we are protecting, was hesitating between Georgia and Panama for his foreign-sourced income. Analysis of his cash flows and the applicable tax treaty led him to choose the legally sound option, rather than the one with the lowest advertised tax rate.
Exit tax, agreements and CRS: the common foundation for all expatriations
Regardless of the destination country, leaving France triggers mechanisms that must be anticipated. The exit tax under Article 167 bis of the French General Tax Code (CGI) can make certain unrealized capital gains on significant shareholdings taxable at the time of transfer, with a deferral of payment subject to certain conditions.
Tax treaties and exchange of information
Bilateral tax treaties resolve cases of dual residence and allocate taxing rights between states. Their existence, or absence, profoundly changes the outcome: income exempt locally may still be taxable in France if the treaty attributes it to the French source.
Finally, the automatic exchange of information (CRS standard) and FATCA-type obligations make banking transparency virtually total. Any serious strategy is therefore based on legality and economic substance , never on secrecy. This is precisely what the concept of a tax haven, as it is currently defined, reminds us.
Frequently Asked Questions
Is leaving France enough to transfer my tax residence?
No. As long as a home, a main activity, or the center of economic interests remains in France, French tax residency can be maintained. The transfer requires a credible and documented relocation of these three centers of gravity.
Is the Portuguese NHR scheme still available?
The non-habitual resident scheme has been closed to new arrivals since 2024. It has been replaced by the IFICI, refocused on research, innovation and certain qualified activities, with stricter eligibility conditions.
Does Georgia really allow you to avoid the 183 days?
High Net Worth Individual status can lead to a residence permit without the usual 183-day waiting period, subject to conditions regarding assets or income and ties to the country. This does not exempt the individual from analyzing the tax treaty with France.
Does the exit tax apply to all departures?
It primarily targets taxpayers holding significant shareholdings and unrealized capital gains at the time of transfer. A payment deferral is possible under certain conditions, but the plan must be put in place well in advance of departure.
Are Panama and the Bahamas risk-free because they have little or no taxation?
Low or no local taxes do not exempt a company from having a real presence or complying with French and international regulations. The soundness of a transfer depends on its substance and legality, not solely on the stated tax rate.
How to choose between these five destinations?
Based on your mobility, the nature of your income, and your ability to establish a real life there, a personalized study objectively compares jurisdictions according to your situation.
Conclusion
Portugal, Andorra, Georgia, Panama, and the Bahamas offer very different paths to lower taxes, ranging from the European framework to pure territoriality. None is "better" in absolute terms: everything depends on your income, your mobility, and your ability to establish a real presence .
Before making any decisions, it's wise to compare your project with residency requirements, exit taxes, and applicable agreements. You can assess your residency relocation options with Coreway Consulting .
