Data confidence, in the open

Where our tax figures are approximate

Every figure in Ember carries a confidence label. This page lists the 288 that sit below our top tier — most are medium confidence (sound, but not yet independently re-verified); the ones worth watching are the low-confidence and not-yet-modelled items, which float to the top of each list. Cross-border tax is genuinely uncertain in places — treaties can read more than one way and reliefs change — so rather than hide that, we show the reason for each. It’s generated directly from the same versioned rule data the planner computes with, so it can never drift from what the app actually does.

22 low confidence · 116 medium confidence · 10 documented but not yet coded.

Income-tax rule packs30

How a country taxes ordinary income. Where a pack is approximate or doesn't yet model a particular rule, it's listed here rather than presented as exact.

WhatFlagWhy / what isn’t captured
AR — income tax (2026)next data review due 2027-01-01low confidence
  • GNI + deducción especial ap.1 NOW modelled as the single-filer allowanceMinor (H2-2026 stack ARS 25,135,816.20); still unmodelled: spouse/child deductions, the '13th-salary' (SAC) exemption, and the ap.2 self-employed variant. APPROXIMATION: the deducción especial statutorily requires employment/pension income, but the flat allowance shields ALL ordinary categories — a rental-only filer is over-shielded by up to the ap.1 amount
  • jubilado deducción específica NOW modelled (retireeSpecificDeduction, 8× HMG): annual figure is a FLOOR — Aug–Dec 2026 held at July's ANSES Res. 186/2026 value (3,295,914.64/mo) pending the monthly movilidad resolutions; refresh as they land. The Bienes Personales forfeiture leg (liability other than from a sole dwelling voids the deduction) is NOT modelled — a wealthy jubilado may be under-taxed by the deduction's spread
  • SEMI-ANNUAL CPI INDEXING: every band boundary and deduction re-indexes each semester (RG ARCA per Ley 27.743 art. 94). H2-2026 (jul–dic) figures wired 2026-07-22 — they are the December-accumulated ANNUAL scale — and go stale ~Jan 2027; the jubilado HMG additionally moves MONTHLY. All ARS thresholds are transient.
  • Empleado social security contributions (jubilacion 11% + PAMI/obra social ~6% = ~17% on gross salary, capped) — separate from income tax, not modelled
  • Provincial income taxes / Ingresos Brutos (turnover tax) not applicable to individuals' employment income but relevant for self-employed — not modelled
  • Impuesto sobre los Bienes Personales (wealth tax on WORLDWIDE assets, ~0.5-1.0%, threshold ~ARS 384.7m 2025, falling to 0.25% by 2027) — a real recurring cost for a resident, separate schedule not modelled
  • Financial/CGT ~15% with many Argentine-security exemptions; dividends ~7% WHT — separate savings schedule, not modelled
  • Deduction mechanism note: AR art. 30 deductions reduce the taxable base at the marginal rate (a genuine deduction) — correctly modelled via allowanceMinor, NOT the credit field (which is for fixed-rate credit-like reliefs, e.g. ES mínimo personal)
  • selfEmployment: no regime module — self-employed social contributions / business-income surcharges for this jurisdiction are not modelled

Source: Ember tax-rulepack dossier (AR — Ember tax-rulepack dossier §5.20 (AR — Argentina), primary source AR-INCOME: PwC); ARCA Tabla Art. 94 LIG jul–dic 2026 (= December accumulated annual scale, verified in-PDF); ARCA Deducciones personales Art. 30 jul–dic 2026 (a diciembre: GNI 5,585,736.93; especial ap.1 19,550,079.27); ARCA Deducción específica jubilados HMG 2026 (ANSES Res. 381/2025–186/2026 monthly ladder)

CH — income tax (2026)next data review due 2027-01-01low confidencefederal floor only
  • FEDERAL-ONLY FLOOR — this pack models federal direct tax (Bundessteuer) ONLY (max ~11.5% marginal), so the CH figure is a LOWER BOUND, not a realistic Swiss tax estimate. Cantonal + communal income tax (the MAJORITY of a Swiss resident's bill, wholly canton-dependent) are NOT modelled: true combined income tax is roughly ~25%–40%+ top-marginal (Zug/Schwyz low vs Geneva/Vaud high). Do NOT rely on the modelled CH figure for a move/compare decision — it materially understates Swiss tax.
  • CANTONAL income tax NOT modelled — the largest single component of the bill, varies enormously by canton (Zug/Schwyz low vs Geneva/Vaud high)
  • COMMUNAL/municipal income tax NOT modelled — levied as a multiplier (Steuerfuss) of the cantonal tax, a large further layer that varies by commune
  • church tax (Kirchensteuer/impot ecclesiastique, cantonal, members only) not modelled
  • the federal scale is a base-plus-marginal FORMULA per bracket; encoded here as flat marginal bands — small rounding vs the exact statutory table
  • the schedule is periodically INDEXED for cold progression (kalte Progression); 2026 thresholds should be re-verified against the exact ESTV/AFC table before use
  • married/registered-partner scale (Verheiratetentarif, more generous) not modelled — SINGLE-filer scale only
  • no CGT on private movable assets (separate regime; cantonal real-estate gains tax exists) — not part of this income pack
  • 35% federal withholding tax (Verrechnungssteuer) on dividends/interest, creditable/refundable, not modelled
  • AHV/IV/EO + ALV social contributions on employment income not modelled (not relevant to drawdown, but relevant to salary)
  • lump-sum taxation regime (forfait fiscal / taxation according to expenditure) for wealthy non-working foreigners not modelled — overrides ordinary income tax for qualifying arrivals
  • cantonal net-wealth tax (~0.05%-0.30%) not modelled — a real annual cost for a HNW retiree, separate from income tax
  • selfEmployment: no regime module — self-employed social contributions / business-income surcharges for this jurisdiction are not modelled

Source: Ember tax-rulepack dossier (CH — Ember tax-rulepack dossier §5.14 (CH — Switzerland), 2026-06-22, drawing on PwC )

CL — income tax (2026)next data review due 2027-01-01low confidence
  • Integrated corporate/personal tax system: dividends and business income carry a first-category corporate-tax credit (partial or full, depending on the SME/semi-integrated regime) against the Global Complementary Tax (IGC) — a credit mechanism, NOT modelled here (this pack treats income as if fully IGC-taxable with no imputation credit, over-stating tax on Chilean dividend/business income)
  • Capital gains and dividends are not a flat CGT; they flow into the IGC with the corporate credit — no separate savings/CGT schedule modelled
  • UTA/UTM indexing: bracket cutoffs are fixed multiples of the Unidad Tributaria Anual (13.5/30/50/70/90/120 UTA), which reprices monthly with CPI; the CLP figures here use a representative mid-2026 UTM approximately CLP 69,265 (UTA approximately CLP 831,180) and will drift from the live SII value
  • Bracket-level fixed statutory deductions (rebaja) that Chile applies per band are folded into the equivalent progressive-band representation here; the marginal-rate shape is preserved but the exact per-band subtraction constant is not carried separately
  • Employee social/pension contributions (AFP approximately 10% + admin, health/Fonasa or Isapre approximately 7%, capped at approximately 87.8 UF) are deductible before IGC and are NOT modelled — pre-tax base is over-stated for wage earners
  • Impuesto Unico de Segunda Categoria (the monthly withholding tax on employment income) has the same rate scale but a monthly UTM base; only the annual IGC scale is modelled
  • Foreign-tax-credit and non-resident Additional Tax (Impuesto Adicional, flat 35%) regimes not modelled
  • Inheritance/gift tax (progressive, exists) and VAT (19%) out of scope for income-tax pack
  • selfEmployment: no regime module — self-employed social contributions / business-income surcharges for this jurisdiction are not modelled

Source: Ember tax-rulepack dossier (CL — Ember tax-rulepack dossier 2026-06-22 §5.19 (CL — PwC WWTS, rev. 2025-12-19); UT)

CO — income tax (2026)next data review due 2027-01-01low confidence
  • Cedular system NOT modelled: Colombia taxes in separate baskets (general/labour+pension+capital+non-labour, then dividends, then occasional gains) each with its own rules; this pack applies the single Art. 241 general-cedula table to all income
  • Foreign-pension exemption up to 1,000 UVT (~COP 52,347,000/yr) NOT applied - materially over-taxes a UK pensioner
  • Cedular deductions/exempt income cap (40% of net income, max 1,340 UVT for the general cedula) NOT modelled
  • Dividend taxation is a separate schedule (progressive with 19% credit, or 35% if not corporately taxed) - not modelled
  • Occasional gains (CGT, inheritances, lottery) taxed separately at 15%/20-35% - not in this scale
  • UVT annual indexation not modelled (DIAN resets UVT each year; FY2026 = COP 52,374)
  • Uses tax-free ALLOWANCE (first 1,090-UVT 0% band subtracted), not a tax credit; bands re-based to post-allowance taxable income
  • Wealth tax (impuesto al patrimonio, 0.5-1.5% over 72,000 UVT; pending Constitutional Court proposal to cut threshold to 40,000 UVT and raise to 5%) not modelled
  • Mandatory social/health contributions (salud/pensión) not modelled — including on PENSION income: a retiree's mesada pays a graduated salud contribution of 4% (≤1 SMLMV) / 10% (>1–3 SMLMV, reduced from 12% by Art. 78 Ley 2294/2023) / 12% (>3 SMLMV) under Art. 204 Ley 100/1993, a real cash-flow reduction this projection omits (triage 2026-07-22)
  • selfEmployment: no regime module — self-employed social contributions / business-income surcharges for this jurisdiction are not modelled

Source: Ember tax-rulepack dossier (CO — Ember tax-rulepack dossier 2026-06-22 §5.18 (CO) + DIAN Estatuto Tributario Art.)

IT — income tax (2026)next data review due 2027-01-01low confidence
  • regional/municipal surcharges (1–3%) not modelled
  • 7% southern-Italy flat regime & €200k/€300k lump-sum regimes not modelled
  • no-tax-area deductions (tax credits) not modelled — over-states tax for low incomes
  • dividends and financial capital gains: Italy's flat 26% imposta sostitutiva (unchanged for 2026; crypto-asset gains are the exception, rising to 33%) is not modelled in this pack — dividends fall through to the ordinary IRPEF schedule (the separate cgtByCountry row does carry the 26% for gains)
  • selfEmployment: no regime module — self-employed social contributions / business-income surcharges for this jurisdiction are not modelled

Source: Ember tax-rulepack dossier §5.7 (IT — MEF/Agenzia Entrate)

ZA — income tax (2026)next data review due 2027-01-01low confidence
  • Primary rebate modelled as an effective 0% tax-free band (R95,750 = R17,235 / 0.18) — arithmetically EXACT at all incomes (upper band boundaries unchanged), so this is a representation choice, not an approximation
  • Medical scheme fees tax credits (Section 6A/6B, per-member monthly credits) not modelled — these are credits against tax, further reducing retiree liability
  • UIF (Unemployment Insurance Fund, 1% employee + 1% employer, capped) — social contribution, not modelled
  • SDL (Skills Development Levy, employer 1%) not modelled
  • Retirement fund contribution deductions (27.5% of income, cap R350,000/yr) not modelled
  • Interest exemption (R23,800 under 65 / R34,500 for 65+) not modelled
  • CGT via 40% inclusion rate x marginal (separate savings schedule) not modelled here
  • retirement lump-sum benefit tables NOT modelled — SARS taxes retirement-fund lump sums on a SEPARATE cumulative table (first R550,000 @0%, R550,001–770,000 @18%, R770,001–1,155,000 @27%, above @36%), distinct from the ordinary brackets. The engine currently adds pension lump sums to the pot 100% tax-free (legacy non-UK lump-sum path), so a ZA lump sum ABOVE R550,000 is mildly UNDER-taxed; below R550,000 the tax-free treatment happens to match (triage 2026-07-22)
  • No provincial/municipal income-tax layer in ZA (national tax only)
  • Bracket indexing / annual fiscal-drag adjustments not modelled
  • selfEmployment: no regime module — self-employed social contributions / business-income surcharges for this jurisdiction are not modelled

Source: Ember tax-rulepack dossier (ZA — Ember tax-rulepack dossier §5.28 (ZA — PwC WWTS South Africa, 2026/27, rev. 2026)

AU — income tax (2026)next data review due 2027-01-01medium confidence
  • 2% Medicare levy (flat levy on taxable income, with a low-income shade-in range) not modelled — a resident's true effective rate is ~2pp higher than these bands imply
  • Medicare Levy Surcharge (1%-1.5% extra for high earners without private hospital cover) not modelled
  • Low Income Tax Offset (LITO, up to A$700, tapering) not modelled — this reduces tax at the bottom, so the pack slightly OVER-states tax for low incomes
  • no separate CGT schedule — AU taxes capital gains at marginal rates with a 50% discount for assets held >12 months (handled in CgtRates, not here)
  • superannuation pension/lump-sum drawdowns for those aged 60+ from a taxed fund are generally TAX-FREE and are NOT represented by these bands (see notes — material for retirees)
  • resident vs non-resident scale: non-residents have NO tax-free threshold and a different first band (32.5%/30%) — only the RESIDENT scale is encoded
  • bracket indexing: the 16% rate stepped down to 15% (1 Jul 2026, in force for FY2026-27) and is legislated to fall further to 14% (1 Jul 2027); this pack now holds the FY2026-27 15% rate
  • franking (imputation) credits not modelled — the 30%/25% company tax pre-paid on fully-franked dividends is creditable and excess credits are refundable in cash (unchanged 2026), so this pack OVER-taxes Australian franked dividend income, possibly heavily
  • selfEmployment: no regime module — self-employed social contributions / business-income surcharges for this jurisdiction are not modelled

Source: Ember tax-rulepack dossier (AU — Ember tax-rulepack dossier §5.26 (AU) — PwC Worldwide Tax Summaries, Australia, )

BE — income tax (2026)next data review due 2027-01-01medium confidence
  • municipal surcharge (~7%) not modelled
  • tax-free sum modelled as a 25% tax credit (belastingvermindering) — matches the reduction method
  • savings-income exemption (€1,020 interest exemption) not modelled
  • dividends/interest: Belgium's flat 30% roerende voorheffing (final withholding for most residents; only the first €833 of dividends per person per year is reclaimable via the return, 2026) is not modelled — dividends here fall through to the ordinary income schedule instead
  • capital gains tax on financial assets (NEW, in force 1 Jan 2026): Belgium's 10% flat levy ('solidarity contribution') on realised gains on shares/bonds/ETFs/crypto/gold — ~€10,000 indexed annual exemption (unused portion carried forward €1,000/yr, cap €15,000), cost basis = 31 Dec 2025 portfolio snapshot so only post-2025 appreciation is taxed — is NOT modelled; the pack computes zero CGT, which UNDER-states tax for a retiree realising portfolio gains (triage 2026-07-22)
  • selfEmployment: no regime module — self-employed social contributions / business-income surcharges for this jurisdiction are not modelled

Source: Ember tax-rulepack dossier §5.9 (BE — SPF Finances)

BR — income tax (2026)next data review due 2027-01-01medium confidence
  • Models the DEFINITIVE ANNUAL liability (ajuste anual, Lei 15.270/2025 Art. 11-A) as synthetic effective brackets: income up to R$60.000/yr exempt, taper to R$88.200 at effective 27.5575%/31.5575%, then the 27.5% top rate. See the header derivation.
  • Monthly withholding (IRRF mensal) timing NOT modelled: in-year withholding (tabela mensal + Art. 3o-A monthly redutor, ×12) is HIGHER than the definitive annual liability and reconciles at the annual return as a refund (restituição). This pack models the definitive Art. 11-A annual liability, not the cash-flow timing of withholding.
  • INSS social security contributions (progressive ~7.5%-14%, wage-capped) -- mandatory payroll deduction, not modelled; substantially reduces the taxable base for employees/pensioners (would lower tax further).
  • Desconto simplificado: the ANNUAL 20%-of-income discount capped at R$17.640,00 is baked into the synthetic brackets (it is the standard election). Itemised legal deductions (dependants R$2.275,08 each, education R$3.561,50, health, private-pension PGBL up to 12%) are NOT modelled -- taxpayers whose legal deductions exceed the 20%-capped simplified discount pay LESS than this pack shows.
  • Lei 15.270/2025 high-income provisions NOT modelled: (a) 10% withholding (IRRFDIV) on dividends over R$50.000/mo from a single payer; (b) the minimum tax on high incomes (IRPFM) phasing in over R$600.000/yr up to full at R$1.200.000/yr. Both are out of scope here.
  • Capital gains taxed on a separate progressive 15%-22,5% schedule (not this table).
  • State ITCMD inheritance/gift tax (up to 8%) and municipal ITBI property transfer (up to 3%) are separate, not income tax.
  • No wealth tax in Brazil.
  • Single-filer basis; Brazil allows joint/separate election with dependant deductions -- not modelled.
  • carne-leao (mandatory monthly self-assessment on foreign-source income, incl. UK pensions) -- mechanics not modelled; the simplified-discount election above may not apply to all foreign-source income.
  • selfEmployment: no regime module — self-employed social contributions / business-income surcharges for this jurisdiction are not modelled

Source: Lei no 15.270, de 26 de novembro de 2025 (Art. 11-A redução ANUAL: até R$2.694,15 até R$60.000; R$8.429,73 - 0,095575 × rendimentos para R$60.000,01-R$88.200,00; desconto simplificado anual majorado para R$17.640,00; Art. 3o-A redução mensal; Art. 8o efeitos 1o-jan-2026); LEI No 15.270, de 26 de novembro de 2025 -- publicação original (Câmara dos Deputados): confirma verbatim a tabela do Art. 11-A (redução anual); Receita Federal -- Tributação de 2026: tabela progressiva ANUAL (ano-calendário 2026; isento <= R$29.145,60; 7,5/15/22,5/27,5% com parcelas R$2.185,92 / R$4.729,91 / R$8.105,85 / R$10.904,66) e desconto simplificado anual 20% limitado a R$17.640,00; tabela MENSAL (parcelas 182,16/394,16/675,49/908,73; simplificado 607,20); Receita Federal -- Exemplos de Aplicação da Lei 15.270/2025 (mensal: R$5.000 -> R$0; R$7.607,20 -> R$1.016,27)

CA — income tax (2026)next data review due 2027-01-01medium confidencefederal floor only
  • PROVINCIAL/TERRITORIAL income tax — NOT modelled; each province/territory levies its own progressive scale on top of federal, pushing combined top rates to ~44.5%-54.8% and combined rates on ordinary/pension income for a typical retiree well above federal-only. This is the DOMINANT gap.
  • BPA high-income taper: the federal BPA is reduced for incomes in the top bracket (from ~CAD 16,340 down to ~CAD 14,538) — not modelled (full BPA assumed for all)
  • capital gains 50% inclusion-rate mechanism (half the gain enters income at marginal rates) — not modelled here (separate CGT schedule)
  • Canadian dividend gross-up + dividend tax credit (eligible 38% / non-eligible 15%) — not modelled
  • CPP/QPP and EI contributions — not modelled (largely irrelevant to a drawdown retiree but affects working income)
  • OAS clawback (Recovery Tax, 15% on income above ~CAD 90k threshold) — NOT modelled; materially affects higher-income retirees
  • pension income credit, age credit, and pension income splitting for seniors — not modelled (would REDUCE a retiree's real tax below this federal-only figure)
  • Quebec operates a separate provincial tax system with a federal abatement — not modelled
  • annual bracket indexation to CPI — thresholds are 2026 point-in-time estimates
  • selfEmployment: no regime module — self-employed social contributions / business-income surcharges for this jurisdiction are not modelled

Source: Ember tax-rulepack dossier (CA — Ember tax-rulepack dossier §5.16 (CA — Canada), from PwC WWTS Canada (taxes on p)

DE — income tax (2026)next data review due 2027-01-01medium confidence
  • the 14%→42% progressive zone (§32a continuous formula) is fitted piecewise-linearly (10 sub-bands whose rates are exact average marginals) — exact at each band boundary, worst mid-band error ~€45 (guarded by a §32a boundary test); the statute's floor-to-full-euro rounding of zvE and tax is not reproduced (sub-euro effect)
  • §32a coefficients are the ENACTED 2026 values (SteFeG Art. 2, BGBl. 2024 I Nr. 449; reconciled against the statute 2026-07-19 — Grundfreibetrag €12,348, zone edges €17,799 / €69,878 / €277,825). The former €68,429-vs-€68,480 discrepancy note is resolved: both were 2025-era figures; the 2026 42%-band edge is €69,878/€69,879
  • Solidaritätszuschlag (5.5% of tax above the 2026 Freigrenze — €20,350 single / €40,700 joint tax amount — with a milder zone) not modelled
  • church tax (Kirchensteuer, 8–9% of tax for members) not modelled
  • Ehegattensplitting modelled via 2×Grundtarif(zvE÷2) (§26b, §32a Abs. 5) — optimal only within the modelled pure-tariff scope; Faktorverfahren and Witwensplitting/Gnadensplitting first-year survivor relief not modelled; Abgeltungsteuer items correctly excluded from splitting; the joint Sparer-Pauschbetrag (€2,000) is moot while Abgeltungsteuer is unmodelled. Under splitting the linear §32a fit is evaluated at half the joint income and doubled, so the couple-level fit error can reach ~2× the single mid-band error (order ~€100s/yr near €100–140k combined income), always in the conservative (over-stating) direction
  • Progressionsvorbehalt (§32b — exempt foreign income raises the rate on domestic income) not modelled; the joint German rate may be understated when either spouse has exempt foreign income
  • employee social contributions (pension/health/care/unemployment, ~20% capped) not modelled
  • Abgeltungsteuer (26.375% flat on interest/dividends/gains) is a separate savings schedule, not modelled
  • pension taxable-portion cohort rules (Alterseinkünftegesetz) not modelled
  • selfEmployment: no regime module — self-employed social contributions / business-income surcharges for this jurisdiction are not modelled

Source: Ember tax-rulepack dossier §5.4 (DE — PwC WWTS); §32a EStG (enacted 2026 tariff — SteFeG Art. 2, BGBl. 2024 I Nr. 449; W3 reconciliation, external check: Grundtabelle 2026 zvE €60,000 → €14,233 reproduced exactly)

ES — income tax (2026)next data review due 2027-01-01medium confidence
  • mínimo personal (€5,550) modelled as a tax credit at 19% (scale(base)−scale(5,550) mechanic) — matches Spain's method; regional mínimo variation still not modelled
  • autonomous-community scale variation not modelled (single combined default scale; Madrid lower, Catalonia/Valencia higher)
  • savings-income schedule (renta del ahorro 19–30%) not modelled — dividends/interest/gains fall on the general scale here instead of the separate schedule
  • Beckham regime (flat 24% to €600k for qualifying new arrivals) not modelled
  • IRNR non-resident rental modelled as flat 24% gross / 19% EU-EEA net (nonResidentRental module) — renta imputada on non-let periods (Art. 24.5), the Art. 46 IRPF-option election, and the pending TS appeal on non-EU expense deductibility are not; the EU-net base reuses the vacancy+maintenance haircut as a coarse expense proxy
  • 2026 reconciliation DONE (2026-07-19, AEAT/BOE primary sources): general state scale (9.5/12/15/18.5/22.5/24.5 halves), mínimo personal €5,550, IRNR 24%/19% and the Patrimonio+ITSGF stack all VERIFIED-unchanged under the PGE-2025 prórroga; the savings scale was corrected to 27% (€200k–300k) / 30% (>€300k) per Ley 7/2024. RD-ley 5/2026 (17 Feb, BOE 19-2-2026, art. 28) adds a low-income work deduction (€590.89 up to €17,094, tapering to nil at €20,048.45) — not modelled, like the €2,000 otros gastos it sits beside
  • tributación conjunta (joint filing) not modelled — a joint declaration reduces the base by €3,400 (two-parent) / €2,150 (single-parent) per year (Arts. 82–84 LIRPF, unchanged 2026); jointFiling is only modelled for DE/FR/US
  • autónomo cuota approximated as a band, not the real income-based monthly quota (draft/low)
  • small-company 23% corp rate not modelled (flat 25%)
  • savings-scale dividend tax approximated
  • wealth tax: regional variation not modelled — the state Art. 30 scale is wired; Madrid/Andalucía 100% bonificación (≈zero IP below ~€3M net wealth), Cataluña/Valenciana/Balears exemption variants, the €300,000 habitual-residence exemption and the pension-rights exemption are all unrepresented (overstates the €700k–€3M window for bonificación regions; the ISGF floor above €3M applies nationally either way)

Source: Ember tax-rulepack dossier §5.3 (ES — combined default general scale; AEAT / PwC); BOE — Ley 19/1991, del Impuesto sobre el Patrimonio (state Art. 30 scale); BOE — Ley 38/2022 (ISGF / solidarity tax; indefinite per RDL 8/2023); W3 2026 reconciliation — AEAT IRPF manual (gravamen estatal, prórroga PGE 2025) + Ley 7/2024 df 7ª (savings top 30% > €300k) + RD-ley 5/2026 art. 28 (low-income work deduction, not modelled)

GR — income tax (2026)next data review due 2027-01-01medium confidence
  • EFKA social security contributions (employee/self-employed contributions on earned income) not modelled — do NOT apply to pension drawdown, so no NL-style combined IT+NI retiree over-taxation risk
  • special solidarity contribution (eisfora allilengyis — largely suspended/abolished for most income since 2023, but flagged as out of scope)
  • family/dependent-children reduced scales and under-30 reduced rates not modelled (single/childless scale used)
  • Art. 16 tax reduction MODELLED at the €777 single/childless base with the €20/€1,000 taper over €12,000 (Queue B7 — effective tax-free point ~€8,633). Family variants (~€810–€1,340 by children, Law 5246/2025 under-30 uplifts) NOT modelled; the credit's taper keys on total scale income in-engine (statutorily employment/pension income — exact whenever only pension income rides this scale)
  • separate rental-income progressive scale (15/25/35/45%) not modelled — this pack is for employment/pension income only
  • 7% flat-tax regime for new-resident foreign pensioners (15 years, all foreign income incl. pensions) not modelled — MAJOR lever for expat retirees
  • €100,000 non-dom lump-sum regime for HNW foreign-source income not modelled
  • investment income taxed on separate schedules (securities/dividends 5%, interest/capital gains 15%) not modelled — this pack covers the unified employment/pension scale only
  • no indexing/inflation-adjustment logic (statutory 2026 brackets under Law 5246/2025)
  • selfEmployment: no regime module — self-employed social contributions / business-income surcharges for this jurisdiction are not modelled

Source: Ember tax-rulepack dossier (GR — Ember tax-rulepack dossier §5.7 (GR — Greece), 2026-06-22 DRAFT, citing PwC WWTS); Queue-B verification record (GR Art. 16 KFE €777 childless credit + €20/€1,000 taper over €12,000 — primary-sourced, recheck 5/5)

IE — income tax (2026)next data review due 2027-01-01medium confidence
  • tax credits MODELLED conditionally (B1b): personal €2,000 unconditional; Employee/PAYE €2,000 only against qualifying PAYE-source income (Irish/untagged pensions, EU state pensions), capped at 20% of it. Conservative edges: UK social-security pensions get NO employee credit (Revenue's list names EU member states — the TCA social-security protocol MAY extend it; over-tax ≤€2,000, seek advice) and the Earned Income Credit for trading income is not modelled
  • USC (Universal Social Charge, ~0.5%-8% banded, ~3%-4.5% surcharge on self-employed >€100k) applies on top and is NOT modelled
  • PRSI (~4.1% Class A) applies on top for working-age earners and is NOT modelled (generally does not apply to most pension/drawdown income and ceases at age 66)
  • standard-rate cut-off band VARIES by family status (single €44,000; married/civil one-earner ~€53,000; two-earner up to ~€88,000) — single-filer scale only
  • age exemption for 65+: income fully exempt below €18,000 single / €36,000 married — NOT modelled
  • 25% pension tax-free lump sum (cap €200k tax-free / €500k @20% band) — NOT modelled
  • remittance basis for non-Irish-domiciled residents (foreign income/gains taxed only when remitted) — NOT modelled
  • DIRT (33% on deposit interest) and 33% flat CGT are separate schedules — NOT modelled
  • bands not indexed automatically — figures are 2026 and must be re-verified annually
  • selfEmployment: no regime module — self-employed social contributions / business-income surcharges for this jurisdiction are not modelled

Source: Ember tax-rulepack dossier (IE — Ember tax-rulepack dossier §5.8 (IE — PwC WWTS Ireland, taxes on personal income); Revenue.ie — Employee Tax Credit (qualifying PAYE-income list incl. occupational pensions/DSP/EU state pensions; 20%-of-income cap under €10,000); Revenue.ie — Earned Income Credit (excludes passive/investment income — the pure-investment cohort gets the personal credit only)

IN — income tax (2026)next data review due 2027-01-01medium confidence
  • §87A rebate + marginal relief MODELLED (taxRebate module) and s.16(ia) Rs 75,000 standard deduction MODELLED for pension income (Queue B3): pensioner NIL threshold Rs 12,75,000. Salary income does not receive the SD in-engine yet (retiree cohort focus); a family/other-sources annuity is over-relieved by ≤Rs 75,000
  • Health & Education Cess of 4% is applied on top of tax+surcharge; not modelled (understates total liability by ~4% of tax).
  • Surcharge 10%-37% on high incomes (capped at 25% under the new regime; 15% cap on LTCG/dividends); not modelled.
  • OLD regime (with Chapter VI-A deductions such as 80C, 80D, HRA, standard deduction Rs 75,000, and its separate slab structure 0/5/20/30 with Rs 2.5L basic exemption) is not supported; only the NEW default regime is encoded.
  • Marginal relief on the SURCHARGE (high incomes) not modelled — the §87A marginal relief IS modelled.
  • Capital gains taxed under separate schedules (LTCG 12.5%, STCG 20% on listed equity, post-Jul 2024) — not part of this income-tax band schedule.
  • No wealth tax (abolished 2015) and no inheritance/estate tax (abolished 1985) — correctly nothing to model.
  • Slab thresholds are set by annual Finance Act, not statutorily indexed to inflation.
  • selfEmployment: no regime module — self-employed social contributions / business-income surcharges for this jurisdiction are not modelled

Source: Ember tax-rulepack dossier (IN — Ember tax-rulepack dossier §5.25 (IN — India), 2026-06-22 DRAFT, citing PwC WWTS); Queue-B verification record (§87A Rs 60k/12L + marginal relief break-even Rs 12,70,588; s.16(ia) Rs 75k — primary-sourced, recheck 5/5)

JP — income tax (2026)next data review due 2027-04-01medium confidence
  • inhabitants tax (住民税) folded into the band rates at a flat 10% — its own smaller basic deduction (¥430,000 vs the ¥620,000 modelled), the ~¥5,000 per-capita levy (incl. forest environment tax) and its prior-year assessment timing are not modelled (net effect ≈ ±¥25k/yr)
  • basic deduction modelled at the permanent ¥620,000 (FY2026 reform base) — the temporary 2026–2027 top-ups (up to ¥1,040,000 below ¥4.89M total income) are NOT applied (conservative over-statement ≤ ~¥63k/yr through 2027), and the high-income taper (¥480k→¥320k→¥160k→0 above ¥23.5M total income) is not applied (under-states only above ¥23.5M)
  • 公的年金等控除 modelled for state/government-service pensions (rental/pension honesty slice, 2026-07-20) with the standard 'other income ≤ ¥10M' table — the higher-other-income variants (minimum drops to ¥1.0M/¥0.9M) are not modelled; qualified CORPORATE plan annuities (also 公的年金等) are indistinguishable from private annuities in this model and stay undeducted (over-taxed — conservative); survivor pensions (遺族年金) are tax-exempt in Japan but are taxed like ordinary pension income here (conservative)
  • employment-income deduction (給与所得控除, 2026 floor ¥690,000) not modelled (retiree-focused pack — salaried users are over-taxed by the missing deduction)
  • social-insurance premiums (national health, long-term care, nenkin) are separate levies, not modelled; their income-deductibility (社会保険料控除) is also not modelled (small conservative bias)
  • spouse/dependant deductions, the dividend aggregate-taxation option with 配当控除, and furusato nozei not modelled
  • corporation tax not modelled (JP national 23.2% + local enterprise taxes)
  • selfEmployment: no regime module — self-employed national health/pension quotas and the blue-return deduction are not modelled
  • exit tax (国外転出時課税 — deemed-disposal on ≥¥100M financial assets when leaving after 5+ resident years) not modelled
  • from 2027 the 2.1% reconstruction surtax re-splits into 1.1% reconstruction + 1.0% defence surtax — the combined burden is unchanged, so ×1.021 stays correct
  • FY2026-reform figures rest on the 26 Dec 2025 大綱 as implemented by the NTA (施行 1 Dec 2026); re-verify the final enacted text at next review

Source: NTA No.2260 所得税の税率 (national brackets, unchanged 2013–2037); NTA 令和8年度 基礎控除見直し (FY2026 reform: permanent base ¥620,000; temporary 2026–27 top-ups); NTA 復興特別所得税 (2.1% reconstruction surtax, multiplicative on national tax, 2013–2037); NTA No.1600 公的年金等の課税関係 (public-pension deduction table, 令和2年分以後 — worked example ¥3.5M → ¥2.35M); Tokyo Metropolitan Tax Bureau — 個人住民税 (10% = 6%+4%; ¥5,000 per-capita incl. forest tax; prior-year basis)

MX — income tax (2026)next data review due 2027-01-01medium confidence
  • cuota fija (fixed quota per band) not modelled — approximation using marginal rate only
  • IMSS/ISSSTE social security not modelled
  • annual bracket limits are illustrative — SAT updates yearly via DOF; verify current year
  • dividends: Mexico's additional 10% final withholding on dividends to resident individuals (post-2013 corporate profits, non-creditable, on top of company-level tax) is not modelled
  • pension exemption (Art. 93 fr. IV/V LISR) not modelled — retirement, pension and annuity income is exempt up to 15 UMA/day (2026: ≈ MXN 53,493/month ≈ MXN 642,000/year, aggregate across all pensions; only the excess is taxable). The pack taxes an MX-SOURCE pension on the full tarifa from MXN 0, materially over-taxing MX-source pensioners. FOREIGN pensions are treaty-governed and typically do NOT qualify for this MX exemption (triage 2026-07-22)
  • selfEmployment: no regime module — self-employed social contributions / business-income surcharges for this jurisdiction are not modelled

Source: Ember tax-rulepack dossier §5.14 (MX — SAT Art. 152)

NL — income tax (2026)next data review due 2027-01-01medium confidence
  • bracket-1 rate (35.75%) FOLDS IN national insurance (8.10% income tax + 27.65% NI) — the working-age combined burden; AOW-age residents take the separate 17.85% art. 2.10a schedule via statePensionAgeIncomeTax
  • working-age heffingskortingen (algemene heffingskorting max €3,115 + arbeidskorting) not modelled — over-states tax for pre-AOW residents at low/mid incomes; the AOW-age variants ARE modelled (statePensionAgeIncomeTax credits)
  • AOW age pinned at 67 (2026 enacted value) — drifts upward with life expectancy in later years; an unknown filer age keeps the working-age table (conservative over-tax)
  • Box 3 (deemed-return tax on savings & investments) is modelled SEPARATELY via the CGT deemed_return mechanism (cgtByCountry NL: 6% asset / 2.7% debt forfaits above the €59,357 allowance / €3,800 debt drempel, 36%, apportioned) — a resident's investment pot and own-situs rental property (at full value; leegwaarderatio not modelled) are charged there, not in this income pack; the bank-deposit forfait (1.28%) and foreign-situs rental Box-3 top-up are not modelled
  • Box 2 (substantial-interest, 24.5%/31%) not modelled
  • 30%/27% expat ruling not modelled
  • selfEmployment: no regime module — self-employed social contributions / business-income surcharges for this jurisdiction are not modelled

Source: Ember tax-rulepack dossier §5.9 (NL — PwC WWTS)

PT — income tax (2026)next data review due 2027-03-31medium confidence
  • dedução específica (€4,587.09) modelled as the ordinary-stack allowance — it legally belongs to Cat A employment + Cat H pension income only, so business income in the ordinary stack is over-shielded by up to ~€2.4k tax; the Cat A variant that rises above the floor with higher mandatory social contributions is not modelled
  • mínimo de existência (Art. 70 — guarantees a post-tax floor for low salary/pension earners) not modelled: low-income earners are over-taxed here (conservative)
  • deduções à coleta (health/education/housing/general-family credits, IRS Jovem under-35 relief) not modelled — over-states tax for entitled filers (conservative)
  • tributação conjunta (optional joint taxation with the quociente conjugal divisor 2) not modelled — spouses keep independent single-filer stacks (the statutory default since 2015; joint election usually helps single-earner couples)
  • englobamento elections not modelled: Cat E savings income may opt into the progressive scale (with 50% dividend inclusion under Art. 40.º-A — favourable roughly below ~€24k taxable), Cat F rental likewise; the flat autonomous rates modelled are the statutory defaults
  • Cat F long-contract reduced rates (15% at 5–10yrs, 10% at 10–20yrs, 5% at 20+yrs, −2pp renewal bonuses), the TEMPORARY 2026–2029 moderate-rent 10% regime (rent ≤ €2,300/mo — DL 97/2026) and the RSAA 0% accessible-rent exemption are not modelled — long-lease landlords are over-taxed at the flat 25% (conservative); the 28% non-residential rental rate is also not modelled (commercial landlords under-taxed by 3pp)
  • IFICI (NHR 2.0, EBF Art. 58.º-A): 20% flat on eligible-profession Cat A/B income + broad foreign-income exemption for qualifying new residents (10 years) not modelled — but note foreign PENSIONS get NO IFICI relief (taxed at the normal progressive scale; the old NHR 10% pension rate is gone for new applicants)
  • regime fiscal para ex-residentes (Art. 12.º-A, 'Programa Regressar'): 50% Cat A/B exclusion (capped €250k/yr) for returning ex-residents through 2026 cohorts not modelled; the 2027+ 'Voltar' successor is not yet enacted
  • 35% aggravated rate on income from blacklisted jurisdictions not modelled
  • social contributions not modelled (retiree-focused pack): employee 11% / employer 23.75% on employment income; pensions bear NO social contributions; trabalhadores independentes quarterly regime (~21.4% on 70% of relevant income) also unmodelled — selfEmployment has no regime module
  • corporation tax (IRC) not modelled
  • regional Açores/Madeira reduced IRS scales not modelled — the mainland (Continente) scale is assumed (over-taxes island residents; conservative)
  • solidarity surtax folded into the marginal bands on the same rendimento-coletável base — exact for single filers; under a (unmodelled) joint election the statute applies it after the quociente, which would differ

Source: OE2026 — Lei n.º 73-A/2025, de 30 de dezembro (2026 CIRS Art. 68 scale: ×1.0351 indexation per Art. 68.º-B + −0.30pp on brackets 2–5); Lei n.º 55-A/2025, de 22 de julho (mid-2025 IRS rate cut — brackets 1–8); Portaria n.º 480-A/2025/1, de 30 de dezembro (IAS 2026 = €537.13 ⇒ dedução específica 8.54×IAS = €4,587.09); CIRS Arts. 68.º-A (taxa adicional de solidariedade 2.5%/5%), 71–72 (taxas liberatórias/especiais 28%; Cat F 25%), 41 (Cat F expenses), 25/53 (dedução específica); PwC Worldwide Tax Summaries — Portugal, individual taxes (corroboration: 2026 scale, 28% Cat E, 25% Cat F, solidarity surtax)

SE — income tax (2026)next data review due 2027-01-01medium confidence
  • sliding grundavdrag (basic deduction) not modelled — allowanceMinor=0 taxes income at 32% municipal from the first krona, systematically OVER-taxing every Swedish resident and especially pensioners: the under-66 grundavdrag shields up to SEK 45,600 and the age-66+ förhöjt grundavdrag up to SEK 179,100 (base 65,800), none of which is applied. Retiree/pension projections are over-taxed (triage 2026-07-22)
  • kapitalinkomst partially modelled: DIVIDENDS now take the flat 30% (dividendTax) and realised gains the flat 30% via cgtByCountry; INTEREST still has no engine category (a retiree's bank/bond interest entered as drawdown/ordinary income rides the 32%/52% earned bands — over-taxed below the skiktgräns), and private rental (statutorily kapital at 30% after the SEK 40,000 + 20%-of-rent schablonavdrag) stays on the earned schedule (triage 2026-07-22)
  • fåmansföretag 3:12 dividends (20% within gränsbelopp) not modelled — the flat 30% retail-investor rate applies to all dividends
  • municipal rate variation (typically 29–35%) collapsed to 32% national average
  • ISK/AF accounts (schablonbeskattning flat-yield regime) not modelled
  • selfEmployment: no regime module — self-employed social contributions / business-income surcharges for this jurisdiction are not modelled

Source: Ember tax-rulepack dossier §5.11 (SE — Skatteverket)

TH — income tax (2026)next data review due 2027-01-01medium confidence
  • remittance basis for foreign-source income (2024 rule change + 2025 easing proposals) — foreign pension/investment income is taxed ONLY if remitted to Thailand in the year; not expressible in a pure resident-band pack and materially affects non-remitting retirees
  • the three core shields ARE modelled (Queue B4): 50%/THB 100k expense deduction on pension/employment income, THB 60,000 personal allowance, over-65 THB 190,000 exemption (needs a known age). STILL not modelled: spouse THB 60,000, insurance/provident-fund/RMF/SSF deductions, child allowances
  • social security contributions (employee ~5% capped, monthly cap ~THB 750) not modelled
  • inheritance tax (10%, or 5% ascendant/descendant, over THB 100m; spouse exempt) is a separate schedule, not modelled
  • no wealth tax (correctly, none exists) and Thai SET capital gains exemption / property transfer taxes (2% transfer fee + SBT/stamp) not modelled
  • no bracket indexing/inflation adjustment modelled — thresholds are static
  • selfEmployment: no regime module — self-employed social contributions / business-income surcharges for this jurisdiction are not modelled

Source: Ember tax-rulepack dossier (TH — Ember tax-rulepack dossier §5.22 (TH — PwC WWTS Thailand, rev. 2026-02-02) [TH-I); Queue-B verification record (TH: 50%/100k expense + 60k allowance + 65+ 190k exemption, PND.91 order — primary-sourced, recheck 5/5)

US — income tax (2026)next data review due 2027-01-01medium confidence
  • federal only — state income tax not modelled; under joint filing, state tax is computed per spouse on each spouse's own income with the single-filer schedule — exact for flat/no-tax states, slightly over-states for unequal-earner couples in graduated states whose MFJ brackets are ~2× single (e.g. CA, NY)
  • standard deduction and bracket thresholds updated 2026-07-15 to IRS Rev. Proc. 2025-32 2026 figures (2026-07-15 Opus-verified correction)
  • FICA (Social Security + Medicare) not modelled
  • MFJ modelled via jointFiling table (IRS Rev. Proc. 2025-32, TY2026); MFS and Head-of-Household not modelled; no MFJ income phase-outs modelled; E2 overrides patch the single schedule only, not the MFJ table
  • age-65 senior deductions ARE modelled (§63(f) aged additional + OBBBA §151(d)(5) bonus through 2028, MAGI-phased per individual) on residence stacks via the simulator; single-filer dividend stacking DOES see the deduction. Remaining gaps: cgtOnGainStacked's ordinary baseline stays pre-deduction; under MFJ, dividend stacking uses per-owner single-filer breakpoints and does not see the joint senior deduction (conservative); blindness additions and the Qualifying-Surviving-Spouse status are not modelled (a 65+ widow(er) files as unmarried, $2,050); MAGI is approximated as the return's residence-stack taxable income + dividends (§911/§931/§933 foreign-exclusion add-backs unmodelled)
  • AMT not modelled
  • OASDI wage base 2026 to verify against the SSA figure
  • qualified-dividend brackets approximate (single filer); under joint filing each spouse's dividends stack on their OWN ordinary income against single-filer breakpoints, so the QDI/LTCG rate may be mis-estimated in either direction for unequal-earner couples (the true breakpoint is a function of combined taxable income)
  • NIIT 3.8% not modelled (MFJ threshold $250k — below 2× single)

Source: Ember tax-rulepack dossier §5.24 (US — IRS/OBBBA); IRS Rev. Proc. 2025-32 — TY2026 inflation adjustments (MFJ brackets + $32,200 standard deduction; OBBBA P.L. 119-21); IRS Rev. Proc. 2025-32 §2.14(3) — TY2026 §63(f) aged additional standard deduction ($1,650; $2,050 unmarried non-surviving-spouse); IRC §151(d)(5) (OBBBA P.L. 119-21 §70103) — $6,000/qualified individual 65+, per-individual 6% MAGI phase-out over $75k/$150k, taxable years before 2029

VN — income tax (2026)next data review due 2027-01-01medium confidence
  • dependant deduction (VND 6.2m/month = VND 74.4m/year per registered dependant, raised from VND 4.4m/month) NOT modelled — only the personal deduction is encoded as the allowance; a taxpayer with dependants is over-taxed by this pack
  • 5-band reform now IN FORCE: Law 109/2025/QH15 replaced the old 7-band scale with the current 5-band scale (5/10/20/30/35% at annualised 120/360/720/1,200m VND) effective 1 Jul 2026 — wired 2026-07-15 (Opus-verified correction)
  • compulsory social/health/unemployment insurance employee contributions (deductible before PIT) not modelled
  • flat schedular rates NOW modelled for dividends (5% of gross via dividendTax) and portfolio-drawdown securities transfers (0.1% of gross proceeds via schedularInvestment); still NOT modelled: real-estate transfer 2% of gross proceeds (property sales ride the CGT/sale path, which encodes VN securities 0.1% on GAIN — an understatement for RE), inheritance 10% over threshold, and the 50% PIT reduction on securities/REIT fund dividends (ordinary company dividends stay 5%)
  • interest income has NO engine category: individual bank/credit-institution deposit interest is PIT-EXEMPT (would need no charge) while non-bank interest is 5% flat — a retiree's interest currently rides whatever category it is entered under; enter bank interest as non-taxable, not as dividend
  • personal deduction is treated as a flat allowance rather than as the statutory monthly deduction (VND 15.5m/month, raised from VND 11m/month by Law 109/2025/QH15) — annual figure assumes 12 full months of residence/eligibility
  • no indexation modelled; deduction amounts are fixed nominal figures that the National Assembly periodically resets
  • VND currency registry entry (exponent 0, symbol dong) must be added to the currency registry before this pack ships — flagged as a gap in the dossier
  • pension income exemption NOT modelled — Vietnamese Social Insurance Fund pensions, monthly voluntary/supplementary pension payments, AND pensions paid by a FOREIGN entity to a VN tax resident are all PIT-EXEMPT (exempt-income list carried into Law 109/2025/QH15). This pack routes pension drawdown through the progressive 5–35% schedule, so a VN-resident retiree drawing a Vietnamese OR foreign (e.g. UK) pension is over-taxed — real VN PIT on that pension income is zero. Do not rely on VN projections for a pension-drawdown retiree until the exemption is modelled (triage 2026-07-22)
  • selfEmployment: no regime module — self-employed social contributions / business-income surcharges for this jurisdiction are not modelled

Source: Ember tax-rulepack dossier (VN — Ember tax-rulepack dossier 2026-06-22 §5.24 (VN — PwC WWTS Vietnam, rev. 2026-03)

AE — income tax (2026)next data review due 2027-01-01approximate
  • UAE Free Zone 0% qualifying-income regime not modelled
  • no personal dividend or self-employment social charge (correct for UAE)

Source: UAE Federal Tax Authority — individuals

CZ — income tax (2026)next data review due 2027-01-01approximate
  • sleva na poplatníka taxpayer credit (CZK 30,840) modelled as a flat 15% tax credit — matches reality
  • pension exemption MODELLED for statutory pensions (state/government-service buckets) up to CZK 806,400/yr — a private-scheme regularly-paid annuity that legally qualifies under §4(1)(g) is conservatively NOT exempted (over-tax direction); statutory §16 rounding (base down to whole hundred CZK, tax to whole CZK) not modelled (sub-crown)
  • social insurance contributions not modelled
  • selfEmployment: no regime module — self-employed social contributions / business-income surcharges for this jurisdiction are not modelled

Source: Ember tax-rulepack dossier §5.25 (CZ); Accace: Minimum, average and guaranteed wage CZ 2026 (CZK 22,400/mo ⇒ 36× = CZK 806,400 pension exemption); KPMG GMS Flash Alert 2026-046 — CZ 2026 employee taxation (bands seam, wage figures); gov.cz INF-295 — cross-border EU pensioners: treaty-CZ-taxable pensions follow Czech law incl. §4

FR — income tax (2026)next data review due 2027-01-01approximate
  • quotient conjugal (2 parts) modelled for spouse households via 2×barème(RI÷2) (CGI Art. 6-4, 193, 194; imposition commune assumed mandatory — the Art. 6-4 a–c exceptions presuppose non-cohabitation and the Art. 6-5 marriage-year election is immaterial to a multi-decade projection); per-child half-parts and the plafonnement du quotient familial (Art. 197) still NOT modelled
  • CSG/CRDS/prélèvements sociaux (social charges ~9.7% employment / up to 9.1% pensions / 17.2% investment) not modelled
  • CEHR high-income surtax (3–4% over €250k single / €500k couple) not modelled
  • décote (CGI Art. 197-I-4) not modelled — over-states tax for modest incomes; the couple/imposition-commune décote (base ≈€1,470, applies while impôt brut ≲€3,248) is ~1.65× the single décote (≈€889 / ≲€1,964), so a modest-income spouse household's FR tax can be over-stated by up to ~€1,470/yr. Direction is conservative (over-statement), same as the single path — no sign flip in the marriage-bonus comparison. Any future décote implementation must apply it ONCE to the doubled result using the couple parameters, never the single décote per half then doubled
  • taux effectif on treaty-exempt foreign income not modelled
  • 10% standard salary/pension abattement is NOT modelled anywhere — engine-verified 2026-07-22: no upstream code applies it (offset pension items enter the barème at full gross; the only pre-band pension deductions in the engine are JP 公的年金等控除 and the US senior deduction). FR pensions are therefore taxed on full gross, OVER-stating tax by up to the real cap (€4,439/foyer, floor €454 — service-public.gouv.fr F1419). The previous wording ('applied upstream') was wrong about engine behaviour; queue with the 157 bis + décote reliefs for an owner-signed retiree-relief slice
  • PFU flat tax (~30%) on financial income is a separate schedule, not modelled
  • régime des impatriés (inbound-worker partial exemption) not modelled
  • IFI (impôt sur la fortune immobilière) not modelled — net real-estate wealth above €1,300,000 is taxed on a 0.5–1.5% scale (from the €800k band) for 2026; the proposed broader 'unproductive-wealth' tax was debated but NOT enacted
  • selfEmployment: no regime module — self-employed social contributions / business-income surcharges for this jurisdiction are not modelled

Source: Ember tax-rulepack dossier §5.5 (FR — DGFiP barème)

GB — income tax (2026-27)next data review due 2027-04-06approximate
  • Scottish income tax divergence (use a GB-SCT pack)
  • Student loan repayments
  • Marriage allowance
  • Salary sacrifice / pension relief
  • Class 2 voluntary-contribution nuance (modelled as £0)
  • dividend bands positioned above ordinary income only (no Scottish divergence)

Source: GOV.UK Income Tax rates and Personal Allowances; GOV.UK National Insurance rates and categories

NZ — income tax (2026)next data review due 2027-01-01approximate
  • ACC earners' levy (~1.6% of employment/self-employment income up to an annual cap, ~$1.67 per $100 for 2024/25-2025/26) is a compulsory payroll deduction on top of income tax and is NOT modelled; it applies only to earnings from work, not to NZ Superannuation, other pensions, or investment income
  • Independent Earner Tax Credit (IETC, up to $520/yr for earners between $24,000 and $70,000 without certain benefits) — a credit, not modelled
  • no tax-free threshold and no personal allowance in NZ (bands start at 0% first-dollar taxed at 10.5%); no allowance was subtracted
  • FIF (Foreign Investment Fund) regime taxes foreign shares on a DEEMED ~5% return (FDR method) as ordinary income at these marginal rates — a quasi-income tax not represented by an income-tax band engine and not modelled here
  • bright-line test taxes gains on residential property sold within the bright-line window as ordinary income — not modelled
  • PIE (Portfolio Investment Entity) income has a separate capped rate schedule (PIR max 28%) — not modelled
  • no CGT, no wealth tax, no inheritance/estate duty, no general stamp duty
  • resident withholding tax (RWT) on interest/dividends is a collection mechanism at these marginal rates — not separately modelled
  • single-filer basis; NZ taxes individuals separately (no joint filing) so this is generally correct
  • selfEmployment: no regime module — self-employed social contributions / business-income surcharges for this jurisdiction are not modelled

Source: Ember tax-rulepack dossier (NZ — Ember tax-rulepack dossier §5.27 (NZ — PwC WWTS New Zealand, individual taxes on)

PL — income tax (2026)next data review due 2027-01-01approximate
  • 4% solidarity surcharge over PLN 1,000,000 not modelled
  • 9% health contribution (non-deductible) not modelled
  • selfEmployment: no regime module — self-employed social contributions / business-income surcharges for this jurisdiction are not modelled

Source: Ember tax-rulepack dossier §5.6 (PL)

SG — income tax (2026)next data review due 2027-01-01approximate
  • CPF contributions not modelled (employment only; not applicable to pension income)
  • Not for employment pass holders on fixed packages (not applicable to FIRE retirees)
  • selfEmployment: no regime module — self-employed social contributions / business-income surcharges for this jurisdiction are not modelled

Source: Ember tax-rulepack dossier §5.19 (SG — IRAS)

Double-tax treaty treatment8

How cross-border income (especially pensions) is split between the source country and where you live. Treaty wording can genuinely read more than one way; low-confidence rows are the ones where the safe reading and the generous reading differ.

WhatFlagWhy / what isn’t captured
GB→SG — pension treatynext data review due 2027-01-31low confidenceHeld below full confidence pending review.

Source: UK–Singapore DTC 1997 (SI 1997/2988) Art. 18; IRAS foreign-sourced-income exemption.

GB→GR — pension treatynext data review due 2027-07-31medium confidenceHeld below full confidence pending review.

Source: UK–Greece Double Taxation Convention 1953 (SI 1954/142, in force 15 Jan 1954), Art. X(2); HMRC DTRM DT8252.

GB→IT — pension treatynext data review due 2027-01-31medium confidenceHeld below full confidence pending review.

Source: UK–Italy DTC 1988 Art 18; HMRC DT10154

GB→SG — dividend treatynext data review due 2027-01-31medium confidenceHeld below full confidence pending review.

Source: UK–Singapore DTC 1997 Art 10

GB→TH — pension treatynext data review due 2027-07-31medium confidenceHeld below full confidence pending review.

Source: UK–Thailand DTC 1981 (SI 1981/1546), in force 20 Nov 1981 — NO pension article and NO other-income catch-all (Art 18 = Artistes & Athletes, Art 21 = Teachers); label is practitioner-consensus + Thai domestic law (remittance basis, Por.161/2566), not a treaty clause.

GB→US — dividend treatynext data review due 2027-01-31medium confidenceHeld below full confidence pending review.

Source: UK–US DTC 2001

GB→US — pension treatynext data review due 2027-04-06medium confidenceHeld below full confidence pending review.

Source: UK–US DTC 2001, Art. 17(1)(a).

GB→US — pension (government_service) treatynext data review due 2027-01-31medium confidenceHeld below full confidence pending review.

Source: UK–US DTC 2001 Art 1(4) saving clause; HMRC DT19939G

Capital-gains tax31

How realised investment gains are taxed. Mechanisms vary widely (flat rates, inclusion in income, deemed-return regimes) and several carry carve-outs we approximate.

WhatFlagWhy / what isn’t captured
Thailand — capital gains taxnext data review due 2027-04-06low confidence
  • No CGT for individuals on financial assets.
Argentina — capital gains taxnext data review due 2027-01-31medium confidence
  • 15% flat on securities/crypto gains, legally computed on a foreign-currency or CPI-adjusted cost basis (FX/inflation component untaxed). The engine applies 15% to the full nominal gain — a good match for foreign-currency assets, but OVER-taxes peso-denominated gains in high inflation. Argentine CNV-listed shares, government/corporate bonds and local funds are exempt for residents (not modelled); dividends 7% WHT. Milei-era reform makes details volatile.
Australia — capital gains tax (inclusion_marginal)next data review due 2027-06-30medium confidence
  • Gains on >12-month holdings: 50% CGT discount then marginal rates (long holdings assumed — the FIRE case; <12mo pays full marginal). Shown basic/higher rates are ESTIMATE bounds: bottom/top marginal × 50%; plans stack the included gain on the year's actual income. Market-value cost base on becoming resident (ITAA97 s.855-45, non-TAP assets; temporary-visa arrivals rebase only when temporary status ends, s.768-950/955). ⚠ The 50% discount is legislated to END 1 Jul 2027, replaced by CPI cost-base indexation + a 30% minimum tax on real gains (not simply abolished); Age-Pension/means-tested-support recipients and new housing are exempt from the 30% floor — re-verify closer to the date.
Belgium — capital gains taxnext data review due 2026-12-31medium confidence
  • NEW 10% CGT on financial assets from 1 Jan 2026 (in force; €10k annual exemption).
Brazil — capital gains taxnext data review due 2027-01-31medium confidence
  • 15% standard; gains over R$5m taxed progressively 17.5–22.5%. Foreign financial investments flat 15%/yr (Law 14,754/2023), no exemption — pre-residency acquisition exemption revoked. Monthly small-sales exemptions (R$35k general / R$20k B3 shares) are domestic-only and not modelled.
Canada — capital gains tax (inclusion_marginal)next data review due 2027-01-31medium confidence
  • 50% of gains count as taxable income at marginal rates (the 2024 two-thirds hike was CANCELLED, Mar 2025); no annual exemption. FEDERAL-only income pack — provincial tax omitted, so this UNDER-states real liability. Shown basic/higher rates are ESTIMATE bounds: bottom/top federal marginal × 50%; plans stack the included gain on the year's actual income. Deemed fair-market-value acquisition on becoming resident (ITA s.128.1; no rebase for taxable Canadian property or excluded rights/interests such as pensions & options).
Switzerland — capital gains taxnext data review due 2027-04-06medium confidence
  • No CGT for private investors on moveable assets.
Chile — capital gains taxnext data review due 2027-01-31medium confidence
  • Chilean-listed shares/funds: 10% flat single tax (Art 107, since Sep 2022). Non-listed and FOREIGN assets = ordinary income, progressive to 40% — the engine's conservative 'higher' slot (two-slot approximation, MX-style). 10 UTA/yr and 8,000 UF real-estate exemptions not modelled. New residents taxed on Chilean-source income only for first 3 years.
Colombia — capital gains taxnext data review due 2027-01-31medium confidence
  • 'Occasional gains' 15% flat (assets held ≥2yrs; incl. inheritances); <2yrs = ordinary income at 0–39%. Colombian-listed shares exempt if ≤3% of the company sold in a year. A 2→4yr holding-period reform was rejected Dec 2025; regime politically volatile.
Czechia — capital gains taxnext data review due 2027-01-31medium confidence
  • Gains on the 15/23 scale; securities exempt if held >3yrs (time test). Two-slot approximation.
Germany — capital gains taxnext data review due 2027-04-06medium confidence
  • 25% Abgeltungsteuer + solidarity surcharge ≈ 26.4% effective. €1,000 annual exemption.
Spain — capital gains taxnext data review due 2027-04-06medium confidence
  • 19–30% progressive savings base (base del ahorro): 19% to €6k / 21% to €50k / 23% to €200k / 27% to €300k / 30% over €300k. Nationwide (regions cannot alter). Top rate rose 28%→30% for FY2025.
Greece — capital gains taxnext data review due 2027-01-31medium confidence
  • 15% flat on securities; listed shares EXEMPT if holding <0.5% of the company (engine over-states typical retail portfolios); real-estate CGT suspended to 31 Dec 2026; dividends 5% / interest 15% taxed separately.
India — capital gains taxnext data review due 2027-04-06medium confidence
  • Listed-equity LTCG 12.5% above the ₹1.25 lakh/yr exemption (no indexation, post-Jul-2024 rules; unchanged under the 2025 Act from FY2026-27). Hides: 20% STCG on equity held <12 months, surcharge (capped 15% on LTCG) and 4% cess.
Mexico — capital gains taxnext data review due 2027-01-31medium confidence
  • Listed shares 10% flat; real estate/unlisted 25–35%. Two-slot approximation.
Malaysia — capital gains taxnext data review due 2027-04-06medium confidence
  • No CGT on financial assets (RPGT applies to property only).
New Zealand — capital gains tax (deemed_return)next data review due 2027-04-06medium confidence
  • No general CGT — but foreign portfolios face the FIF regime: a deemed 5% (FDR) annual return taxed as income at marginal rates (modelled as an annual drag on the whole GIA stock, assuming a foreign-domiciled portfolio — the expat case). NZ$50k-cost de-minimis, CV-method election, NZ/AU-listed exemptions and the 4-year transitional-resident exemption not modelled (all reduce the real drag); residential bright-line (2yr) not modelled. Budget 2026 proposed a NZ$100k de-minimis — re-verify.
Poland — capital gains taxnext data review due 2027-01-31medium confidence
  • Flat 19% 'Belka' on capital gains/dividends/interest; no allowance.
Portugal — capital gains taxnext data review due 2027-04-06medium confidence
  • 28% flat autonomous rate on securities gains for residents; no annual exemption (CIRS Art. 72). NOT modelled: optional englobamento (aggregate at the 2026 progressive scale 12.5–48%, favourable roughly below ~€24k taxable income); compulsory aggregation of <365-day gains when total taxable income ≥ €86,634 (2026 top bracket, OE2026/Lei 73-A/2025; no 28% option — CIRS Art. 72 n.º 14/15); Lei 31/2024 long-term partial exclusions on direct securities (10% held 2–5yrs, 20% 5–8yrs, 30% 8+yrs; CFDs/derivatives excluded). NHR/RNH closed to new registrations (general end-2023, transitional into 2024) and never generally exempted securities CGT; its IFICI replacement exempts most FOREIGN-source gains for eligible high-skill beneficiaries but not Portuguese-source securities gains — general resident CGT stays 28%. Real-estate gains (residents AND non-residents since 2023): 50% inclusion at the progressive scale, not this flat rate.
United States — capital gains taxnext data review due 2027-04-06medium confidence
  • LTCG 0/15/20% + 3.8% NIIT; short-term = ordinary. Plus state CGT.
Vietnam — capital gains taxnext data review due 2027-01-31medium confidence
  • Securities taxed 0.1% of SALE PROCEEDS (not gain) — retained by the new PIT Law 109/2025/QH15 (eff. 1 Jul 2026). Encoded as rate-on-gain, which understates the true proceeds-based tax, though it is negligible either way. Real estate 2% of proceeds; LLC capital transfers 20% on gain — not modelled.
UAE — capital gains taxnext data review due 2027-04-06approximate
  • No capital gains tax under current UAE rules.
France — capital gains taxnext data review due 2027-04-06approximate
  • 31.4% flat PFU (prélèvement forfaitaire unique) on securities gains: 12.8% IR + 18.6% social charges (social-charges rate raised from 17.2%, effective 1 Jan 2026). Assurance-vie, PEL/CEL and immovable-property gains keep the 17.2% social-charges rate (30% total).
United Kingdom — capital gains taxnext data review due 2027-04-06approximate
  • 18% basic / 24% higher. £3,000 annual exempt amount (2026-27).
Ireland — capital gains taxnext data review due 2027-01-31approximate
  • 33% flat CGT; €1,270 annual exemption (directly-held assets only). Irish/EU funds & ETFs instead face 38% exit tax (cut from 41% in Budget 2026) with NO exemption plus 8-year deemed disposal — not modelled, so fund-heavy portfolios are under-taxed here.
Italy — capital gains taxnext data review due 2027-01-31approximate
  • 26% flat on financial gains; some govt bonds 12.5%. Real estate exempt if >5yrs / main home.
Japan — capital gains taxnext data review due 2027-04-06approximate
  • 20.315% flat on listed securities (15% national + 0.315% reconstruction surtax + 5% inhabitants), separate self-assessment (申告分離課税); unlisted shares same rate in a ring-fenced pool (no cross-offset). Real estate differs: 39.63% held ≤5yrs / 20.315% >5yrs measured to 1 Jan of sale year — not modelled. NISA tax-free wrappers not modelled.
Netherlands — capital gains tax (deemed_return)next data review due 2027-01-01approximate
  • No tax on realised gains — Box 3 instead taxes a DEEMED return on net investment wealth above the €59,357 heffingsvrij vermogen (2026, €118,714 partners) at 36%, charged annually. 2026 forfaits: 6.00% on 'overige bezittingen' (investments + rental property) and −2.70% on deductible debts above the €3,800 schuldendrempel (€7,600 partners), apportioned by the post-allowance base share (rendementspercentage). A rental mortgage nets the deemed return at 2.70%, NOT 6% — netting at the asset rate under-taxes a leveraged rental ~35%. Rental property enters at FULL value: the leegwaarderatio WOZ discount (73–100%) is NOT modelled, so mortgaged/rented property is conservatively OVER-taxed (safe direction). Rental income itself is untaxed (Box 3 replaces it); a rented second property's mortgage is a Box-3 debt, not Box-1 deductible. The actual-return election (tegenbewijsregeling) makes the forfait a legal CEILING; statutory replacement (Wet werkelijk rendement) planned ~2028. Owner-occupied primary residence is NOT in Box 3 (Box 1 eigenwoning). Bank-deposit forfait (1.28%) not separately modelled — the GIA pot is treated as investments at 6%.
Sweden — capital gains taxnext data review due 2027-01-31approximate
  • 30% flat on capital income. ISK accounts have a separate flat-yield regime (not modelled).
Singapore — capital gains taxnext data review due 2027-01-31approximate
  • No CGT; territorial (foreign income untaxed unless received via SG partnership).
South Africa — capital gains tax (inclusion_marginal)next data review due 2027-04-06approximate
  • 40% of gains above the R50,000 annual exclusion count as income at marginal rates → max effective 18%. Shown basic/higher rates are ESTIMATE bounds: bottom/top marginal × 40%; plans stack the included gain on the year's actual income. Assets deemed acquired at market value on becoming SA tax resident (Eighth Schedule para 12(2)(a); no rebase for SA immovable property or SA permanent-establishment assets).

Inheritance & estate tax30

What happens to your estate on death. Reliefs and thresholds are simplified where noted.

WhatFlagWhy / what isn’t captured
Switzerland — estate/inheritance taxnext data review due 2027-07-02low confidence
  • CANTONAL VARIATION IS THE TAX: 26 cantons with wholly different tariffs; pack encodes Canton Zurich only. Spread for unrelated heirs on CHF 500k runs from 0% (SZ/OW levy no inheritance tax) to ~54% (GE per VZ example); the retiree's canton of residence (and canton of any Swiss real estate) fully determines the bill
  • Descendants are NOT exempt everywhere: AI 1% (above CHF 300k per child), NE 3%, VD up to 3.5% cantonal + communal centimes up to 100% (~7% max), and many LU communes (varies by commune) 1–2% above CHF 100k — pack's child=0% (Zurich) under-states in those four
  • PARENTS of the deceased get a CHF 200,000 allowance and ×1 multiplier in ZH (§21(1)(a), §23(1) — marginal max 7%) but are collapsed into 'other' (×6, no allowance) here — grossly over-taxes parent heirs (conservative)
  • Solothurn levies an additional estate-level Nachlasssteuer on the whole undivided estate regardless of heir (progressive by estate size) — the only crack in the 'spouse wholly exempt' picture; its rate schedule was not confirmed (not invented here)
  • Communal inheritance taxes exist in FR (centimes up to 70% of cantonal), GR (max 5% parental line / 25% others), VD (centimes up to 100%) and LU (descendant tax) — Zurich has NO communal surcharge so the ZH numbers need no uplift, but they don't transplant to those cantons
  • 'Other' class collapse over-taxes ZH intermediate relatives: grandparents/step-children ×2 (grandparents CHF 15k allowance), step-parents ×4, uncles/aunts/siblings' descendants ×5, fiancé(e) CHF 15k allowance, cohabiting partner of 5+ years CHF 50k allowance (still ×6); life-partner treatment varies wildly by canton (fully exempt in e.g. ZG/GR/UR under conditions)
  • Non-monotonic top band is statutory, not an error: ZH §22(2) switches to flat 6% of the TOTAL taxable amount above CHF 1.5m, encoded as an exact final marginal band (18% sibling / 36% other) after the 21%/42% catch-up band; if a monotone marginal schedule is ever required, implement as a 6%-average cap — do not drop the 7%-tranche
  • Band thresholds are measured on the POST-allowance taxable amount (ZH frames the Freibetrag as a §21 deduction, not a 0% tranche) — matches the engine's allowance-then-bands mechanic, so boundaries are encoded unshifted
  • Aggregation not modelled: multiple transfers (gifts + inheritance) from the same person to the same recipient are aggregated for rate/allowance purposes (§21(3), §24 ZH; similar clawbacks elsewhere, e.g. LU 5-year gift clawback despite having no gift tax)
  • ZH reliefs not modelled: §25a 80% reduction for qualifying business-succession assets; 12% special rate for non-reciprocating out-of-canton legal entities (§22(3)); charitable/public-benefit exemptions
  • Situs/scope not modelled: tax accrues to the deceased's canton of last residence; real estate is taxed by the canton where it lies (movable/immovable split matters for multi-canton or cross-border estates); Switzerland has only a handful of inheritance-tax treaties and none covering gift tax
  • Discrepancy resolved by statute: Taxolution's 2026 'effective rate' table (e.g. ZH sibling 28.1% on CHF 500k) is not reproducible from the law (statutory ≈13.5%) and contradicts ESTV/Centrolaw/the rechner — Taxolution's ZH figures were discarded
  • Federal layer: none today, and the Juso initiative (50% above CHF 50m) was rejected 78.3% on 30 Nov 2025 — but the topic recurs politically; note is time-stamped 2026
  • Spouse allowance CHF 1bn is a synthetic sentinel — the exemption is genuinely uncapped

Source: Zurich Erbschafts- und Schenkungssteuergesetz (ESchG ZH, LS 632.1) §§11, 21–23 — tariff verified verbatim (base scale 2–7%, flat 6%-of-total above CHF 1.5m, ×3 sibling / ×6 unrelated, CHF 15k sibling allowance); ESTV Dossier 'Erbschafts- und Schenkungssteuern' (legislation as of 1.1.2025) for the all-cantons spouse exemption and canton/communal matrix. Cross-checked vs PwC WWTS, Centrolaw and erbschaftssteuer-rechner.ch; Deloitte/Withers confirm the 30 Nov 2025 federal-tax rejection (78.3% against).

Spain — estate/inheritance taxnext data review due 2027-06-26low confidence
  • regional variation not modelled — the 17 autonomous communities set reductions and bonificaciones (up to 99% for Groups I/II in Madrid, Andalucía, Valencia); only the state default scale is encoded (the dominant real-world driver; reason confidence is 'low')
  • Art. 22 pre-existing-wealth/relationship multiplier (1.0–2.4) on the cuota not representable in the flat-band model — sibling (Group III) and unrelated-heir (Group IV) liability materially understated
  • regional Group III collateral-relative reliefs not modelled (Catalonia 25% from 1 Jun 2026; Madrid 50% from Jul 2025)
  • spouse not exempt at state level but near-exempt in most communities — pack shows the harsher state position
  • extra state reductions not modelled (under-21 scale, disability, 95% main-home, 95% family-business, life-insurance)
  • non-resident vs resident situs and EU/EEA equal-treatment (DA-2) not modelled

Source: Ley 29/1987 (ISD) Art. 20.2.a (reductions), Art. 21 (state scale — 16 brackets verified vs iberley.es), Art. 22 (multiplier 1.0–2.4). Cross-checked vs idealista 2026 guide.

Belgium (Flanders) — estate/inheritance taxnext data review due 2027-07-02medium confidence
  • REGIONAL VARIATION (biggest gap): pack encodes FLANDERS only. Wallonia 2026 (per heir, single combined base): direct line 3% ≤12.5k / 4% ≤25k / 5% ≤50k / 7% ≤100k / 10% ≤150k / 14% ≤200k / 18% ≤250k / 24% ≤500k / 30% above, with €12,500 abattement (doubled to €25,000 if net share ≤€125,000); siblings 20/25/35/50/65% (breaks 12.5k/25k/75k/175k); uncles-nephews 25/30/40/55/70% (same breaks); others 30/35/60/80% (breaks 12.5k/25k/75k). Brussels 2026: direct line 3% ≤50k / 8% ≤100k / 9% ≤175k / 18% ≤250k / 24% ≤500k / 30% above, €15,000 abattement; siblings 20/25/30/40/55/60/65% (breaks 12.5k/25k/50k/100k/175k/250k); uncles-nephews 35/50/60/70% (breaks 50k/100k/175k); others 40/55/65/80% (breaks 50k/75k/175k)
  • MOVABLE/IMMOVABLE SPLIT not modelled: Flanders direct line/partner runs the 3/9/27 scale SEPARATELY over the movable and the immovable portion per heir (each from zero; the split survives the 2026 reform) — this single-run encoding OVER-taxes any mixed estate (e.g. €200k half/half child share: real 2×(€1,500+€4,500)=€12,000, 6% effective, vs €15,000 single-run)
  • PER-HEIR vs GROUP AGGREGATION: direct line and siblings are taxed per heir on their own share, but Flanders 'anderen' (and the Brussels/Wallonia uncle-nephew classes) are assessed on the GROUP's combined acquisition then apportioned — this per-heir encoding UNDER-taxes multiple 'other'-class heirs
  • FAMILY-HOME EXEMPTION not modelled: the surviving spouse/legal cohabitant inherits the family home 100% tax-free in ALL THREE regions (Flanders also de facto cohabitants ≥3 years); Brussels additionally has a reduced direct-line scale on the family home (2/5.3/6/12% up to €250k)
  • spouse €75,000 allowance is legally a foot-exemption on net MOVABLES only — this encoding applies it to the WHOLE share, under-taxing immovable-heavy partner shares (partly offset by the unmodelled family-home exemption); the shifted bands do reproduce the foot-relief (no-restart) mechanics correctly
  • encoding compromise: the partner's 3% gross band (top €50,000) lies entirely inside the €75,000 exempt tranche, so it is dropped from the shifted bands — post-allowance taxable starts at 9%
  • CLASS COLLAPSE: uncles/aunts/nephews/nieces mapped to 'other' — exact for Flanders (no separate class there), conservative-high for Wallonia/Brussels which have milder intermediate scales (top 70% vs 80%)
  • SCHEDULED REFORMS — re-review no later than 2028-01-01: Wallonia's adopted reform halves top rates from 1 Jan 2028 (direct line max 15%, unrelated max 40%, unconditional €25k direct-line exemption); Flanders' postponed main rate cut is expected ~2028/29; Brussels extended the unregistered-gift add-back window 3→5 years for gifts from 1 Jan 2026
  • Flanders 'singlevermindering' (from 2026: a childless, partnerless testator can will up to €100,000 at 3%/9% to any beneficiary; replaces the abolished €15k vriendenerfenis) not modelled
  • minor-heir reliefs not modelled: Brussels +€2,500 abattement per year under age 21; Flanders orphans-under-21 reliefs; Wallonia abattement doubling
  • family business/farm regimes (Flanders 3% direct/7% others flat, conditions tightened 1 Jan 2026), charity/legal-entity special rates and their reduced scales not modelled
  • scope rules not modelled: Belgian residents' WORLDWIDE estate is taxable (region = deceased's last main residence, ≥2.5 of last 5 years); non-residents pay only on Belgian immovables, on GROSS value (droit de mutation); unregistered gifts within 5 years pre-death are added back
  • not independently confirmed against the raw Flemish Codex (VCF) text — official vlaanderen.be tariff pages were unreachable; figures rest on FSMA Wikifin + VRT + Fednot + firm sources, which are fully concordant

Source: Wikifin (FSMA, Belgian financial regulator) regional rate tables updated 13 Apr 2026 — Flanders 3/9/27 direct line/partner, 25/30/55 siblings, 25/45/55 others; VRT News (3 Oct 2025) confirming the 1 Jan 2026 reform is phase-1-only (partner movables foot-exemption €50k→€75k, rate scales unchanged). Cross-checked vs Fednot (notary federation), PwC WWTS, Moore Belgium and pia.be 2026 guides.

Brazil — estate/inheritance taxnext data review due 2027-07-31medium confidence
  • state variation not modelled — 26 states + DF each set their own ITCMD within the 8% federal cap; only Rio de Janeiro's progressive scale is encoded (São Paulo is still flat 4% and Minas Gerais flat 5%, both with progressive bills pending)
  • 2026 per-state band tables are a moving target post-EC 132/2023 (31 Dec 2025 compliance deadline; several states' progressive schedules still in the state legislature) — re-verify per-state tables at wiring time
  • cross-border nexus not modelled: since EC 132/2023 (with LC 227/2026 referenced as the regulating complementary law) a Brazil-domiciled heir/donee is taxed by their state of domicile on the FULL worldwide inheritance/gift, including foreign-situs assets, regardless of the deceased's domicile
  • no foreign-tax-credit guarantee for foreign estate/inheritance tax — a Brazil-resident heir of a UK estate can face UK IHT and Brazilian ITCMD on the same transfer with no treaty relief; flagged only, no credit modelled
  • raw EC 132/2023 and LC 227/2026 statutory text not reached this verification pass — mechanism corroborated via Baker McKenzie, Colégio Notarial and PwC

Source: https://taxsummaries.pwc.com/brazil/individual/other-taxes

Chile — estate/inheritance taxnext data review due 2027-07-31medium confidence
  • thresholds are UTA/UTM index-linked and drift annually — this pack freezes UTA 2026 = CLP 859,788 pesos; peso values are stale after the next uprating (main reason confidence is 'medium')
  • sibling +20% and unrelated +40% surcharges on the whole computed tax are represented by scaling band rates ×1.2/×1.4 — exact for the tax amount, but the displayed marginal rates differ from the statutory scale's labels
  • sibling class covers 2nd–4th-degree collaterals generally; more remote degrees within that group share the same 5-UTA allowance treatment
  • 5-year survivor relief (Ley 16.271 Art 2 final clause — reduced tax where an heir dies within 5 years of a prior taxed inheritance) not modelled
  • per-heir 'asignación' basis: tax applies to each recipient's share, not the aggregate estate — the engine must apply bands per recipient
  • foreign-heir / situs rules and valuation bases (fiscal vs market value for real estate, vehicles at SII appraisal) not modelled

Source: https://www.sii.cl/preguntas_frecuentes/herencias/001_160_6164.htm (SII scale in UTM = the statute's UTA bands ×12; Ley 16.271 Art 2 https://www.sii.cl/normativa_legislacion/ley16271.pdf; cross-checked https://www.sii.cl/preguntas_frecuentes/herencias/001_160_0332.htm; UTA 2026 = CLP 859,788)

Colombia — estate/inheritance taxnext data review due 2027-07-31medium confidence
  • structural mismatch: Colombia's regime is asset-type-based, not relationship-based — all four RelationshipClass buckets are identical by construction (same spirit as the ES Art. 22 gap)
  • asset-type exemptions not modelled: deceased's habitual residence 13,000 UVT = COP 680,862,000 and rural real estate 6,500 UVT = COP 340,431,000 (ET Art. 307 nums. 1-2) — only the per-heir 3,250-UVT exemption is encoded, so estates containing a family home are overstated
  • exemption concurrency/stackability is DIAN doctrine, not primary-confirmed this cycle
  • non-resident situs scope (worldwide if deceased CO-resident; CO-situs only if non-resident) not independently primary-verified — low confidence
  • UVT-denominated thresholds are revalued annually (2026 UVT = COP 52,374, DIAN Res. 000238/2025); COP figures are 2026-only
  • ET Art. 307 numeral 2 is framed as RURAL property specifically, not generic 'other real estate'
  • 2026 was a volatile CO tax year (two economic-emergency declarations, Constitutional Court reversals) — annual re-check required

Source: Estatuto Tributario Arts. 302/303 (occasional gains), 307 (exemptions), 313 (15% rate), as amended by Ley 2277 de 2022 — https://estatuto.co/307 (statute mirror; primary host http://www.secretariasenado.gov.co/senado/basedoc/estatuto_tributario_pr013.html intermittently unreachable); UVT 2026 = COP 52,374 per DIAN Res. 000238 de 2025.

France — estate/inheritance taxnext data review due 2027-06-26medium confidence
  • Only 4 relationship classes; nieces/nephews (55%, €7,967), 4th-degree (55%), grandchildren-as-heirs collapse into 'other'/'child' — nieces/nephews OVER-taxed at 60%
  • Barème thresholds and the €100,000 child allowance frozen through 31 Dec 2028; re-check at expiry
  • Handicap allowance (€159,325) and prior-gift/15-year rappel fiscal not modelled
  • Assurance-vie passes largely outside succession (€152,500/beneficiary) — not represented; users with life-insurance wrappers over-taxed
  • Non-resident situs (CGI art. 750 ter; 6-of-10-year rule) not modelled
  • Spouse exemption encoded via a €10bn sentinel rather than a structural flag

Source: service-public.gouv.fr (droits de succession, F35794/F17456/A18843); Loi TEPA 2007 spouse/PACS exemption (CGI art. 796-0 bis); CGI art. 777/779/788. Direct-line & sibling barèmes frozen through 31 Dec 2028.

Japan — estate/inheritance taxnext data review due 2027-06-26medium confidence
  • Flat per-class band model approximates Japan's statutory-share two-step method; omits the 20% surtax (二割加算) on non-spouse/child/parent heirs — ~20% understatement for siblings/'other' unless the engine layers it
  • Only the ¥6M per-heir allowance is encoded — the ¥30,000,000 estate-level base must be applied by the engine
  • Spouse allowance is the ¥160M floor only; the larger statutory-share alternative not modelled — over-taxes high-net-worth surviving spouses
  • Minor-heir, disability, successive-inheritance, gift-in-contemplation credits not modelled; small-scale residential land 80% reduction not modelled
  • Resident vs limited/non-resident situs scope (post-2017/2021 reforms) not modelled

Source: National Tax Agency (NTA) — Inheritance Tax and Gift Tax; PwC WWTS Japan 2026. Top rate 55% over ¥600M.

Portugal — estate/inheritance taxnext data review due 2027-06-30medium confidence
  • situs-only scope not modelled by the class bands: the 10% legally reaches ONLY Portuguese-situs assets (CIS Art. 4) — applying it to a worldwide estate overstates tax for PT residents with foreign assets and misses PT-situs assets of non-residents
  • the additional 0.8% stamp duty on gratuitous transfers of PT real estate (TGIS verba 1.1 — payable even by otherwise-exempt spouse/descendant/ascendant heirs) is not expressible in the class-band shape and is omitted
  • ascendants (parents/grandparents) are exempt like descendants (CIS Art. 6(e)) but the 4-class model routes them through 'other' at 10% — over-taxed here
  • life-insurance proceeds and pension-fund/PPR death benefits are NOT subject to the transfer duty at all (CIS Art. 1(5)) — include them in an estate here and they are wrongly taxed at 10% for non-exempt heirs
  • real estate is valued at the VPT (or market value if higher), not plain market value

Source: Código do Imposto do Selo Arts. 1, 4, 6(e) + Tabela Geral verbas 1.1/1.2 (portaldasfinancas.gov.pt); APECA/OCC doctrinal notes; PT rental pack slice 2026-07-24.

Vietnam — estate/inheritance taxnext data review due 2027-07-31medium confidence
  • real-estate close-family exemption (0% for spouse / parent-child incl. adoptive / in-laws / grandparent-grandchild / blood siblings, PIT Law Art 4) applies to REAL ESTATE ONLY and is not representable in a relationship-keyed model — cash/securities/vehicles/business interests to the same relatives are taxed at 10%; spouseExempt deliberately false to avoid wrongly zero-rating a spouse inheriting cash or shares
  • the VND 20M allowance is per-occurrence (per transfer event), not an annual or lifetime allowance as the engine may assume
  • mid-2026 timing: occurrences before 1 Jul 2026 use the old VND 10,000,000 threshold (Law 109/2025/QH15 effective date) — immaterial to forward FIRE projections
  • family-exemption relationship list is law-firm-sourced (not read against the Vietnamese statute's raw text)

Source: thuvienphapluat.vn — official English translation, Law 109/2025/QH15 (PIT): 10% on inheritance/gift value exceeding VND 20 million per occurrence — https://thuvienphapluat.vn/van-ban/EN/Thue-Phi-Le-Phi/Law-109-2025-QH15-personal-income-tax/687756/tieng-anh.aspx

United Arab Emirates — estate/inheritance taxnext data review due 2027-06-26approximate
  • Succession allocation under Sharia/civil law is a distribution rule, not a tax — not modelled (affects WHO receives, not FIRE tax)
  • Foreign-situs assets of a UAE resident may still face estate/inheritance tax in the asset's jurisdiction (e.g. UK IHT on UK situs incl. the 2025/26 long-tail; US estate tax on US situs) — captured by those packs, not here

Source: PwC Worldwide Tax Summaries — UAE, Individual Other taxes (2026): 'There are currently no inheritance, estate, or gift taxes imposed on individuals in the United Arab Emirates.'

Australia — estate/inheritance taxnext data review due 2027-06-26approximate
  • Superannuation death benefits to non-tax-dependants (~15–17% on the taxed element) modelled as super/income tax, not an estate pack
  • Deemed cost-base inheritance / deferred CGT and the 2-year main-residence window are CGT-layer concerns
  • State stamp/transfer duty on some transfers not modelled (state variation)

Source: Australian Taxation Office — Deceased estates / Inherited assets and CGT (no inheritance or estate tax; CGT rollover at death, Div 128 ITAA 1997). PwC WWTS — Australia.

Canada — estate/inheritance taxnext data review due 2027-06-26approximate
  • Provincial probate / estate-administration fees (e.g. Ontario EAT ~1.5% over CAD 50,000) not modelled — administrative levies, vary by province
  • Deemed-disposition CGT at death handled by the CGT engine layer, not this pack
  • Spousal/common-law rollover is conditional (recipient Canadian-resident, vested ≤36 months); only the headline deferral is recorded
  • spouseExempt=true is recorded for schema consistency but is a CGT-deferral rollover, not an estate-tax exemption (Canada has no death-transfer tax)

Source: PwC WWTS — Canada (no estate/inheritance tax; deemed disposition at death, 50% CGT inclusion). CRA — Taxable capital gains for a deceased person. Dept of Finance (21 Mar 2025) cancelled the proposed inclusion-rate increase.

Czechia — estate/inheritance taxnext data review due 2027-07-31approximate
  • Gifts from NON-relatives are taxed as ordinary 'other income' (§10 ZDP, 15%/23%) above a small annual exemption — a gift-tax track outside the death-transfer model; the exact non-relative threshold is muddled across sources (CZK 15,000 occasional-gift vs CZK 50,000 occasional-income figures conflated)
  • §38v CZK 5m threshold is reporting-only, not modelled (no tax effect)
  • Foreign-situs assets of a CZ-resident deceased may still face estate/inheritance tax in the asset's own jurisdiction — captured by those packs, not here

Source: Income Taxes Act (ZDP) §4a (universal inheritance exemption since 1 Jan 2014) + §38v (CZK 5m reporting threshold); PwC Worldwide Tax Summaries — Czech Republic, Individual, Other taxes: https://taxsummaries.pwc.com/czech-republic/individual/other-taxes; ARROWS law: https://arws.cz/news-at-arrows/tax-aspects-of-large-inheritances-2026

Germany — estate/inheritance taxnext data review due 2027-06-26approximate
  • Versorgungsfreibetrag (§17): +€256,000 spouse / up-to-€52,000 child support allowances not modelled
  • Owner-occupied family-home exemption (10-year occupancy) not modelled
  • Business/agricultural reliefs (§§13a/13b, 85–100%) not modelled
  • Grandchild allowance €200,000/€400,000 collapsed into child class
  • Parents/grandparents-on-death €100,000 Class I allowance not separately modelled
  • Non-resident / Inlandsvermögen situs (§2) not modelled
  • Härteausgleich (§19(3)) marginal smoothing not applied
  • 10-year prior-gift aggregation (§14) not modelled
  • Pending reform risk: BVerfG ruling + Jan-2026 SPD concept open — re-review before nextReviewDue
  • regional variation not modelled (federal tax, but assessment practice can vary by Land)

Source: ErbStG §16 (Freibeträge) & §19 (Steuersätze), gesetze-im-internet.de/erbstg_1974; PwC WWTS Germany 2026; florian-enders.de Erbschaftsteuer-Tabelle 2026. Unchanged for 2026.

United Kingdom — estate/inheritance taxnext data review due 2027-06-26approximate
  • RNRB taper full-withdrawal point (~£2.35m) not modelled as a derived field
  • Limited spouse exemption for a non-long-term-resident surviving spouse IS modelled (couples slice 1, 2026-07-15: capped at the NRB per IHTA s18(2)/(2A), keyed off the partner's stored domicile) — but the s267ZA-ZE election into UK treatment is note-only, the cap's CUMULATIVE lifetime nature is applied at-death only, and LTR is approximated by a static domicile field
  • From 6 Apr 2025 IHT scope moved from domicile to a long-term-residence test (10/20-year rule); residence-based situs/excluded-property logic not modelled
  • Business Property Relief & Agricultural Property Relief (and the £1m 100% combined cap from Apr 2026) not modelled
  • Unused pension funds chargeable to IHT from Apr 2027 not yet reflected in this pack
  • 7-year lifetime gift taper and PET/CLT mechanics not modelled
  • No nonResidentSitusThreshold — the UK-situs charge has no de minimis (NRB applies)
  • Freeze extends to 5 Apr 2031 (Finance Bill 2025-26); track Budget announcements

Source: GOV.UK — IHT nil-rate band & residence nil-rate band thresholds 6 Apr 2026–5 Apr 2028; frozen to 5 Apr 2031 (Finance Bill 2025-26).

Greece — estate/inheritance taxnext data review due 2027-07-02approximate
  • Minor children qualify for the €400,000 special exemption (same derived scale as the spouse); the single 'child' class uses the standard €150k Cat A scale, over-taxing minor heirs (conservative)
  • Spouse scale assumes marriage/civil partnership of >=5 years at death; if shorter, the standard Cat A scale (€150k / 1% / 5% / 10%) applies instead — un-modelled fallback
  • 4-class collapse: Category B non-sibling relatives (nephews/nieces, grandparents, great-grandchildren, step-relatives, in-laws) are mapped to 'other' (Cat C 20–40%) instead of their legal Cat B 5–20% scale — over-taxes them (conservative)
  • Territorial scope not modelled: Greek inheritance tax covers all property situated in Greece plus foreign-situated movables of Greek nationals or Greece-resident foreigners; foreign immovables of Greek residents are outside scope
  • Aggregation not modelled: prior lifetime gifts/parental grants to the same heir are aggregated with the inheritance when applying the scale; the separate gift/parental-grant regime differs materially (since Oct 2021: €800,000 Cat A allowance then flat 10%; money gifts to Cat B/C at flat 20%/40%)
  • Reliefs not modelled: primary-residence exemption for spouse/children under conditions; ~10% reduction for heirs with disability >=67%; agricultural/farm exemptions; exemptions for deceased in military service
  • AADE page returned HTTP 403 to direct fetch; its content was verified via search extraction plus the Ministry of Finance page — no figure rests on AADE alone
  • L.5303/2026 (published 22 May 2026) rewrites the Civil Code succession-LAW book for deaths on/after 16 Sept 2026; no source shows it touching the L.2961/2001 TAX scales, but re-verify for secondary effects at the next review

Source: Hellenic Ministry of Economy and Finance capital-taxation guide (official Cat A/B/C scales with cumulative-tax figures; €400,000 spouse/minor-child exemption of Art. 25(2) L.2961/2001 as amended by L.3815/2010, incl. the >=5-year condition) and AADE inheritance-tax guidance. Band boundaries cross-checked against PwC Worldwide Tax Summaries and Greek practitioner guides (KPAG, efm.gr, Taxheaven) — the Ministry's cumulative check figures reproduce exactly under this encoding.

Ireland — estate/inheritance taxnext data review due 2027-06-26approximate
  • Major CAT reliefs not modelled: Agricultural Relief & Business Relief (90%), Dwelling House Exemption, €3,000 small-gift exemption
  • Lifetime-cumulative aggregation within each group (since 5 Dec 1991) not represented — treated as a single per-class allowance per event; under-taxes recipients with prior same-group benefits
  • Group B/C collapse several relationships (sibling, niece/nephew, grandchild, lineal ancestor; cousins, friends, cohabitants) into 'sibling'/'other'
  • Non-resident situs / foreign-domicile CAT scope not modelled
  • Spouse allowance €1bn is a synthetic sentinel — the exemption is genuinely uncapped

Source: Revenue.ie — Capital Acquisitions Tax (CAT) thresholds, rates & aggregation (2026); Budget 2026 left thresholds and the 33% rate unchanged. Corroborated by Citizens Information.

India — estate/inheritance taxnext data review due 2027-07-31approximate
  • no step-up in basis on death — a later SALE of an inherited asset triggers ordinary CGT using the deceased's original cost and acquisition date (a CGT-side effect, not modelled in this pack)
  • foreign-situs assets of an India resident may still face estate/inheritance tax in the asset's own jurisdiction — captured by those countries' packs, not here

Source: PwC Worldwide Tax Summaries — India, Individual Other taxes: https://taxsummaries.pwc.com/india/individual/other-taxes (no inheritance/estate tax; Estate Duty Act 1953 abolished 1985)

Italy — estate/inheritance taxnext data review due 2027-06-26approximate
  • Disabled-beneficiary allowance €1,500,000 (any relationship) not modelled
  • Relatives to 4th degree / in-laws to 3rd taxed 6% with NO allowance, distinct from siblings (6% WITH €100,000) — mapped imprecisely
  • Family-business / qualifying-shareholding exemption not modelled
  • Imposta ipotecaria (2%) & catastale (1%) on real property are separate transfer taxes, not captured
  • 2026 coacervo abolition not modelled at the lifetime-aggregation level (consistent with treating each death independently)

Source: D.Lgs. 346/1990 (TUS) as amended by D.Lgs. 139/2024; PwC WWTS Italy. All four headline rates and both allowances corroborated.

Mexico — estate/inheritance taxnext data review due 2027-07-31approximate
  • Gifts to other than spouse/lineal relatives are exempt only up to 3x annual UMA = MXN 128,384 (2026); the excess is ordinary taxable income to the recipient — a gift-side income-tax rule, not a death tax, and not modelled (sibling gifts are not exempt; parent gifts lose exemption if later passed/sold to a sibling)
  • Disclosure obligation: inheritances over MXN 500,000 must be reported in the recipient's annual ISR return (Art. 150 LISR) to keep the exemption — a compliance requirement, not a tax; not modelled
  • Pending 22 Apr 2026 Senate initiative (not enacted, ~4th such proposal in a decade): inheritance/gift tax above ~MXN 14M at 10–18% plus a wealth tax above MXN 100M at 2–6% — watch item only, model stays 'none' under current law
  • Foreign-situs assets of a Mexican-resident deceased may still face estate/inheritance tax in the asset's jurisdiction — captured by those countries' packs, not here

Source: Justia México — LISR Título IV Art. 93 Frac. XXII (inheritances ISR-exempt, official-text mirror): https://mexico.justia.com/federales/leyes/ley-del-impuesto-sobre-la-renta/titulo-iv/; PwC Worldwide Tax Summaries — Mexico, Other taxes (reviewed 30 Jan 2026): 'There is no specific inheritance, estate, or gift tax in Mexico.'

Netherlands — estate/inheritance taxnext data review due 2027-01-31approximate
  • Grandchildren (18%/36%, €26,230 exemption) not modelled — no grandchild slot
  • Parents' specific exemption (€62,110) and parent rate (10%/20%) not modelled — 'other' understates their allowance and overstates their rate
  • Disabled-child exemption (€78,671) not modelled
  • Unmarried cohabitants qualify for the partner exemption only with a registered/notarial partnership; otherwise 'other' — nuance not modelled
  • Business-succession relief (BOR) and 30-day successive-death relief not modelled
  • Box-3 wealth tax and gift tax (schenkbelasting) are separate regimes

Source: Belastingdienst — Tarieven & Vrijstelling erfbelasting 2026 (verified 2026-06-26); Nu Notariaat 2026.

New Zealand — estate/inheritance taxnext data review due 2027-07-31approximate
  • Deceased's final income-tax return and pre-existing FIF/bright-line liabilities at death are the deceased's own income-tax items, not a death tax — not modelled here
  • Foreign-situs assets of an NZ resident may still face estate/inheritance tax in the asset's jurisdiction (e.g. UK IHT on UK situs, US estate tax on US situs) — captured by those packs, not here
  • Green Party 2026-election proposal (33% inheritance tax above NZD 1m) is not law — watch item only, re-check after the October 2026 general election

Source: Estate Duty Abolition Act 1993 (legislation.govt.nz): https://www.legislation.govt.nz/act/public/1993/0013/latest/whole.html; IRD Tax Technical — gift duty abolition (gifts on/after 1 Oct 2011): https://www.taxtechnical.ird.govt.nz/new-legislation/act-articles/taxation-tax-administration-and-remedial-matters-act-2011/gift-duty-abolition

Poland — estate/inheritance taxnext data review due 2027-07-31approximate
  • Group 0 full exemption is conditional on filing form SD-Z2 within 6 months of acquisition — the pack assumes timely filing; late filing drops the heir to Group I ordinary rates (allowance 36,120 zł, 3/5/7%), not modelled
  • 'other' collapses three distinct non-exempt tiers into the harshest: Group I in-laws (allowance 36,120 zł, 3/5/7%) and Group II (allowance 27,090 zł, 7/9/12%) heirs are overstated by defaulting to the Group III (unrelated) scale, per the record's DE-mirroring conservative default
  • 2027 expansion of Group 0 to registered informal partners passed the Sejm 29 May 2026 but is not law for 2026 — deliberately not encoded; re-check at next review
  • statutory złoty-and-groszy band flat amounts reconcile exactly to the cumulative-band encoding except a 5-grosz display difference in the Group I second-band flat (immaterial and Group I is not directly modelled)

Source: podatki.gov.pl — Stawki i limity (official current SD rates/allowances): https://www.podatki.gov.pl/podatki-osobiste/sd/stawki-i-limity (cross-checked vs MF archive full scale https://podatki-arch.mf.gov.pl/pcc-sd/abc-sd/stawki-podatkowe-sd/)

Sweden — estate/inheritance taxnext data review due 2027-07-31approximate
  • Foreign death taxes on a Swedish resident's foreign-situs assets or foreign-domiciled connections (e.g. UK IHT, US estate tax on US situs) can still apply — captured by those countries' packs, not here

Source: PwC Worldwide Tax Summaries — Sweden, Individual, Other taxes (no inheritance/estate/gift tax): https://taxsummaries.pwc.com/sweden/individual/other-taxes

Singapore — estate/inheritance taxnext data review due 2027-07-31approximate
  • Deaths BEFORE 15 Feb 2008 remain within the old estate-duty regime — historical edge case, not modelled
  • Foreign-situs assets of a Singapore resident may still face estate/inheritance tax in the asset's jurisdiction (e.g. UK IHT on UK situs, US estate tax on US situs) — captured by those packs, not here
  • Commentary speculating on a possible future re-introduction of estate duty is opinion, not law — no pending bill as of 2026-07-14

Source: IRAS — Estate Duty (primary, accessed 2026-07-14): 'Estate Duty has been removed for deaths on and after 15 Feb 2008' (s.2A Estate Duty Act). https://www.iras.gov.sg/taxes/other-taxes/estate-duty/estate-duty

Thailand — estate/inheritance taxnext data review due 2027-07-31approximate
  • Thai-situs scope not modelled — the Act reaches only 4 statutory asset categories (Thai real estate, Thai-registered securities/shares, Thai bank deposits, registered vehicles) regardless of nationality/residence; offshore assets are entirely outside the Act, so applying this pack to a worldwide estate overstates tax
  • ascendants (parents/grandparents) share the 5% descendant rate and are mapped onto the 'child' relationship class — the four-key class model has no separate ascendant slot
  • separate lifetime Gift Tax (THB 20m allowance for ascendant/descendant/spouse, THB 10m other, 5% on excess) is a distinct un-modelled base
  • filing/valuation mechanics (return within 150 days of receipt, official appraised values) not modelled

Source: Thai Revenue Department — Inheritance Tax Act B.E. 2558 index (Act + Royal Decree + Ministerial Regs): https://www.rd.go.th/english/27739.html

United States — estate/inheritance taxnext data review due 2027-06-26approximate
  • State-level estate/inheritance taxes (~12 states + DC) not modelled — regional variation not modelled
  • Non-citizen surviving spouse requires a QDOT — treated here as fully exempt
  • Graduated 18–40% schedule collapsed to flat 40%
  • Lifetime gift-tax unification ($15M is a combined gift+estate exclusion) not separately modelled
  • NRA situs threshold may be raised by estate-tax treaties (UK/DE/FR) — treaty uplifts not modelled
  • DSUE portability requires a timely Form 706 election; not automatic
  • Basic exclusion is inflation-indexed from 2027 — $15,000,000 applies to 2026 deaths only; refresh before nextReviewDue

Source: IRS 2026 inflation adjustments (basic exclusion $15,000,000, OBBBA §2010(c)(3)); IRS Estate Tax & NRA $60,000 situs exclusion; IRC §2056/§2055/§2010(c). Verified 2026-06-26.

South Africa — estate/inheritance taxnext data review due 2027-07-31approximate
  • Two-tier rate not representable: duty is 20% up to R30,000,000 of dutiable value and 25% above — the shape's single flatRatePct encodes 20%, so duty on estates with dutiable value over R30m is understated
  • Situs scope not modelled: SA-resident deceased is taxed on worldwide property, a non-resident deceased only on SA-situated property (s3(2)) — the pack applies the same computation regardless of residence/situs
  • Donations tax (lifetime gifts) not modelled: 20% up to R30m cumulative / 25% above, with a R150,000 annual exemption effective 1 March 2026 (raised from R100,000)
  • s4 deductions and valuation rules (liabilities, funeral/administration costs, usufruct and limited-interest valuations, farm-property relief) not modelled — dutiable value is taken as the modelled estate value
  • Spouse abatement portability is modelled only as transferableBands doubling the R3.5m abatement to R7m on the second death; actual s4A(2) portability depends on unused abatement at the first death

Source: SARS — Estate Duty (Estate Duty Act 45 of 1955): https://www.sars.gov.za/types-of-tax/estate-duty/ (cross-checked https://www.sars.gov.za/tax-rates/other-taxes/), verified 2026-07-14

AR — estate/inheritance tax (not yet coded)not yet coded
  • documented in the dossier; not yet coded into an estate pack

Source: docs/tax/2026-06-22-tax-rulepack-dossier-DRAFT.md

US state taxes51

State-level income tax on top of federal. Local variations and credits are not all modelled.

WhatFlagWhy / what isn’t captured
US — Utah (state tax)medium confidence
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • Taxpayer Tax Credit (6% of federal deductions + UT exemptions, phasing out 1.3%/$ above ~$18,213 single, vanishing ~$91k) APPROXIMATED as a ~$7,000 allowance-equivalent — PROVISIONAL. Reviewed 2026-07-19 (W3): the approximation is retained deliberately (low model-fit across the income band is a known, bounded trade-off); underlying rates remain asOf 2025 and were NOT re-verified for 2026. Whether to buy professional verification is an owner budget decision — queued in the owner question pack.

Source: https://incometax.utah.gov/paying/tax-rates ; https://incometax.utah.gov/credits/taxpayer-tax-credit

US — Vermont (state tax)medium confidence
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • Vermont capital-gains exclusion (greater of a flat $5,000 general exclusion or 40% of qualifying in-state assets held 3+ yrs; the 40% option EXCLUDES publicly-traded stock/bonds/real estate) not modelled — for typical investors only the flat $5,000 general exclusion applies.
  • Bracket thresholds conflict across secondary sources (official VT Dept. of Taxes 2025 Rate Schedules PDF returned HTTP 403) — verify before use.

Source: https://taxfoundation.org/data/all/state/state-income-tax-rates/ ; https://www.tax-brackets.org/vermonttaxtable ; https://tax.vermont.gov/individuals/personal-income-tax/rates ; https://roberthalltaxes.com/news/vermont-capital-gains-tax-in-2025/

US — Alaska (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.

Source: https://taxfoundation.org/location/alaska/

US — Alabama (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • Local occupational/license taxes (Birmingham, Bessemer, Gadsden, Auburn, etc.) not modelled.
  • Standard-deduction phase-down ($3,000 max → $2,500 floor) and $1,500 personal exemption not modelled.

Source: https://www.revenue.alabama.gov/faqs/what-is-alabamas-individual-income-tax-rate/ ; https://taxfoundation.org/data/all/state/state-income-tax-rates/ ; https://www.taxformfinder.org/alabama/standard-deduction-chart-form-40

US — Arkansas (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • Full exemption of net capital gain over $10,000,000 not modelled.
  • Bracket-adjustment / tax-reduction table that smooths the low/middle-income schedule not modelled.

Source: https://taxfoundation.org/data/all/state/state-income-tax-rates/

US — Arizona (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • TY2025 acquisition-date restriction (assets acquired after Dec 31, 2011) on the 25% LTCG subtraction not modelled.
  • 34%-of-qualified-charitable-contributions standard-deduction increase not modelled.

Source: https://taxfoundation.org/data/all/state/state-income-tax-rates/ ; https://taxfoundation.org/location/arizona/ ; https://azdor.gov/news-center/ador-outlines-executive-order-and-2025-tax-year-income-tax-forms ; https://www.azleg.gov/ars/43/01022.htm

US — California (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • 1% Mental Health / Behavioral Health Services surtax on taxable income over $1,000,000 (modelled as the 10th band here — but the surtax also reaches capital-gain income over $1M).
  • 1.1% uncapped SDI payroll tax on wages not modelled (it is a payroll levy, not an income-tax bracket).

Source: https://www.ftb.ca.gov/forms/2025/2025-540-tax-rate-schedules.pdf ; https://www.nerdwallet.com/taxes/learn/california-state-tax ; https://taxfoundation.org/data/all/state/state-income-tax-rates/

US — Colorado (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • Flat-dollar local Occupational Privilege ('head') taxes not modelled.

Source: https://taxfoundation.org/data/all/state/state-income-tax-rates/ ; https://ustax.tools/tax-by-state/colorado/

US — Connecticut (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • Personal exemption ($15,000 single) + 1–75% personal tax credit fully phase out by ~$45k–$52.5k AGI ⇒ ~zero relief for middle income (modelled); sub-$45k filers get partial relief NOT modelled (allowance+band model can't express the phase-out).
  • Tax-benefit recapture and complex high-earner phase-outs (footnotes i/p) not modelled.

Source: https://taxfoundation.org/data/all/state/state-income-tax-rates/

US — District of Columbia (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • QHTC (High Technology Company) deferral/exclusion for capital gains not modelled.

Source: https://otr.cfo.dc.gov/page/dc-individual-and-fiduciary-income-tax-rates ; https://taxfoundation.org/data/all/state/state-income-tax-rates/

US — Delaware (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • Wilmington 1.25% local earned-income tax not modelled.
  • $110-per-exemption personal credit not modelled.

Source: https://taxfoundation.org/data/all/state/state-income-tax-rates/ ; https://legis.delaware.gov/json/BillDetail/GenerateHtmlDocument?legislationId=130098&legislationTypeId=1&docTypeId=2&legislationName=HB89 ; https://learn.valur.com/delaware-income-tax-explained/ ; https://www.wilmingtonde.gov/residents/earned-income-tax-and-net-profits-tax

US — Florida (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.

Source: https://taxfoundation.org/data/all/state/state-income-tax-rates/

US — Georgia (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • $4,000-per-dependent deduction not modelled.

Source: https://taxnews.ey.com/news/2025-0930-georgia-law-lowers-personal-income-tax-retroactive-to-january-1-2025-allows-for-future-tax-cuts ; https://taxfoundation.org/data/all/state/state-income-tax-rates/ ; https://dor.georgia.gov/taxes/important-tax-updates

US — Hawaii (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • $1,144 personal exemption not modelled.
  • Preferential 7.25% LTCG cap applies only to the LOWER of 7.25% / marginal rate; the 'min(7.25%, marginal)' refinement is not modelled.

Source: https://tax.hawaii.gov/forms/d_25table-on/d_25table-on_p13/ ; https://taxfoundation.org/data/all/state/state-income-tax-rates/

US — Iowa (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • In-state-asset-only capital-gain deductions/exclusions (qualifying farmland 10+ yrs, qualifying-business sale, ESOP/employer stock) not modelled — they do NOT apply to ordinary securities.
  • School-district / EMS surtaxes (a % of state liability) not modelled.

Source: https://taxfoundation.org/data/all/state/state-income-tax-rates/ ; https://revenue.iowa.gov/press-release/2025-10-21/idr-announces-2026-individual-income-tax-and-interest-rates

US — Idaho (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • In-state-asset-only deduction (up to 60% of net capital gain on QUALIFYING IDAHO real property) not modelled — intangibles such as stocks/bonds do NOT qualify and are fully taxed at 5.3%.

Source: https://taxfoundation.org/data/all/state/state-income-tax-rates/ ; https://www.paylocity.com/resources/tax-compliance/alerts/idaho-lowers-2025-state-income-tax-rate/ ; https://gov.idaho.gov/pressrelease/idaho-delivers-largest-income-tax-cut-in-state-history-sending-another-253-million-back-to-idahoans/ ; https://legislature.idaho.gov/wp-content/uploads/sessioninfo/2025/legislation/H0040.pdf ; https://tax.idaho.gov/taxes/income-tax/individual-income/popular-credits-and-deductions/capital-gains/

US — Illinois (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • Personal-exemption allowance ($2,850, modelled as the allowance) is disallowed above $250,000 federal AGI — phase-out not modelled.

Source: https://tax.illinois.gov/research/taxrates/income.html

US — Indiana (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • County adjusted-gross-income tax (~0.5%-3%, all 92 counties) not modelled.

Source: https://taxfoundation.org/data/all/state/state-income-tax-rates-2026/ ; https://www.in.gov/dor/

US — Kansas (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • Large personal/dependent exemptions ($9,160 single / $2,320 dependent) not modelled.

Source: https://taxfoundation.org/data/all/state/state-income-tax-rates/

US — Kentucky (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • Local occupational license/payroll taxes (counties + cities, can stack) not modelled.

Source: https://taxfoundation.org/location/kentucky/ ; https://revenue.ky.gov/News/Pages/Kentucky-DOR-Announces-2026-Standard-Deduction.aspx

US — Louisiana (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • In-state-asset-only net-capital-gains deduction (sale of a non-publicly-traded Louisiana-domiciled business) not modelled — ordinary portfolio/stock LTCG does NOT qualify and is taxed at the full 3%.

Source: https://taxfoundation.org/data/all/state/state-income-tax-rates-2026/ ; https://revenue.louisiana.gov/tax-education-and-faqs/faqs/income-tax-reform/what-are-the-individual-income-tax-rates-and-brackets/ ; https://taxfoundation.org/location/louisiana/

US — Massachusetts (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • Short-term capital gains carry a special 8.5% rate (higher than ordinary 5%), and collectibles 12%; these special CGT rates are not modelled.
  • 4% 'Fair Share' surtax over $1,083,150 (modelled as the 9% band here) also reaches capital gains pushing income over the threshold.

Source: https://taxfoundation.org/data/all/state/state-income-tax-rates/ ; https://www.mass.gov/info-details/massachusetts-personal-income-tax-exemptions

US — Maryland (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • Mandatory county/Baltimore-City local income tax (2.25%-3.30%) not modelled.
  • 2% net-capital-gains surtax for federal AGI over $350,000 (from TY2025) not modelled.
  • Itemized-deduction phase-out above $200,000 FAGI not modelled.

Source: https://www.marylandcomptroller.gov/content/dam/mdcomp/tax/legal-publications/alerts/tax-alert-changes-to-standard-and-itemized-deductions-and-to-state-and-local-income-tax-rates-from-the-2025-legislative-session.pdf ; https://taxfoundation.org/data/all/state/state-income-tax-rates/

US — Maine (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • Standard-deduction phase-out (income over $100,000) and $5,150 personal exemption (phasing over $323,900) not modelled.

Source: https://www.maine.gov/revenue/sites/maine.gov.revenue/files/inline-files/ind_tax_rate_sched_2025.pdf

US — Michigan (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • Local municipal income taxes (24 cities) not modelled.

Source: https://taxfoundation.org/data/all/state/state-income-tax-rates/ ; https://www.michigan.gov/taxes ; https://www.michigan.gov/treasury/news/2026/04/15/state-individual-income-tax-rate-for-2026-tax-year-determined ; https://www.michigan.gov/treasury/news/2025/05/01/calculation-of-state-individual-income-tax-rate-adjustment-for-2025-tax-year

US — Minnesota (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • 1% Net Investment Income Tax (NIIT) on net investment income over $1,000,000 (from TY2024) — effectively a +1% surtax on capital gains over the threshold — not modelled.

Source: https://www.revenue.state.mn.us/press-release/2024-12-16/minnesota-income-tax-brackets-standard-deduction-and-dependent-exemption

US — Missouri (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • Kansas City / St. Louis 1% local earnings tax not modelled.

Source: https://dor.mo.gov/taxation/individual/tax-types/income/year-changes/ ; https://taxfoundation.org/data/all/state/state-income-tax-rates/ ; https://dor.mo.gov/news/newsitem/uuid/15044650-59dd-48f4-975a-01988d485255

US — Mississippi (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • In-state-asset-only exclusion (gains on Mississippi-domiciled financial institutions / domestic corporations / LPs / LLCs held >1 yr) not modelled — ordinary portfolio gains taxed at the flat 4%.
  • $6,000 single personal exemption not modelled.

Source: https://taxfoundation.org/data/all/state/state-income-tax-rates-2026/

US — Montana (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • LTCG 'stacks on top of ordinary income' so the 3% tier only fills the portion of $0-$21,100 not used by ordinary income; this stacking interaction is not modelled (the preferential bands are applied to the gain standalone).
  • $5,660 age-65+ subtraction not modelled.

Source: https://taxfoundation.org/data/all/state/state-income-tax-rates/ ; https://revenue.mt.gov/files/BIT/Montana-Tax-Tables-and-Deductions/2025-Tax-Rates-and-Deductions.pdf

US — North Carolina (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.

Source: https://www.ncdor.gov/taxes-forms/individual-income-tax/tax-rate-schedules

US — North Dakota (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.

Source: https://taxfoundation.org/data/all/state/state-income-tax-rates/

US — Nebraska (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • In-state-asset-only employee-stock exclusion (sale of employer capital stock, Neb. Rev. Stat. 77-2715.08) not modelled — a narrow carve-out, not a general LTCG exclusion.

Source: https://taxfoundation.org/data/all/state/state-income-tax-rates/

US — New Hampshire (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.

Source: https://taxfoundation.org/location/new-hampshire/ ; https://www.revenue.nh.gov/news-and-media/repeal-nh-interest-and-dividends-tax-now-effect

US — New Jersey (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • Property-tax/medical deductions not modelled.
  • $10,000 single filing-threshold (no-tax cliff for sub-$10k income) not modelled.
  • Capital losses cannot offset other income categories in NJ — not modelled.

Source: https://taxfoundation.org/data/all/state/state-income-tax-rates/ ; https://www.nj.gov/treasury/taxation/taxtables.shtml

US — New Mexico (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • Net capital-gain deduction (greater of $2,500 or 40% of up to $1M of in-state-business gain, Sec. 7-2-34) not modelled — most ordinary investment LTCG effectively gets only the flat $2,500 deduction.

Source: https://taxfoundation.org/data/all/state/state-income-tax-rates/

US — Nevada (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.

Source: https://taxfoundation.org/data/all/state/state-income-tax-rates/

US — New York (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • NYC resident income tax and Yonkers surcharge not modelled.
  • Tax-benefit recapture (supplemental tax) that phases out the lower brackets for high earners not modelled.

Source: https://taxfoundation.org/data/all/state/state-income-tax-rates/

US — Ohio (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • Relief is the 0% first band to $26,050 (modelled); OH has no standard deduction.
  • Municipal income taxes and school-district income taxes (SDIT) not modelled.
  • Personal/dependent exemptions ($1,900-$2,400 by AGI, phasing out above $750,000 MAGI) not modelled.

Source: https://taxfoundation.org/data/all/state/state-income-tax-rates/ ; https://www.nerdwallet.com/taxes/learn/ohio-state-tax ; https://www.plantemoran.com/explore-our-thinking/insight/2025/07/ohio-budget-bill-makes-significant-tax-changes-for-a-variety-of-taxpayers

US — Oklahoma (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • In-state-asset-only 100% Oklahoma capital-gain deduction (Form 561; in-state real/tangible property held 5+ yrs, or qualified Oklahoma company interests) not modelled — out-of-state gains taxed in full.
  • $1,000 personal exemption not modelled.

Source: https://taxfoundation.org/data/all/state/state-income-tax-rates/

US — Oregon (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • Portland-metro local income taxes (Multnomah PFA, Metro SHS) and transit payroll taxes not modelled.
  • Federal income tax subtraction (capped ~$8,500 single, phasing out) not modelled.

Source: https://taxfoundation.org/data/all/state/state-income-tax-rates/

US — Pennsylvania (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • Local Earned Income Taxes (EIT) and Philadelphia/Chester wage taxes not modelled.
  • Low-income 'Tax Forgiveness' credit not modelled.
  • PA does not recognise federal capital-loss carryovers or the federal primary-residence exclusion — not modelled.

Source: https://www.pa.gov/agencies/revenue/resources/tax-rates/personal-income-tax-rates

US — Rhode Island (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • $5,100 personal exemption and standard-deduction/exemption phase-out (eliminated above $283,250 modified FAGI) not modelled.
  • New TY2026 top bracket (~3% surtax over ~$625,000) not modelled (this row is TY2025).

Source: https://taxfoundation.org/data/all/state/state-income-tax-rates/ ; https://tax.ri.gov/sites/g/files/xkgbur541/files/2025-11/ADV_2025_22_Inflation_Adjustments.pdf

US — South Carolina (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • New SC Income-Adjusted Deduction (SCIAD, modelled as the allowance) phases out between $40,000 and $95,000 of income for single filers — phase-out not modelled.
  • Revenue-trigger top-rate ratchet (toward 1.99%) not modelled.

Source: https://dor.sc.gov/news/information-about-h-4216

US — South Dakota (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.

Source: https://taxfoundation.org/location/south-dakota/

US — Tennessee (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.

Source: https://taxfoundation.org/location/tennessee/ ; https://revenue.support.tn.gov/hc/en-us/articles/360057828631-HIT-3-Hall-Income-Tax-Repealed-Beginning-January-1-2021 ; https://taxfoundation.org/data/all/state/state-income-tax-rates/

US — Texas (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.

Source: https://taxfoundation.org/data/all/state/state-income-tax-rates-2026/

US — Virginia (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • Narrow Virginia 'technology business' LTCG subtraction (investments 2010-2020, held >=24 months) not modelled — irrelevant to most filers.

Source: https://www.tax.virginia.gov/news/new-virginia-tax-laws-july-1-2025 ; https://taxfoundation.org/data/all/state/state-income-tax-rates/

US — Washington (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • Only LONG-TERM gains on intangibles (stocks, bonds, business interests) allocated to WA are taxed; real estate, retirement accounts, timber, livestock and qualifying-family-business assets are EXEMPT — these exemptions are not modelled.
  • 0.58% WA Cares payroll tax (not an income tax) excluded.

Source: https://dor.wa.gov/forms-publications/publications-subject/special-notices/new-tiered-rates-washingtons-capital-gains-tax ; https://dor.wa.gov/taxes-rates/other-taxes/capital-gains-tax ; https://taxfoundation.org/data/all/state/state-income-tax-rates/

US — Wisconsin (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.
  • Higher 60% LTCG exclusion for qualifying farm assets not modelled (this row uses the 30% non-farm exclusion).
  • Sliding-scale standard deduction (SSSD) phases down to $0 as AGI rises — phase-out not modelled.

Source: https://www.revenue.wi.gov/Pages/FAQS/pcs-taxrates.aspx ; https://taxfoundation.org/data/all/state/state-income-tax-rates/ ; https://www.revenue.wi.gov/DOR%20Publications/pb103.pdf

US — West Virginia (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.

Source: https://tax.wv.gov/ ; https://tax.wv.gov/Individuals/Pages/PersonalIncomeTaxReductionBill.aspx ; https://taxfoundation.org/location/west-virginia/ ; https://taxfoundation.org/data/all/state/state-income-tax-rates/

US — Wyoming (state tax)approximate
  • Single-filer schedule only; MFJ/HoH/MFS not modelled.
  • Federal AMT, itemized-vs-standard election, personal exemptions, tax credits, and standard-deduction phase-outs are not expressible in v1 and are not modelled.

Source: https://taxfoundation.org/location/wyoming/

Property transaction fees10

Buying and selling costs used in property modelling.

WhatFlagWhy / what isn’t captured
Argentina — property feesapproximate
  • subnational rates span 2–3.5% — the representative rate is wired

Source: https://www.agip.gob.ar/impuestos/sellos

Australia — property feesapproximate
  • subnational rates span 6.5–7% — the representative rate is wired

Source: https://www.revenue.nsw.gov.au/taxes-duties-levies-royalties/transfer-duty/understanding-transfer-duty/calculate-transfer-duty

Brazil — property feesapproximate
  • subnational rates span 2–5% — the representative rate is wired

Source: https://prefeitura.sp.gov.br/web/fazenda/w/servicos/itbi/2513

Canada — property feesapproximate
  • subnational rates span 0–5% — the representative rate is wired

Source: https://www.ontario.ca/document/land-transfer-tax/calculating-land-transfer-tax

Switzerland — property feesapproximate
  • subnational rates span 0–3% — the representative rate is wired

Source: https://en.comparis.ch/immobilien/verkaufen/vertragsabschlussphase/handaenderungssteuer

Colombia — property feesapproximate
  • subnational rates span 0.85–1.85% — the representative rate is wired

Source: https://www.supernotariado.gov.co/prensa/noticias/supernotariado-actualiza-tarifas-registrales/

Germany — property feesapproximate
  • subnational rates span 3.5–6.5% — the representative rate is wired

Source: https://www.finanz-tools.de/grunderwerbsteuer/bundeslaender-tabelle

Spain — property feesapproximate
  • subnational rates span 6–13% — the representative rate is wired

Source: https://atc.gencat.cat/es/tributs/itpajd/tpo/tarifes-tipus/

France — property feesapproximate
  • subnational rates span 3.8–6.32% — the representative rate is wired

Source: https://www.service-public.gouv.fr/particuliers/actualites/A18183?lang=en

India — property feesapproximate
  • subnational rates span 3–11% — the representative rate is wired

Source: https://cleartax.in/s/stamp-duty-and-registration-charges-in-maharashtra

Cost-of-living factors30

Rough, illustrative comparisons of living costs against a UK baseline — useful for direction, never precise forecasts.

WhatFlagWhy / what isn’t captured
CH — cost-of-living factorlow confidenceHeld below full confidence pending review.

Source: OECD/World Bank/Eurostat PPP price-level (illustrative)

DE — cost-of-living factorlow confidenceHeld below full confidence pending review.

Source: OECD/World Bank/Eurostat PPP price-level (illustrative)

FR — cost-of-living factorlow confidenceHeld below full confidence pending review.

Source: OECD/World Bank/Eurostat PPP price-level (illustrative)

AE — cost-of-living factormedium confidenceHeld below full confidence pending review.

Source: Numbeo/Mercer 2026 + UAE compulsory retiree health insurance (Hayah broker bands); owner-verified resident correction

AR — cost-of-living factormedium confidenceHeld below full confidence pending review.

Source: OECD/World Bank/Eurostat PPP price-level (illustrative)

AU — cost-of-living factormedium confidenceHeld below full confidence pending review.

Source: OECD/World Bank/Eurostat PPP price-level (illustrative)

BE — cost-of-living factormedium confidenceHeld below full confidence pending review.

Source: OECD/World Bank/Eurostat PPP price-level (illustrative)

BR — cost-of-living factormedium confidenceHeld below full confidence pending review.

Source: OECD/World Bank/Eurostat PPP price-level (illustrative)

CA — cost-of-living factormedium confidenceHeld below full confidence pending review.

Source: OECD/World Bank/Eurostat PPP price-level (illustrative)

CL — cost-of-living factormedium confidenceHeld below full confidence pending review.

Source: OECD/World Bank/Eurostat PPP price-level (illustrative)

CO — cost-of-living factormedium confidenceHeld below full confidence pending review.

Source: OECD/World Bank/Eurostat PPP price-level (illustrative)

CZ — cost-of-living factormedium confidenceHeld below full confidence pending review.

Source: OECD/World Bank/Eurostat PPP price-level (illustrative)

ES — cost-of-living factormedium confidenceHeld below full confidence pending review.

Source: Eurostat price-level index (illustrative)

GB — cost-of-living factormedium confidenceHeld below full confidence pending review.

Source: OECD/World Bank PPP (illustrative)

GR — cost-of-living factormedium confidenceHeld below full confidence pending review.

Source: OECD/World Bank/Eurostat PPP price-level (illustrative)

IE — cost-of-living factormedium confidenceHeld below full confidence pending review.

Source: OECD/World Bank/Eurostat PPP price-level (illustrative)

IN — cost-of-living factormedium confidenceHeld below full confidence pending review.

Source: OECD/World Bank/Eurostat PPP price-level (illustrative)

IT — cost-of-living factormedium confidenceHeld below full confidence pending review.

Source: OECD/World Bank/Eurostat PPP price-level (illustrative)

JP — cost-of-living factormedium confidenceHeld below full confidence pending review.

Source: OECD/World Bank/Eurostat PPP price-level (illustrative)

MX — cost-of-living factormedium confidenceHeld below full confidence pending review.

Source: OECD/World Bank/Eurostat PPP price-level (illustrative)

NL — cost-of-living factormedium confidenceHeld below full confidence pending review.

Source: OECD/World Bank/Eurostat PPP price-level (illustrative)

NZ — cost-of-living factormedium confidenceHeld below full confidence pending review.

Source: OECD/World Bank/Eurostat PPP price-level (illustrative)

PL — cost-of-living factormedium confidenceHeld below full confidence pending review.

Source: OECD/World Bank/Eurostat PPP price-level (illustrative)

PT — cost-of-living factormedium confidenceHeld below full confidence pending review.

Source: Eurostat prc_ppp_ind AIC price-level 2024 (PT 85.0 vs UK 129.1, EU27=100); Numbeo 2026 corroboration

SE — cost-of-living factormedium confidenceHeld below full confidence pending review.

Source: OECD/World Bank/Eurostat PPP price-level (illustrative)

SG — cost-of-living factormedium confidenceHeld below full confidence pending review.

Source: OECD/World Bank/Eurostat PPP price-level (illustrative)

TH — cost-of-living factormedium confidenceHeld below full confidence pending review.

Source: World Bank PPP (illustrative)

US — cost-of-living factormedium confidenceHeld below full confidence pending review.

Source: OECD PPP (illustrative)

VN — cost-of-living factormedium confidenceHeld below full confidence pending review.

Source: OECD/World Bank/Eurostat PPP price-level (illustrative)

ZA — cost-of-living factormedium confidenceHeld below full confidence pending review.

Source: OECD/World Bank/Eurostat PPP price-level (illustrative)

Wrapper recognition on drawdown8

How pension and savings wrappers (ISA, SIPP, 401k, UAE provident, …) are taxed when drawn while resident in another country. Several treatments — especially UAE provident/DEWS payouts — have no clear authority guidance yet; provisional rows use the conservative reading and deserve advice before you rely on them.

WhatFlagWhy / what isn’t captured
uae_resident (AE) — drawdown tax character by residencenext data review due 2027-01-01low confidence
  • GB: taxed_as_income — provisional
  • ES: taxed_as_income — provisional
  • FR: taxed_as_income — provisional
  • AT: taxed_as_income — provisional
  • US: taxed_as_income — provisional
  • default: taxed_as_income — provisional
  • DEWS/provident Art.18-vs-Art.15 characterisation UNRESOLVED everywhere (design §5) — every non-AE cell is provisional.
  • The owner-directed alternative is crystallising before the move (plan §R4 lever).

Source: UK–UAE DTA Art. 17 (pension) vs Art. 14 (employment income) — characterisation UNRESOLVED for DEWS-style funded DC master trusts; design 2026-07-11 residency-aware-drawdown-tax §2; UAE FTA — no personal income tax; ES–UAE DTC characterisation unresolved (design §5); FR–UAE DTC characterisation unresolved (design §5); AT–UAE DTC characterisation unresolved; §124b Z 53 ⅓ concession deliberately NOT encoded (electable drawdown typically fails the no-choice-of-form test); No US–UAE income-tax treaty — nonqualified foreign trust treatment assumed; OECD MC Art. 18 pension characterisation assumed (unresolved — design §5)

isa (GB) — drawdown tax character by residencenext data review due 2027-01-01low confidence
  • AT: taxed_as_investment — provisional
  • Residence-keyed only — no source-state or citizenship overlay (design §2).

Source: HMRC — ISA regulations (ITTOIA 2005 ss.694–701); design 2026-07-11 residency-aware-drawdown-tax §2; UAE FTA — no personal income tax; AEAT — ISA has no Spanish recognition; ordinary savings-income account; DGFiP — ISA has no French recognition; ordinary investment account; BMF — foreign account treatment (no ISA recognition found); IRS — ISA is not a qualified plan; taxable account for US residents; ISA is a GB-only statutory shelter; ordinary account elsewhere

lisa (GB) — drawdown tax character by residencenext data review due 2027-01-01low confidence
  • AT: taxed_as_investment — provisional
  • The 25% unauthorised-withdrawal charge before age 60 is not modelled.

Source: HMRC — Lifetime ISA rules (Savings (Government Contributions) Act 2017); design 2026-07-11 residency-aware-drawdown-tax §2; UAE FTA — no personal income tax; AEAT — no Spanish recognition of the LISA shelter; DGFiP — no French recognition of the LISA shelter; BMF — foreign account treatment (no LISA recognition found); IRS — LISA is not a qualified plan; LISA is a GB-only statutory shelter; ordinary account elsewhere

sipp (GB) — drawdown tax character by residencenext data review due 2027-01-01low confidence
  • AT: taxed_as_income — provisional
  • UK Lump Sum Allowance cap not modelled on the GB 25% fraction (v1).
  • Time-apportioned s.574A splits (pre-2017 accrual) not modelled — needs contribution history (design §2, v2).

Source: FA 2004 pension freedoms — 25% PCLS (HMRC PTM063230); design 2026-07-11 residency-aware-drawdown-tax §2; UK–UAE DTA Art. 17 — pensions taxable only in the residence state; UAE levies none; UK–Spain DTC Art. 17 + AEAT — Spain taxes the full draw, no PCLS recognition; UK–France DTC Art. 18 + DGFiP — residence-taxed, no PCLS recognition; UK–Austria DTC Art. 18 (residence taxation assumed); US–UK DTA Art. 17 — periodic pension distributions residence-taxed; OECD MC Art. 18 — private pensions taxed at residence

pension — drawdown tax character by residencenext data review due 2027-01-01low confidence
  • default: taxed_as_income — provisional
  • Generic OECD Art. 18 position — no per-source-country nuance in v1.

Source: UAE FTA — no personal income tax; design 2026-07-11 residency-aware-drawdown-tax §2; OECD MC Art. 18 — private pensions taxed at residence (generic position)

401k (US) — drawdown tax character by residencenext data review due 2027-01-01low confidence
  • FR: tax_free — provisional
  • AT: taxed_as_income — provisional
  • US source-state withholding for non-treaty residences (e.g. 30% NRA on AE residents) not modelled — residence-keyed v1 (design §2).
  • 10% early-distribution additional tax not modelled.

Source: US–UK DTA Art. 17(1) — periodic distributions taxed at residence; design 2026-07-11 residency-aware-drawdown-tax §2; UAE levies no personal income tax (residence-keyed v1 — US source withholding is a documented exclusion); US–Spain DTC Art. 20 + AEAT — residence-taxed; US–France DTA Art. 18 (US taxing right) + Art. 24(1)(a) crédit d'impôt; US–Austria DTC Art. 18 (residence taxation assumed); IRC §72 / IRS Pub 575 — distributions ordinary income; OECD MC Art. 18 — private pensions taxed at residence

roth_ira (US) — drawdown tax character by residencenext data review due 2027-01-01low confidence
  • ES: taxed_as_income — provisional
  • FR: taxed_as_income — provisional
  • AT: taxed_as_income — provisional
  • Qualified-distribution conditions (age 59½, 5-year rule) assumed met.

Source: US–UK DTA Art. 17(1)(b) — exempt-in-US distribution exempt at residence; HMRC accepts qualified Roth draws tax-free; design 2026-07-11 residency-aware-drawdown-tax §2; UAE levies no personal income tax; AEAT — no Roth recognition found; conservative full-income reading; US–France DTA Art. 18 reading disputed (plan §R1 ruling: conservative full-income); No Austrian Roth guidance found; conservative reading; IRC §408A — qualified Roth distributions tax-free (IRS Pub 590-B); Conservative default — foreign states rarely recognise the Roth shelter

trad_ira (US) — drawdown tax character by residencenext data review due 2027-01-01low confidence
  • FR: tax_free — provisional
  • AT: taxed_as_income — provisional
  • US source-state withholding for non-treaty residences not modelled — residence-keyed v1.

Source: US–UK DTA Art. 17(1) — periodic distributions taxed at residence; design 2026-07-11 residency-aware-drawdown-tax §2; UAE levies no personal income tax (residence-keyed v1); US–Spain DTC Art. 20 + AEAT — residence-taxed; US–France DTA Art. 18 + Art. 24(1)(a) crédit d'impôt; US–Austria DTC Art. 18 (residence taxation assumed); IRC §408(d) / IRS Pub 590-B — distributions ordinary income; OECD MC Art. 18 — private pensions taxed at residence

Residency-transition warnings29

Arrival-year residence scope (whole-year vs split-year vs from-arrival) and whether each country's UAE treaty covers non-national expats — advisory warnings only; the engine works at age granularity and never computes a charge from these.

WhatFlagWhy / what isn’t captured
Belgium — arrival-year scope + UAE-treaty residence (advisory)next data review due 2027-01-31medium confidence
  • Belgium's 'split year' on arrival is not a named statutory split-year REGIME (no UK-SRT-style codified cases): it flows from residence being a factual/annual concept (CIR92 art. 2-3) plus the taxable-period rules (art. 360). The practical effect is two returns for the arrival year — a resident return covering worldwide income from the arrival date, and non-resident treatment (Belgian-source only) for the pre-arrival part.
  • Residence is factual (not a pure 183-day test): registration in the national register is a rebuttable presumption; family seat in Belgium is an irrebuttable presumption (CIR92 art. 2 §1, 1°).
  • Foreign-source income of a Belgian resident is typically exempted-with-progression where a DTA gives the other State taxing rights — relevant to double-counting in projections.
  • BE-UAE treaty: art. 4(1) has NO nationality bar (contrast Spain-UAE art. 4.1.b), but the Belgian administration interprets 'liable to tax' as not satisfied where the UAE imposes no personal income tax, so a UAE-resident individual can be refused treaty-resident status on the liable-to-tax limb rather than on nationality. The UAE's post-2023 9% corporate tax does not create individual PIT.
  • The treaty has a Protocol (integral part). Its ad-Article-4 note only EXTENDS 'resident' to the State itself, political subdivisions/local authorities and State-controlled financial institutions; it does not add an individual nationality or 183-day test.
  • Fact 1 arrival-scope classification (part-year vs split) is a judgment call: the substantive point — worldwide exposure starts at arrival, not for the whole year — is well corroborated, but the exact FPS Finance statutory wording of the split mechanism was not read verbatim (PDF sources unextractable), hence medium confidence.

Source: FPS Finance (official) — Coming to Belgium: tax return; OECD — Belgium: Information on residency for tax purposes (official); PwC Worldwide Tax Summaries — Belgium Individual Residence (statutory pointer, CIR92 art. 2); Belgium-UAE Double Tax Convention full text (Art. 4 + Protocol), signed 30 Sep 1996; UN iLibrary — Treaty No. 39858, Belgium and United Arab Emirates (official registration)

Switzerland — arrival-year scope + UAE-treaty residence (advisory)next data review due 2027-01-31medium confidence
  • Rate-determination caveat: although only post-arrival income is taxed, Switzerland annualises recurring income to set the progressive rate (satzbestimmendes Einkommen) - the part-year income is taxed at the rate that would apply to the full-year equivalent.
  • Residence trigger (art. 3 LIFD): residence is established by intent-to-stay domicile, or by a stay of at least 30 days with gainful activity / 90 days without; once the threshold is met, unlimited liability applies retroactively from the first day of the stay.
  • Tax is levied at three levels (federal LIFD + cantonal/communal under the harmonised StHG art. 68); the start-of-liability-on-arrival rule is harmonised across all three, but effective rates and net-wealth tax vary by canton/commune.
  • CH-UAE DTA timeline: signed 6 Oct 2011, entered into force 2012 (generally applicable from 1 Jan 2013); a Protocol of Amendment signed 5 Nov 2022 modified other provisions (e.g. permanent establishment), not the art. 4 residence definition.
  • The exact art. 4 UAE wording ('domicile ... provided substantial presence') is drawn from multiple secondary reproductions of the treaty; the primary Fedlex/SIF PDF text was not directly machine-readable in this session, hence medium (not high) confidence on the verbatim phrasing - though every source concurs there is no nationality restriction for individuals.
  • UAE domestic tax-residency (Cabinet Decision No. 85 of 2022, effective 1 Mar 2023) can independently make an expat a UAE tax resident, but the treaty's own art. 4 definition governs treaty access and is what matters for treaty tie-breaks.

Source: Fedlex - Convention between the Swiss Confederation and the UAE for the avoidance of double taxation with respect to taxes on income (treaty 2011/2432); OECD - Switzerland: Information on residency for tax purposes; Findea.ch - Income Tax Part I: Tax Liability (Art. 8 DBG - liability begins with establishment of residence); LexNews.ch - Understanding Swiss tax liability for natural persons (Art. 8 DBG, retroactive-to-first-day rule); Taxolution Advisory - Moving to Switzerland 2026: taxes, residency start, part-year liability

Czechia — arrival-year scope + UAE-treaty residence (advisory)next data review due 2027-01-31medium confidence
  • No explicit split-year regime exists in the statute; the mid-year 'split residency' (worldwide taxation for only part of the year) is administrative practice under the General Financial Directorate (GFŘ) methodology and the applicable treaty, keyed to the date the permanent home (bydliště) is established/ceases.
  • If CZ residence arises via the §2(4) 183-day usual-abode test (assessed over the whole calendar year) rather than a permanent home, the worldwide-income period can extend beyond just the post-arrival portion; the treaty tie-breaker (art. 4(2)) then allocates residence period-by-period.
  • §2(3): persons present in Czechia solely to study or receive medical treatment are non-residents even if they exceed 183 days.
  • The applicable treaty for TY2026 is the 2023 CZ-UAE treaty (Sb. m. s. 206/2024), in force 29 May 2024 and effective from 1 Jan 2025; it replaced the 1996 treaty (Sb. 276/1997) whose Article 4 tied UAE residence to actual taxation/domicile criteria.
  • Treaty residence for a UAE-side individual still requires being a resident of the UAE under UAE domestic law AND not a resident of a third state (art. 4(1)(a)); a UAE Tax Residency Certificate is the practical evidence.
  • FACT 1 confidence is medium: the §2 statute text was read directly (high), but the part-year/split-residency characterisation for a mover rests on the GFŘ methodology, confirmed via professional (Crowe/EY/Deloitte) commentary rather than the methodology instruction text itself. FACT 2 (treaty Article 4, no nationality restriction) was read from the official Sbírka text and is high-confidence.

Source: Sb. m. s. 206/2024 — CZ-UAE Double Tax Treaty (full Czech text, Article 4 Rezident); Czech Ministry of Finance — Information on entry into force of the CZ-UAE double tax treaty (in force 29 May 2024, effective from 1 Jan 2025, replaces 1996/1997 treaty); Act No. 586/1992 Coll., Income Tax Act — § 2 (residence: bydliště / 183 days, worldwide income); Crowe Czech Republic — New GFR methodology on determining tax residency (split residency mid-year); EY Czech Republic — New CZ-UAE double tax treaty (Article 4 residence now based on UAE domestic law)

Greece — arrival-year scope + UAE-treaty residence (advisory)next data review due 2027-01-31medium confidence
  • Fact 1 (whole-year) confidence is MEDIUM: it rests on the ABSENCE of a split-year statute plus AADE/practitioner consensus, not an explicit 'whole year' clause; art. 4(2)'s 'resident from the first day of presence in Greece' wording is occasionally argued the other way, but the assessment unit remains the full calendar year. Fact 2 (UAE nationality bar) is HIGH — verbatim treaty text confirmed.
  • Greek tax year is the calendar year (Law 4172/2013 art. 8); worldwide-income taxation attaches to Greek tax residents for the full fiscal year.
  • The GR-UAE DTA LAPSED on 18 Dec 2024 and was reinstated: re-entered into force by exchange of notes 2 May 2025, ratified by Law 5228/2025 — re-confirm current in-force status at the date of any advice.
  • Treaty is comprehensive (income AND capital); base treaty ratified by Law 4234/2014 (ΦΕΚ B' 28, 04-02-2014 per the Greek source), amending Protocol signed Athens 27 Jun 2013, in force 2014.
  • UAE-side art. 4(1)(b) nationality requirement means Marcus (a non-Emirati UAE resident) generally cannot claim UAE treaty residence against Greece — destination Greek domestic law governs, and Greece may assert Greek residence for a Greek national settled in the UAE.
  • Separate from split-year: Greece offers alternative/non-dom regimes for qualifying NEW tax residents (Law 4172/2013 arts. 5A €100k flat-tax on foreign income, 5B foreign pensioners 7%, 5C employees/self-employed 50% exemption) that can materially cut worldwide-income exposure — check eligibility and election deadlines.

Source: AADE — Tax residence for natural persons (ITC), art. 4 Law 4172/2013; AADE — Transferring tax residency from Greece abroad (POL 1201/2017 procedure; whole-year worldwide-income filing); AADE — Taxation of non-Greek-sourced income obtained by Greek tax residents (worldwide income); TaxExperts (Greek treaty text, GR-UAE) — Art. 4 residence: UAE individual = residence + UAE nationality; ratified Law 4234/2014; KPMG — Greece: income tax treaty with UAE once again in force (Law 5228/2025; re-entered into force 2 May 2025 after lapsing 18 Dec 2024)

Argentina — arrival-year scope + UAE-treaty residence (advisory)next data review due 2027-06-30approximate
  • Residency trigger for a foreigner is obtaining permanent migration residence OR completing 12 months of authorised temporary stay (LIG art. 116 / T.O.1997 art. 119). Someone merely present short-term stays a non-resident; the whole-year six-month test in LIG art. 116(a) applies to Argentine nationals/existing residents, not to a newly-arriving foreigner whose start date is set by the acquisition rule.
  • Effective date is the first day of the month IMMEDIATELY FOLLOWING the month the qualifying event occurs ('a partir de la iniciación del mes inmediato subsiguiente'), so residence never starts retroactively to 1 January — it is genuinely part-year.
  • Migration residency and tax residency are independent regimes (holding a DNI/permanent migration status does not by itself make one a tax resident, and vice-versa).
  • AR-AE treaty is in force from 4 Jan 2019 but with general effect for amounts paid/withheld from 1 Jan 2020 — confirm the relevant income period falls within its temporal scope.
  • The treaty carries a Limitation-on-Benefits article (art. 25, 'qualified person') that can independently deny treaty benefits even to someone who is a resident under art. 4; a passive UAE-resident individual should check LOB qualification.
  • The UAE 183-day limb in art. 4.1(a) is a domestic-presence test, not a nationality test — but it still requires actual 183-day UAE presence in the calendar year, which a genuinely UAE-domiciled expat normally meets. Argentina has also signed the OECD MLI (approved 2024), which can layer principal-purpose anti-abuse rules onto this treaty.

Source: Ley de Impuesto a las Ganancias, texto ordenado (consolidated, arts. 119-126 residence chapter incl. acquisition-effect rule) — UNC official copy; Decreto 824/2019 — texto ordenado 2019 of the Income Tax Law (art. 116 residents / acquisition effective date) — argentina.gob.ar; ARCA/AFIP — Residencia (income-tax residency guidance: foreigners resident on permanent residence or 12 months; worldwide vs Argentine-source); Convenio Argentina–Emiratos Árabes Unidos para evitar la doble imposición (full official Spanish text, art. 4 Residencia + Protocolo) — argentina.gob.ar; Ley 27.496 — aprobación del Convenio con EAU (Boletín Oficial 04/01/2019 / Ministerio de Relaciones Exteriores)

Australia — arrival-year scope + UAE-treaty residence (advisory)next data review due 2027-06-30approximate
  • No statutory split-year regime like the UK SRT and no whole-year worldwide charge like Spain (LIRPF art. 9); part-year residency is inherent in applying ITAA 1936 s 6(1) to the period you are resident.
  • For the non-resident portion of the income year, only Australian-source ordinary income is assessable (ITAA 1997 s 6-5(3)); worldwide income is assessable only for the resident portion (s 6-5(2)).
  • Residency itself is decided by the four s 6(1) tests (ordinary 'resides' concept, domicile/permanent-place-of-abode, 183-day, Commonwealth superannuation), interpreted in Taxation Ruling TR 2023/1; the arrival date is the date the person first satisfies a test.
  • Part-year tax-free threshold = a fixed base (about A$13,464) plus a pro-rata of the remaining ~A$4,736 by resident months including the arrival month (Income Tax Rates Act 1986; 2024-25 figures — confirm the current-year amount).
  • Because there is no Australia-UAE DTA, there is no treaty tie-break or nationality gate to consider; UAE-source income earned before becoming resident is outside the Australian net simply as foreign-source non-resident income, and any double tax on the resident portion is relieved only by the domestic foreign income tax offset, not a treaty.

Source: Australian Treasury — Income Tax Treaties (in-force comprehensive DTA list; UAE absent); ATO — myTax 2026 Part-year tax-free threshold (part-year resident from date residency begins; income year 1 July–30 June); ATO — Tax-free threshold for newcomers to Australia (resident tax rates + pro-rated threshold from arrival); INCOME TAX ASSESSMENT ACT 1936 s 6 — Interpretation ('resident of Australia')

Brazil — arrival-year scope + UAE-treaty residence (advisory)next data review due 2027-06-30approximate
  • Arrival-date conditions (IN 208/2002 art. 2): a permanent-visa holder, or someone entering with a Brazilian employment relationship, is resident from the date of entry; a temporary-visa holder without a local employment tie becomes resident on the 184th day of presence (consecutive or not) within any 12-month period — so the exact start of the part-year residence depends on visa/immigration status.
  • Before the residence-characterisation date, the individual is taxed only as a non-resident (Brazilian-source income, generally flat withholding), not on worldwide income; there is no retroactive whole-year worldwide charge.
  • The BR-UAE treaty's nationals-only individual definition means a non-Emirati Ember user resident in the UAE gets no treaty relief against Brazil — Brazilian domestic law governs alone; the treaty's tie-breaker/relief articles are unavailable to them.
  • Under Art. 4 of the treaty, UAE COMPANY residence is additionally conditioned on a UAE competent-authority residence certificate accepted by Brazil (a Protocol/administrative requirement) — relevant only for entities, not the individual case here.
  • IN 208/2002 is an administrative instruction implementing the income-tax law (esp. Lei nº 9.718/1998 art. 12 and RIR); it is the operative Receita Federal guidance on when residence begins.

Source: Decreto nº 10.705, de 26 de maio de 2021 (BR-UAE Convention full text) — Receita Federal; Decreto nº 10.705, de 26 de maio de 2021 — Planalto; Instrução Normativa SRF nº 208, de 27 de setembro de 2002 (residência de pessoa física); IN SRF nº 208/2002 — Receita Federal (Normas)

Canada — arrival-year scope + UAE-treaty residence (advisory)next data review due 2027-06-30approximate
  • Part-year treatment turns on the FACT of when Canadian residential ties are established (dwelling, spouse/dependants, personal property/social ties per Folio S5-F1-C1), not a mechanical day-count; CRA determines the arrival date factually.
  • Distinguish part-year (factual) residence under s.114 from DEEMED residence: a person who 'sojourns' 183+ days (ITA s.250(1)(a)) is deemed resident for the WHOLE year and taxed on worldwide income throughout — a different, whole-year outcome that can apply to some arrivals.
  • During the non-resident part of the arrival year the individual is still taxable on Canadian-source income listed in s.115 (employment, business, taxable Canadian property).
  • Canada–UAE treaty art. 4 also defines UAE government/political-subdivision bodies as residents; the nationality restriction bites only on the individual limb (art. 4(1)(b)(i)).
  • Because a non-Emirati expat is treaty-non-resident on the UAE side, the treaty's tie-breaker cannot rescue him from continuing Canadian residence — Canadian domestic departure/arrival rules govern, and he should confirm no protocol has amended art.4 before relying on it.
  • Verify the specific in-force / entry-into-force status and any protocol for tax year 2026 against the Department of Finance treaty page before advice; the 403 on the Finance page was a fetch block, not evidence of change.

Source: Income Tax Act, s. 114 — Justice Laws (laws-lois.justice.gc.ca); CRA Income Tax Folio S5-F1-C1, Determining an Individual's Residence Status; Canada–United Arab Emirates Tax Convention Act, 2002 (schedule/treaty text), art. 4; Convention Between Canada and the United Arab Emirates (2002) — Dept of Finance

Chile — arrival-year scope + UAE-treaty residence (advisory)next data review due 2027-06-30approximate
  • 3-year shelter: LIR art. 3 taxes an arriving foreigner ONLY on Chilean-source income for the first 3 years from entry (extendable by the Regional Director in qualified cases); worldwide income applies only after that period expires.
  • Timing hook: domicile can attach from the date of entry if the person intends to stay permanently/significantly (taxation then runs from entry), whereas residence otherwise crystallises on exceeding 183 days in a 12-month period — so 'from arrival' means from acquisition of domicile OR residence, not a fixed statutory split-year date.
  • No statutory split-year regime like the UK SRT and no Spain-style whole-calendar-year worldwide deeming; the arrival year is simply taxed from when residence/domicile is established.
  • Treaty tie-breaker for dual-resident individuals (art. 4(2)): permanent home → centre of vital interests → habitual abode → (final) competent-authority mutual agreement.
  • Treaty caveat for UAE COMPANIES only: art. 4(1)(b)(ii) requires the company be UAE-incorporated with effective management there AND capital ultimately owned/controlled by the UAE, a UAE governmental entity, or UAE-resident individuals — this ownership/nationality restriction does NOT apply to individuals.
  • Treaty provisions have effect from 1 January 2023; confirm any protocol/MLI overlay before relying for a specific year.

Source: Convenio Chile–Emiratos Árabes Unidos — official Spanish treaty text (SII), Art. 4 Residente; SII — Convenios Tributarios Internacionales (Chile–UAE listed 'vigente' 01.01.2023); Ley sobre Impuesto a la Renta (DL 824) art. 3 — worldwide taxation + 3-year foreign-source rule for arriving foreigners; Ley Chile (BCN) — Decreto Ley 824, Ley sobre Impuesto a la Renta; SII — Código Tributario art. 8 N°8 (residente = >183 días en cualquier período de 12 meses)

Colombia — arrival-year scope + UAE-treaty residence (advisory)next data review due 2027-06-30approximate
  • Tax-year nuance: the arrival calendar year is a full RESIDENT year only if the 183-day count (continuous or discontinuous, in any 365-day window) is completed within that same calendar year; if the qualifying stay straddles two calendar years, art. 10 makes the person resident 'a partir del segundo año o periodo gravable' — i.e. resident (whole year) from the second year, leaving the arrival year as a full non-resident year. Never a prorated part-year.
  • Separate nationality-based residence tests in art. 10 (Colombian nationals with family/business seat, 50% of income/assets in Colombia, spouse/minor children resident, etc.) apply independently of the 183-day rule and can make a Colombian national resident for the whole año gravable regardless of physical presence — relevant if the mover is a Colombian national.
  • CO–UAE treaty status is live-moving: signed 2017, and in Aug 2025 the Ministry of Finance prioritised it for congressional submission. Entry into force still requires an approval law, Constitutional Court review, and exchange of ratification instruments — none completed as of the 2026 tax year. Re-verify DIAN's in-force list if used in a later year.
  • Colombia also has a separate (also NOT in force) CO–UAE agreement for exchange of fiscal information — distinct from and not a substitute for a comprehensive income-tax DTA.

Source: Estatuto Tributario art. 10 — Residencia para efectos tributarios (official statute text); DIAN — ¿Eres residente en Colombia para efectos tributarios? (tax authority guidance); DIAN — Convenios Tributarios Internacionales (official in-force treaty list; UAE marked No vigente); DIAN — signed Colombia–UAE Convention text, 12 Nov 2017 (not in force)

Germany — arrival-year scope + UAE-treaty residence (advisory)next data review due 2027-06-30approximate
  • Residence trigger is factual, not date-of-registration: unlimited liability starts the day a Wohnsitz (§ 8 AO — a dwelling kept for continued use) or gewöhnlicher Aufenthalt (§ 9 AO — presence indicating more than temporary stay, generally >6 months, which can straddle two calendar years) is established.
  • Because there is no treaty for 2026, a non-Emirati expat's UAE residence question never arises for Germany — but the absence of a treaty means NO relief mechanism: Germany taxes worldwide income from arrival with only unilateral relief under § 34c EStG (foreign-tax credit/deduction), and the UAE levies no personal income tax so there is typically no foreign tax to credit.
  • Foreign income in the pre-arrival portion of the arrival year is not taxed but enters the Progressionsvorbehalt (§ 32b(1) no. 2 EStG), which can materially raise the rate on the German-period income; special expenses / extraordinary burdens are generally deductible only for the unlimited-liability period.
  • The historic 2010 DE-UAE treaty's residence article covered UAE-side individuals broadly (domicile/residence, not nationality-restricted) and used the exemption-with-progression method, but it is irrelevant for 2026 as it is no longer in force; do not apply it.
  • No known negotiations for a successor DE-UAE treaty as of the research date; re-check before relying on treaty-less status for later years.

Source: § 2 EStG (Umfang der Besteuerung, Begriffsbestimmungen) — Absatz 7 full text; EY Deutschland — DBA mit den Vereinigten Arabischen Emiraten endet zum 31.12.2021 (BMF non-renewal, Art. 30/29); WTS Deutschland — DBA mit den VAE tritt zum 31.12.2021 außer Kraft

Spain — arrival-year scope + UAE-treaty residence (advisory)next data review due 2027-06-30approximate
  • No split-year: residence is all-or-nothing per calendar year. There is an anti-avoidance rule (LIRPF art. 8.2) whereby a Spanish national who moves to a listed tax haven remains taxed as a Spanish resident for the move year plus the next 4 years — not applicable to a genuine foreign national but relevant to Spanish citizens.
  • The residence tests in art. 9 are alternatives: >183 days in the calendar year (counting sporadic absences unless fiscal residence elsewhere is proven), OR main centre/base of economic activities or interests in Spain, OR (presumption) non-separated spouse and minor children habitually resident in Spain.
  • Because there is no split-year, the arrival year is worldwide-taxable from 1 January even if the person arrived in, say, October — double-tax relief for pre-arrival foreign income depends on domestic foreign-tax-credit rules, not a treaty (and, for a UAE mover, not on the ES-UAE DTA which the expat cannot invoke).
  • The ES-UAE DTA Protocol amends only arts. 13 and 25; it does NOT alter the art. 4 residence definition, so the UAE-nationals-only restriction stands.
  • New Spanish residents may separately elect the impatriate 'Beckham regime' (LIRPF art. 93) if eligible — a special non-resident-style taxation, distinct from the ordinary worldwide-income rule above.

Source: BOE-A-2007-1343 — Convenio España–Emiratos Árabes Unidos (consolidated statute text, art. 4); Agencia Tributaria — Residencia habitual en territorio español (IRPF, LIRPF art. 9; tax period = año natural per art. 12); Ley 35/2006 IRPF art. 9 (LIRPF residence criteria)

France — arrival-year scope + UAE-treaty residence (advisory)next data review due 2027-06-30approximate
  • No statutory split-year regime in the UK SRT sense and no whole-year worldwide sweep like Spain: the arrival year is apportioned by CGI art. 166 - worldwide income only from the date domicile is established, French-source income before that date taxable as a non-resident (often an imposition distincte / effective-rate calculation per BOFiP).
  • French domicile itself is tested under CGI art. 4 B (foyer / main abode, professional activity, or centre of economic interests); establishing domicile mid-year triggers the art. 166 cut-off date.
  • The FR-UAE treaty's individual residence test is unusual: because the UAE levies no personal income tax, art. 4 requires domicile/establishment in the UAE, not liability to tax there. French courts (Conseil d'Etat) nonetheless scrutinise whether the person genuinely has UAE domicile before granting treaty benefits.
  • Treaty amended by an avenant signed 6 December 1993; verify the consolidated text and any later protocol before relying on specific distributive articles.
  • This covers French domestic income tax (impot sur le revenu); social levies (prelevements sociaux) and IFI wealth tax have their own residence/scope rules not addressed here.

Source: Code général des impôts, art. 166 (transfert du domicile en France) - Légifrance; Code général des impôts, art. 4 B (domicile fiscal) - Légifrance; BOFiP BOI-IR-CHAMP-10 - Personnes imposables et domicile fiscal; Décret n° 90-631 du 13 juillet 1990 - publication de la convention France - Emirats arabes unis (19 juillet 1989) - Légifrance; Convention avec les Emirats arabes unis (texte) - impots.gouv.fr

United Kingdom — arrival-year scope + UAE-treaty residence (advisory)next data review due 2027-06-30approximate
  • Split-year treatment is NOT the default and is not discretionary: it applies automatically only if the individual meets one of the five arrival Cases in FA 2013 Sch 45 Part 3 — Case 4 (starts to have a UK home), Case 5 (starts full-time work in UK), Case 6 (ceasing full-time work overseas), Case 7 (partner of someone in Case 6), Case 8 (starts to have a UK home). If no Case is met, the individual is taxed on worldwide income for the entire 6 Apr-5 Apr tax year of arrival.
  • UK tax year runs 6 April to 5 April, not the calendar year.
  • From 6 April 2025 the non-domicile/remittance basis was abolished and replaced by a residence-based 4-year Foreign Income and Gains (FIG) regime for new arrivals (broadly those UK-resident after 10 consecutive non-resident years) — relevant to how the arrival-year worldwide charge actually bites, though it does not change the SRT split-year mechanics themselves.
  • UK-UAE treaty timing: signed 12 April 2016, entered into force 25 December 2016; effective for withholding taxes from 1 January 2017 and for other taxes for years beginning on/after 1 January 2017 (UK income tax/CGT from 6 April 2017).
  • The treaty contains a residence tie-breaker (art. 4(3)) and, per the exchange of notes/protocol, competent authorities consider factors such as where senior management is carried on for non-individual dual-residence cases.

Source: Finance Act 2013, Schedule 45, Part 3 (Split Year Treatment) — legislation.gov.uk; Finance Act 2013, Schedule 45 (Statutory Residence Test) — legislation.gov.uk; 2016 UK-UAE Double Taxation Convention (in force) — GOV.UK; The Double Taxation Relief and International Tax (United Arab Emirates) Order 2016, SI 2016/754 — legislation.gov.uk; Finance Act 2013, Schedule 45, Part 1 (statutory residence test; para 2(3) whole-year rule, para 2(4) pointer to Part 3) — legislation.gov.uk

Ireland — arrival-year scope + UAE-treaty residence (advisory)next data review due 2027-06-30approximate
  • Residence day-count (TCA 1997 s.819): resident if present 183+ days in the tax year, OR 280+ days across the current and preceding year with more than 30 days in the current year. Meeting this in the arrival year makes the WHOLE calendar year a resident year.
  • Split-year relief (s.822) applies to EMPLOYMENT INCOME ONLY (not office/directorship income, not investment income, rental, pensions or capital gains). Conditions: resident in the arrival year, not resident the previous year, and will be resident the following year. Finance Act 2024 (s.23) lets an arriving employee claim it via the income-tax return where the in-year authorisation was not obtained.
  • Non-Irish-domiciled residents are taxed on the REMITTANCE basis for foreign-source income and gains (TCA 1997 s.71/s.29) - foreign investment income/gains are taxed only to the extent remitted to Ireland, which materially changes the worldwide-income picture for a mover from the UAE.
  • Irish year of assessment has been the calendar year since 2002 (previously 6 April - 5 April); confirm any pre-2002 historical modelling separately.
  • The Ireland-UAE Convention numbers the Resident article as Article 5 (an extra Article 3 'Income from Hydrocarbons' shifts the usual numbering), not Article 4 - cite Article 5 + Protocol para 2.
  • The Convention has been modified by the MLI (Ireland ratified 29 Jan 2019, UAE 29 May 2019); the Protocol nationality restriction on UAE individual residence is unaffected by the MLI.

Source: Revenue: Synthesised text of the MLI and the Ireland-UAE Double Taxation Convention (Art. 5 Resident; Protocol para 2); Revenue: Split-year treatment in your year of arrival (employment income only; conditions); Revenue Tax and Duty Manual Part 34-00-11 - Split year residence (s.822 TCA 1997); Revenue: United Arab Emirates double taxation treaty page

India — arrival-year scope + UAE-treaty residence (advisory)next data review due 2027-06-30approximate
  • No statutory split-year: s.6 residence is determined for the whole tax year by day-count tests (>=182 days in the year, OR >=60 days in the year plus >=365 days across the preceding 4 years). Meet the test and the entire year is a resident year; fail it and the whole year is non-resident (taxed only on India-source income).
  • Whole-year WORLDWIDE taxation applies only to a Resident and Ordinarily Resident. Under s.6(6) a person non-resident in 9 of the prior 10 years (or present <=729 days in the prior 7 years) is Resident but Not Ordinarily Resident (RNOR); an RNOR is NOT taxed on foreign-source income unless it derives from a business controlled in / profession set up in India. So a typical first-year arrival's foreign income is often out of scope despite whole-year residence.
  • From FY 2026-27 (from 1 April 2026) the Income-tax Act 2025 replaces the 1961 Act and renames 'previous year' to 'tax year', but carries forward the same s.6 day-count residence tests, the RNOR concept and the whole-year (no split-year) scope - substance unchanged.
  • Treaty (art.4) is in force and comprehensive; the 2007 Protocol substituted the 183-day presence test for the UAE side (the original 1992 text merely said 'an individual who is a resident of the UAE'). Tie-breaker in art.4(3): permanent home -> centre of vital interests -> habitual abode -> mutual agreement.
  • To claim India-UAE treaty relief the individual needs a UAE Tax Residency Certificate plus Form 10F (Income Tax Act s.90(4)/(5)); India's GAAR and treaty PPT can still be applied. The UAE 183-day treaty test is separate from India's own s.6 day counts.

Source: Section 6, Income Tax Act 1961 (residence in India) - Income Tax Department; Section 6 in The Income Tax Act, 1961 - Indian Kanoon; India-UAE Agreement for Avoidance of Double Taxation (official DTAA text, Article 4 Resident, as amended by 2007 Protocol); UAE: Comprehensive Agreements - Income Tax Department (treaty status); Income Tax Act 1961 Section 6 — residential status day-count tests (182 / 60+365) and s.6(6) RNOR, no split-year (reproduction)

Italy — arrival-year scope + UAE-treaty residence (advisory)next data review due 2027-06-30approximate
  • The residence test is 'maggior parte del periodo d'imposta' = more than 183 days (184 in a leap year). MIRROR TRAP: if the individual arrives too late in the year to exceed 183 days, they are NON-resident for that entire calendar year (taxed in Italy only on Italian-source income), and full worldwide residence starts the FOLLOWING 1 January — there is no split-year to tax them from the arrival date either way.
  • D.Lgs. 209/2023 (effective 1 Jan 2024) rewrote art. 2 co. 2: the alternative triggers are now civil-law residence, domicile (redefined as the place where personal and family relationships mainly develop), physical presence, OR registration in the resident population registry (anagrafe) — the latter now a rebuttable, not absolute, presumption. Days are counted 'considering also fractions of a day'.
  • Italy grants statutory split-year treatment ONLY via specific treaty protocols (Switzerland and Germany). No such split-year applies under the Italy-UAE treaty or as a matter of domestic law.
  • UAE-side 'liable to tax' caveat: the UAE levies no federal personal income tax, so whether a UAE-resident individual is 'assoggettata ad imposta' under art. 4(1) is doctrinally contested. Italian Supreme Court case-law (Corte di Cassazione) has held that a UAE-resident individual DOES qualify for treaty residence notwithstanding the absence of UAE personal income tax, applying a substance-over-form approach; a UAE tax-residency certificate helps but alternative evidence can suffice.
  • The Additional Protocol (integral part of the Convention) does NOT modify Art. 4; its lettered items concern arts. 7, 8, 9, 15, 24, 25, 28, 29 and, at item (i), exclude income from petroleum and similar activities from the Convention entirely.
  • English text prevails in case of doubt (the Convention was done in Italian, Arabic and English, all equally authentic, English controlling).

Source: Art. 2 TUIR (DPR 917/1986) - Soggetti passivi / residenza fiscale (full statutory text of comma 2); Agenzia delle Entrate - Regole generali per persone fisiche (residenza fiscale): maggior parte del periodo d'imposta, oltre 183 giorni; Agenzia delle Entrate - Circolare n. 20 del 4 novembre 2024, istruzioni sulla residenza fiscale (D.Lgs. 209/2023); Convenzione Italia - Emirati Arabi Uniti per evitare le doppie imposizioni (testo ufficiale, Abu Dhabi 22.01.1995), Art. 4 Residenti - FiscoOggi / Agenzia delle Entrate; Agenzia delle Entrate - Convenzioni per evitare le doppie imposizioni (elenco ufficiale trattati, incl. Emirati Arabi Uniti L. 309/1997)

Japan — arrival-year scope + UAE-treaty residence (advisory)next data review due 2027-06-30approximate
  • Non-permanent resident status ends automatically once cumulative residence exceeds 5 of the past 10 years — worldwide taxation follows; the remittance rule also captures foreign-source income 'paid in Japan' even when earned abroad.
  • Departure trap (not arrival): Japan's national exit tax (国外転出時課税) deems ¥100M+ financial-asset holders resident >5 of the past 10 years to dispose at departure — see the JP income pack caveats.
  • UAE-side 'liable to tax' wording: the UAE levies no personal income tax; Japan–UAE art. 4(1) carries no nationality gate, but a UAE tax-residency certificate remains the practical evidence standard for claiming treaty residence.

Source: NTA No.12006 — Income tax on residents and non-residents (domicile-based residence; non-permanent resident scope); MOF — Japan–UAE Convention, English text (art. 4 Resident + Protocol); PwC — Japan individual residence (corroboration: domicile-day start, non-permanent regime)

Mexico — arrival-year scope + UAE-treaty residence (advisory)next data review due 2027-06-30approximate
  • Mexico has no formal statutory split-year regime; the part-year result follows structurally from residence being a date-based factual status under CFF art. 9 (casa habitación; if also a home abroad, centre of vital interests, deemed in Mexico when >50% of annual income is Mexican-sourced or Mexico is the principal centre of professional activities). There is no explicit 'split-year' article to cite.
  • A change of residence requires filing an aviso with the SAT no later than 15 days before the change (CFF art. 9).
  • Exit-side trap (not arrival): a Mexican who moves to a preferential-tax-regime jurisdiction is deemed to remain a Mexican resident for the year of the notice and the following five fiscal years unless the destination has a broad tax-information-exchange agreement (CFF art. 9) — relevant if later leaving Mexico, not on arrival.
  • MX-AE DTA signed Abu Dhabi 20 Nov 2012, in force 9 Jul 2014, effective from 1 Jan 2015; where the Spanish, Arabic and English texts diverge, the English text prevails — confirm the English wording of art. 4.1.a.i if a borderline case turns on it.
  • The Mexican-side residence definition (art. 4.1.b) is the ordinary OECD liable-to-tax test (domicilio/residencia/sede de dirección), so the nationality restriction bites only on the UAE side.

Source: Código Fiscal de la Federación, Artículo 9 (residencia en territorio nacional); Decreto Promulgatorio – Acuerdo México–Emiratos Árabes Unidos para Evitar la Doble Imposición y su Protocolo (DOF 08/07/2014), official Spanish text incl. Artículo 4; Acuerdo México–EAU doble imposición – texto oficial certificado (ordenjuridico.gob.mx / SRE); LISR Título V – Residentes en el Extranjero con Ingresos en Territorio Nacional (arts. 153–175)

Netherlands — arrival-year scope + UAE-treaty residence (advisory)next data review due 2027-06-30approximate
  • Netherlands has no single dedicated 'split-year' statute; the part-year outcome flows from residence commencing on the actual arrival date under AWR art. 4 (facts-and-circumstances test), with the M-form combining a worldwide resident-period return and a Dutch-source non-resident-period return.
  • The M-form (M-biljet) is compulsory for any year of immigration or emigration and cannot be filed as an ordinary P-form.
  • Certain qualifying inbound employees can elect partial non-resident status linked to the 30%-ruling (box 2/box 3 treated as non-resident); separate regime, not the default migration-year treatment.
  • Treaty is modified by the MLI, but the MLI does not alter the art. 4(1)(b) nationality requirement for UAE individuals (the MLI's dual-resident tiebreaker targets non-individuals).
  • The UAE-national restriction mirrors the Spain-UAE pattern: a foreign (non-Emirati) individual living in the UAE is outside the treaty's personal scope, so Dutch domestic law alone governs the arrival-year position.

Source: Convention between the Kingdom of the Netherlands and the United Arab Emirates (official Belastingdienst treaty text, Art. 4 verbatim); Overheid.nl Treaty Database — NL-UAE Convention (avoidance of double taxation on income); signed 8 May 2007, in force 2 June 2010; Belastingdienst — Filing a tax return for the year of emigration or immigration (M tax return); NetherlandsWorldwide (Dutch government) — Filing a tax return for the year you moved to the Netherlands (M Form mandatory)

New Zealand — arrival-year scope + UAE-treaty residence (advisory)next data review due 2027-06-30approximate
  • The 'arrival date' is precisely the date a residence test is first met: the permanent-place-of-abode test (s YD 1(2)) makes you resident from when the abode exists; the 183-day test (s YD 1(3)-(4)) backdates residence to the FIRST of the >183 days present in any 12-month window — for a fresh migrant this is normally the day of arrival, so worldwide-income taxation can start from that first day rather than the later day the 183-day count is completed.
  • Big mover trap the other way: a new migrant who becomes NZ-resident is usually a 'transitional resident' (ss HR 8, CW 27) and is exempt from NZ tax on most foreign-source income for about 4 years (48 months) from the residence start — so 'part-year worldwide taxation from arrival' is heavily qualified in practice for new arrivals.
  • The NZ-UAE DTA is an in-force COMPREHENSIVE income-tax agreement (UAE taxes covered = income tax and corporation tax; NZ = income tax). The residence article is Article 5, not Article 4 (this treaty's numbering: Art 1 persons, Art 2 taxes, Art 3 hydrocarbons/general, Art 4 general definitions, Art 5 Residence).
  • UAE-side treaty residence defers to 'the laws of the United Arab Emirates'. Post-2023 the UAE domestic individual tax-residence definition is Cabinet Decision No. 85 of 2022 (usual/primary residence + centre of financial and personal interests, or 183 days' presence), so a non-Emirati expat must actually meet UAE domestic residence (and typically hold a UAE Tax Residency Certificate) to invoke the treaty — being covered by the definition is not automatic merely from holding a UAE residence visa.
  • The original Protocol to the DTA treats UAE government bodies (incl. Abu Dhabi Investment Authority and Dubai Investment and Development Authority) as UAE residents/governmental institutions; no protocol has amended the individual-residence definition (IRD NIA: 'no future protocols anticipated').
  • Confirmed correction: the New Zealand income-tax year runs 1 April to 31 March (an automated page-summary that returned 'July 1–June 30' was wrong).

Source: Income Tax Act 2007, s YD 1 — Residence of natural persons (NZ Legislation); IRD — Tax residency status for individuals (183-day rule, permanent place of abode, backdating); IRD — Tax for New Zealand tax residents (part-year: split resident vs non-resident income; start date = first day of residence; 1 April–31 March year); IRD — Temporary tax exemption for transitional residents (~4-year foreign-income exemption for new migrants); Double Taxation Relief (United Arab Emirates) Order 2004 (SR 2004/177) — full DTA text, Article 5 Residence

Poland — arrival-year scope + UAE-treaty residence (advisory)next data review due 2027-06-30approximate
  • Poland has NO UK-style statutory split-year clause in the PIT Act. The part-year outcome is not a named statutory regime; it derives from art. 3 as interpreted by the binding-protective MoF objaśnienia podatkowe of 29.04.2021, sec. 2.3 ('Zmiana rezydencji podatkowej w trakcie roku podatkowego'): unlimited liability applies only up to/from the day residence exists, then Polish-source only. The MoF worked example (Przykład 9) illustrates a departure; the arrival case is the mirror image — worldwide liability runs FROM the residence-start day.
  • Residence trigger is disjunctive: centre of personal/economic interests (ośrodek interesów życiowych) in Poland OR physical presence >183 days in the tax year (art. 3 ust. 1a). The 183-day test counts days across the whole calendar year, so a person arriving late in the year may not become resident until the vital-interests test is met, while a mid-year arrival who crosses 183 cumulative days can be resident for the residence period.
  • The Poland–UAE DTA is an in-force COMPREHENSIVE income-and-capital treaty (signed 31.01.1993, Dz.U. 1994 nr 81 poz. 373), amended by a Protocol signed 11.12.2013 and in force 1 May 2015, and further modified by the MLI (the cited synthesised text reflects both). Footnote in the official synthesised text expressly states Art. 4(1) is 'presented as amended by the Amending Protocol'.
  • Because a non-Emirati UAE-resident individual is NOT a treaty resident of the UAE under art. 4(1)(b)(i), the treaty's tie-breaker and relief articles are unavailable to such a person — Polish domestic residence law alone governs the Poland side, and there is no treaty protection against Polish worldwide taxation if Polish residence is established.
  • Art. 4 tie-breakers for a genuine dual-resident individual (permanent home → centre of vital interests → habitual abode → nationality → MAP) exist, but they only engage once the person qualifies as a resident of BOTH states under para 1 — which a non-Emirati cannot on the UAE side.

Source: Synthesised text of the MLI and the Poland–UAE Agreement (Art. 4 Resident, as amended by the Amending Protocol) — Polish Ministry of Finance / podatki.gov.pl; Umowa PL–ZEA o unikaniu podwójnego opodatkowania, Abu Zabi 31.01.1993 (Dz.U. 1994 nr 81 poz. 373) — ISAP, Sejm; Objaśnienia podatkowe z 29 kwietnia 2021 r. ws. rezydencji podatkowej oraz zakresu obowiązku podatkowego osób fizycznych w Polsce (sec. 2.3 Zmiana rezydencji w trakcie roku) — Ministerstwo Finansów; MoF landing page for the 29.04.2021 residency tax explanations — gov.pl/finanse

Portugal — arrival-year scope + UAE-treaty residence (advisory)next data review due 2027-06-30approximate
  • Anti-abuse (CIRS Art. 16(14)/(16)): a departure year with >183 days' presence plus post-departure income stays fully resident (n.º 14), and reacquiring residence during the SUBSEQUENT year restores whole-period residence (n.º 16) — a brief emigration cannot manufacture a non-resident window.
  • Departure trap: crypto-assets are DEEMED DISPOSED on loss of Portuguese residency (CIRS Art. 10, OE2023) — an exit charge at 28% on unrealised crypto gains; there is NO general exit tax on ordinary securities/property portfolios (rolled-over corporate-reorganisation gains also crystallise).
  • IFICI registration is deadline-bound (by 15 January following the first resident year) and excludes anyone who was PT-resident in the prior 5 years or ever held old NHR; foreign PENSIONS get no IFICI relief (the old NHR 10% pension rate is closed to new applicants).
  • The 2025 UK–Portugal Convention (SI 2025/1300, in force 29 Dec 2025) replaced the 1968 DTC from tax year 2026 — pension/rental/dividend routing is modelled in the treaty rows.

Source: CIRS Art. 16.º (residência; residência parcial n.º 3-4; anti-abuse same-year reacquisition n.º 14) — Lei 82-E/2014; EBF Art. 58.º-A (IFICI/NHR 2.0 — Lei 82/2023 OE2024) + Portaria n.º 352/2024/1 (eligible professions/activities); Portugal–UAE Convention 2011, English text (Art. 4 Resident — domicile AND national gate) — Resolução AR n.º 47/2012

Sweden — arrival-year scope + UAE-treaty residence (advisory)next data review due 2027-06-30approximate
  • The arrival-year tax return covers the whole calendar year (beskattningsår = kalenderår, IL 1 kap. 13 §), but WORLDWIDE-income (unlimited) liability applies only from the arrival/residence date; before that the individual is limited tax liable (begränsat skattskyldig) on Swedish-source income only — no statutory 'split-year' mechanism, it flows from when residence/habitual abode begins.
  • Three independent triggers for unlimited liability (IL 3 kap. 3 §): (1) bosatt (domiciled/real home) i Sverige; (2) stadigvarande vistelse — habitual abode, in practice a continuous stay of ~6 months or more; (3) väsentlig anknytning (essential connection) for someone previously resident. A returning Swede can be unlimited liable via essential connection even before physical arrival.
  • 'Stadigvarande vistelse' is not statutorily defined; Skatteverket proposed (2024) codifying it — check current status before relying on the ~6-month rule of thumb.
  • Limited-liability income in the pre-arrival portion (e.g. Swedish employment) may be taxed under SINK (Lag 1991:586) at a flat rate rather than under ordinary IL rules.
  • No Sweden–UAE income-tax treaty means no treaty tie-breaker and no treaty relief; double taxation is relieved only by Sweden's unilateral foreign-tax-credit rules (avräkningslagen, Lag 1986:468). The UAE nationals-only residence-article issue (as in the Spain–UAE DTA) is moot here because no DTA exists.

Source: Inkomstskattelag (1999:1229) — Sveriges riksdag (SFS full text; 3 kap. 3 §, 3 kap. 8 §, 1 kap. 13 §); Inkomstskattelag (1999:1229) (IL) — Lagen.nu; Liability for taxation — Skatteverket (English; unlimited vs limited liability, worldwide income); Lag (2016:409) om avtal mellan Sverige och Förenade Arabemiraten om utbyte av upplysningar i skatteärenden — Sveriges riksdag (TIEA, not a DTA); Lag (2016:409) — Skatteverket Rättslig vägledning (confirms information-exchange agreement with UAE, in force 1 April 2017)

Singapore — arrival-year scope + UAE-treaty residence (advisory)next data review due 2027-06-30approximate
  • Singapore taxes on a TERRITORIAL basis: even a resident is generally not taxed on foreign-sourced income (most foreign income received by individuals is exempt), so the arrival-year 'whole-year worldwide' comparison to Spain does not apply — 'whole_year' here describes only that residency STATUS is all-or-nothing for the YA, not a worldwide charge.
  • The DTA covers any UAE-resident individual only if that individual is a 'resident ... in accordance with the taxation laws' of the UAE (art. 4.1); historically the UAE levied no federal personal income tax, which can make it factually hard for an expat to establish treaty residence under para 1 — the UAE now addresses this domestically via its 2023 residence rules / Tax Residency Certificate practice.
  • The Protocol signed 31 Oct 2014 (in force 16 Mar 2016, effective 1 Jan 2017) amended Art. 4 only in respect of paragraph 2(a)(iii)/(iv) — the UAE government/statutory-body inclusion list — and did NOT alter the individual residence definition (para 1) or the individual tie-breaker (para 3).
  • Art. 4(2)'s enumerated 'resident' list is an inclusive extension for the two Governments, central banks, sovereign funds and statutory bodies — it does not narrow individual residence and imposes no nationality condition.
  • If a mid-year arrival meets neither the 183-day test nor the 2-year/3-year concessions for that basis year, the first Year of Assessment is a NON-resident year (flat/withholding non-resident rates on Singapore-source employment income), with resident status starting the following YA — a timing trap, not a split-year apportionment.

Source: Singapore–UAE Agreement for the Avoidance of Double Taxation (full text incl. 2014 Protocol Annex B and 2019 MLI Annex A) — IRAS; IRAS — Working out my tax residency (183-day rule, qualitative test, 2-year/3-year concessions); Singapore — Individual — Residence (Income Tax Act s 2; no split-year; preceding-year basis) — PwC Worldwide Tax Summaries; Singapore–UAE Comprehensive DTA (Avoidance of Double Taxation, concluded 1 Dec 1995, in force 30 Aug 1996) — full text incl. Article 4 (Resident), IRAS; Singapore–UAE Limited DTA (International Air Transport, 27 Oct 1989) — IRAS (Article 4 = Refund; red-herring instrument)

Thailand — arrival-year scope + UAE-treaty residence (advisory)next data review due 2027-06-30approximate
  • Thai residence attaches to the WHOLE calendar year, but the taxable base is not full worldwide-arising income: residents are taxed on Thai-source income regardless of where paid, and on foreign-source income only to the extent it is remitted into Thailand (Revenue Code s. 41 para. 2, as interpreted by Departmental Orders Por.161/2566 and Por.162/2566 from 1 Jan 2024). A proposal to tax worldwide income on an arising basis had NOT passed into law as of mid-2026.
  • Because residence is a binary 180-day whole-year test, a mover who arrives after ~4 July and therefore cannot reach 180 days is a NON-resident for the entire arrival calendar year (taxed only on Thai-source income), then typically becomes resident from 1 Jan of the following year.
  • DTA practical trap: Article 4(1) requires the individual to be 'liable to tax' in the UAE by reason of domicile/residence. The UAE levies no personal income tax, so a UAE-resident individual's ability to satisfy the 'liable to tax' limb (and thus obtain a UAE Tax Residency Certificate for treaty purposes) can be contested despite the absence of a nationality bar — confirm current UAE TRC practice before relying on treaty relief.
  • No amending protocol to Article 4 was located; the residence definition read is the original 2000 treaty text as published by the Thai Revenue Department.

Source: Thai Revenue Department — Thailand-UAE DTA, Articles 1-5 (official English text, Art. 4 Resident); Thai Revenue Code, Section 41 (income tax — resident 180-day rule, full text); Thai Revenue Department — Double Tax Agreement (DTA) index (treaty list incl. UAE); ASEAN Briefing — Double Taxation Avoidance Agreement between Thailand and the United Arab Emirates (full treaty text; Article 4 verbatim cross-check); The Revenue Department (English) — Personal Income Tax / Section 41 resident definition (180 days in any tax/calendar year)

United States — arrival-year scope + UAE-treaty residence (advisory)next data review due 2027-06-30approximate
  • Default arrival-year treatment is DUAL-STATUS: worldwide-income taxation runs only from the residency starting date, and dual-status filers cannot use the standard deduction and are barred from joint filing (in the general case).
  • Optional full-year-resident elections exist that override dual status: (a) IRC §6013(g)/(h) — a resident/citizen spouse and nonresident spouse may elect to treat the nonresident as a resident for the ENTIRE year and file jointly; (b) IRC §7701(b)(4) first-year residency election. Choosing either makes the person a whole-year resident like Spain.
  • Residency starting date has a de minimis exception: up to 10 days of U.S. presence can be disregarded if the individual maintained a tax home and closer connection abroad during those days (IRC §7701(b)(2)(C)).
  • 'No-lapse' rule (IRC §7701(b)(10)): if the person was a U.S. resident in the immediately preceding year (or becomes one the following year), continuity rules can extend resident treatment across the gap — this is separate from the arrival-year dual-status default and does not make a first-time arrival a whole-year resident.
  • Green-card holders are treated as U.S. tax residents worldwide even while living in the UAE; the absence of a U.S.-UAE treaty means no treaty tie-breaker or reduced-rate relief — only unilateral mechanisms (foreign tax credit IRC §901, foreign earned income exclusion IRC §911) mitigate double tax.
  • A U.S.-UAE FATCA intergovernmental agreement exists but is an information-exchange arrangement, NOT a comprehensive income-tax treaty and confers no residence-article or rate relief.

Source: IRS — Residency starting and ending dates (dual-status; residency starting date under substantial presence / green card tests); 26 CFR §301.7701(b)-4 — Residency time periods (dual-status / part-year residence); IRS Publication 519, U.S. Tax Guide for Aliens (Dual-Status Aliens); IRS — United States income tax treaties A to Z (UAE absent; primary treaty-partner list)

Vietnam — arrival-year scope + UAE-treaty residence (advisory)next data review due 2027-06-30approximate
  • The whole-calendar-year worldwide-tax trap bites in full only if you are present 183 days or more IN the arrival calendar year. If you are present under 183 days in the arrival calendar year but reach 183 days across the 12 months from your first arrival date, your FIRST tax period is instead the 12 consecutive months running from that first-arrival date (worldwide income taxed over that window); from the second year the tax year reverts to the calendar year (Circular 111/2013/TT-BTC art. 1, worked example 'B': arrival 20 Apr 2014 → first tax year 20 Apr 2014–19 Apr 2015, second tax year 1 Jan–31 Dec 2015).
  • Residency is also triggered — without 183 days' presence — by having a registered permanent residence or a leased/rented dwelling in Vietnam for 183 days or more in the tax year, unless you prove tax residence elsewhere (Law 04/2007/QH12 art. 2.2; Circular 111/2013/TT-BTC art. 1).
  • Where the first 12-month tax period overlaps months already counted in the following calendar-year tax period, PIT paid on the double-counted months is credited to avoid double taxation (Circular 111/2013/TT-BTC art. 1).
  • Residents are taxed on worldwide employment income at progressive rates 5%–35%; foreign tax credit / treaty relief applies. Because the UAE levies no personal income tax on individuals, the VN-UAE DTA operates mainly to allocate Vietnam's taxing rights and to certify UAE residence (via a UAE Tax Residency Certificate) rather than to relieve UAE tax.
  • Both Vietnam and the UAE are parties to the OECD Multilateral Instrument (MLI); the principal-purpose test and other MLI provisions may modify access to VN-UAE treaty benefits where the treaty is a covered tax agreement.
  • The treaty Article 4 wording was read directly from the scanned official English text of the Agreement (UAE Ministry of Finance / Vietnam Ministry of Finance registry); a professional advisor should confirm current in-force status and any protocol/MLI synthesised text before relying on it.

Source: Circular No. 111/2013/TT-BTC guiding the Law on Personal Income Tax (art. 1 — resident definition; first-tax-year 12-month rule with worked example 'B'); Circular No. 111/2013/TT-BTC (English full text, thuvienphapluat); Vietnam - Individual - Residence (PwC Worldwide Tax Summaries, pointer to statute); Agreement between Vietnam and the United Arab Emirates for the Avoidance of Double Taxation — full English treaty text (Article 4 Resident), signed 16 Feb 2009; Asiapedia — Double Taxation Avoidance Agreement between the United Arab Emirates and Vietnam (Dezan Shira, hosts the treaty PDF)

South Africa — arrival-year scope + UAE-treaty residence (advisory)next data review due 2027-06-30approximate
  • Two resident tests exist. 'Ordinarily resident' (the usual trigger for a genuine mover) makes a person resident from the actual day they become ordinarily resident, so worldwide income runs from that date. The separate day-counting 'physical presence test' (s1(1)(a)(ii): >91 days in the current YoA AND >91 days in each of the five preceding YoA AND >915 aggregate days over those five years) deems residence to start on the first day of the year of assessment in which the test is first met - a nuance that can look more like whole-year for that specific test, but it rarely applies to a first-time arrival.
  • No named statutory split-year regime like the UK SRT (FA 2013 Sch 45); the part-year outcome is a consequence of the s1(1) 'resident' definition applying from the day residence starts, plus s9H CGT deemed-disposal rules on changes of residence.
  • The SA-UAE DTA is modified by the MLI, including the Principal Purpose Test (PPT) - treaty benefits (including UAE residence relief) are subject to anti-abuse denial. MLI effective for SA 'other taxes' for taxable periods from 1 July 2023.
  • UAE-side proof: because the UAE has no personal income tax, SARS in practice expects a UAE Tax Residency Certificate and evidence of the Art 4(2) tie-breaker factors to accept exclusive UAE residence; merely holding a UAE visa is not automatically sufficient.
  • A separate DTA provision (government service) can override where a person became UAE-resident solely to render services to the UAE government - not relevant to an ordinary private mover but flagged in SARS FAQ guidance.

Source: SARS Interpretation Note 3 (Issue 2) - Resident: definition in relation to a natural person - ordinarily resident; SARS - Synthesised text of the MLI and the SA-UAE Double Taxation Agreement (Art 4 Resident); Income Tax Act 58 of 1962 (consolidated) - LawLibrary; SARS - Double Taxation Agreements & Protocols (Rest of the World); SARS — Double Taxation Agreements & Protocols (index of official treaty texts)

Property growth defaults30

Per-country long-run REAL residential price growth used when a property has no explicit growth rate — measured from BIS real indices, with forward defaults capped at 2.5% real (the 1995-2024 window was an exceptional boom). Every property can override.

WhatFlagWhy / what isn’t captured
Czechia — property growth default 2% real (measured 2%, ~2008-2024, BIS/CNB real Czech RPP index)next data review due 2027-01-31low confidence
  • Short series with a very strong post-2015 real boom (+44% real 2015-2023 per CNB); default trimmed below the raw window CAGR to avoid anchoring on a frothy endpoint.

Source: Czech National Bank - housing market and house prices; BIS residential property prices - data portal

United Arab Emirates — property growth default 1% real (measured 1.9%, Underpinned by the BIS real (CPI-deflate)next data review due 2027-01-31medium confidence
  • EXCEPTION to the clamp formula: full-cycle real growth is ~0% (peak-to-peak NEGATIVE); the specialist default is 1.0 despite the +1.9 full-window measurement. Extreme cyclicality makes any single forward number fragile: real prices fell ~40% in the 2008–09 crash, recovered to a fresh peak by 2014, fell ~28% through 2020–21, then boomed again into 2024. The chosen 1.0%/yr real is a conservative judgement, not a measured trend — the same BIS data supports anything from −0.8%/yr (2014 peak base) to +1.9%/yr (2004 base). Do NOT extrapolate the 2021–2024 ups

Source: BIS Real Residential Property Prices for the UAE, index level 2010=100 (FRED QAER628BIS); BIS Real Residential Property Prices for the UAE, year-on-year % change (FRED QAER771BIS); BIS — Residential property price developments in the United Arab Emirates (box note, Nov 2015)

Argentina — property growth default (no defensible series)next data review due 2027-01-31medium confidence
  • Argentina has no reliable CPI-deflated residential price index over a long window; repeated inflation regimes and CPI credibility breaks make any real CAGR a guess. Returning null per instruction.

Source: BIS residential property prices - data portal (Argentina not in real long series)

Australia — property growth default 2.5% real (measured 3.4%, ~1995-2025, BIS real Australia RPP index)next data review due 2027-01-31medium confidence
  • Very strong real growth over 30yr; slightly trimmed for a conservative forward default given stretched valuations.

Source: Australia house price growth: 30-year view (DPN); BIS residential property prices - data portal

Belgium — property growth default 2.5% real (measured 2.6%, ~1995Q1-2024, BIS real Belgium RPP index)next data review due 2027-01-31medium confidence
  • Unusually steady real appreciation with no GFC crash; among the more reliable long real uptrends in the euro area.

Source: BIS residential property prices - data portal; OECD housing prices (real HPI)

Brazil — property growth default 0.5% real (measured 0.5%, ~2008-2024 (BIS/FIPE-ZAP real series sta)next data review due 2027-01-31medium confidence
  • Short series: strong 2008-2014 real boom then a multi-year real decline; 2024 real level still below post-GFC per BIS. Low-to-flat real CAGR; treat as provisional.

Source: BIS residential property price statistics, Q3 2024; BIS residential property prices - data portal

Canada — property growth default 2.5% real (measured 3.3%, ~1995Q1-2024, BIS real Canada RPP index)next data review due 2027-01-31medium confidence
  • Among the strongest OECD real uptrends (roughly tripled in real terms); default trimmed below the raw window CAGR given elevated valuation/affordability at the endpoint.

Source: Bank of Canada - long-term evolution of house prices; BIS residential property prices - data portal

Switzerland — property growth default 1.8% real (measured 1.8%, ~1995Q1-2024, BIS real Switzerland RPP i)next data review due 2027-01-31medium confidence
  • Low-volatility steady real appreciation from a mid-1990s trough (after the early-90s decline); ~1.7-2%/yr real.

Source: BIS residential property prices - data portal; OECD housing prices (real HPI)

Chile — property growth default 2.5% real (measured 2.5%, ~2002-2024, BIS real Chile RPP index (se)next data review due 2027-01-31medium confidence
  • Shorter EME series with strong 2000s-2010s real growth and a recent slowdown; UF-indexation and inflation make real deflation sensitive to method.

Source: BIS residential property prices - data portal; BIS residential property price statistics, Q3 2024

Colombia — property growth default 2% real (measured 2%, ~2004-2024 (Colombia BIS real series dis)next data review due 2027-01-31medium confidence
  • Late-1990s crash then a long 2004-2016 real boom and subsequent flattening; using the post-crash window avoids an artificially high CAGR off the 1999 trough.

Source: BIS residential property prices - data portal; BIS residential property price statistics, Q3 2024

Spain — property growth default 1.3% real (measured 1.3%, ~1995Q1-2024, BIS real Spain RPP index)next data review due 2027-01-31medium confidence
  • Severe boom (to 2007) and bust (-40% real to 2014); 2024 real level still below 2007 peak, so long-window real CAGR is modest despite huge mid-cycle swings.

Source: BIS residential property price statistics, Q4 2024; OECD housing prices (real HPI)

France — property growth default 1.7% real (measured 1.7%, ~1995Q1-2024, BIS real France RPP index)next data review due 2027-01-31medium confidence
  • Strong 1998-2008 real boom then long plateau with a 2022-24 nominal/real dip; long-window real CAGR ~1.7-1.9%.

Source: BIS residential property prices - data portal; OECD housing prices (real HPI)

India — property growth default 1% real (measured 1%, ~2009-2024 (BIS India real series from ~)next data review due 2027-01-31medium confidence
  • Short series; real prices roughly flat-to-slightly-positive over 2013-2022 with a recent rebound (+3% yoy). High-inflation deflation makes real readings noisy.

Source: BIS residential property price statistics, Q4 2025; BIS residential property prices - data portal

Italy — property growth default 0% real (measured -0.2%, ~1995Q1-2024, BIS real Italy RPP index)next data review due 2027-01-31medium confidence
  • Italy is a genuine long-run real decliner: 2024 real level is at/below the late-1990s and ~20+ index points below 2010. A ~0% (slightly negative) default is defensible, not a data error.

Source: OECD housing prices (real HPI); BIS residential property prices - data portal

Mexico — property growth default 1.5% real (measured 1.5%, ~2005-2024 (BIS Mexico real series start)next data review due 2027-01-31medium confidence
  • Shorter EME series; modest steady real growth (+~5% yoy nominal-driven in 2024). Not backdated to 1970s.

Source: BIS residential property price statistics, Q3 2024; BIS residential property prices - data portal

Poland — property growth default 1% real (measured 1%, ~2010-2024 (BIS Poland real series is sh)next data review due 2027-01-31medium confidence
  • Short series; recent nominal boom largely eroded in real terms by 2021-2023 high inflation. Duller/longer reading preferred over the 2020-21 boom endpoint.

Source: OECD - Housing market trends in Czechia and Poland; BIS residential property prices - data portal

Singapore — property growth default 1% real (measured 1%, ~1995Q1-2024, BIS long real Singapore RP)next data review due 2027-01-31medium confidence
  • Window starts near the 1996 peak (pre-Asian-crisis), so real CAGR is low and highly cyclical; heavy policy (cooling-measure) intervention.

Source: BIS residential property prices - data portal; BIS residential property price statistics, Q4 2024

Thailand — property growth default 1% real (measured 1%, ~1995-2024, BIS real Thailand (Bangkok) )next data review due 2027-01-31medium confidence
  • 1997 Asian-crisis crash dominates the early window; slow real recovery since, ~+1% yoy recently. Long-run real CAGR is low.

Source: FRED - Real Residential Property Prices for Bangkok, Thailand (BIS); BIS residential property prices - data portal

Vietnam — property growth default (no defensible series)next data review due 2027-01-31medium confidence
  • Vietnam is not covered by BIS RPP or OECD analytical house prices; available private indices are short, urban-only and not consistently CPI-deflated. Returning null per instruction.

Source: BIS residential property prices - data portal (Vietnam not covered)

South Africa — property growth default 1.5% real (measured 1.5%, ~2000-2024, BIS real South Africa RPP in)next data review due 2027-01-31medium confidence
  • Large 2000-2008 real boom (roughly doubled) then a long real decline/flat trend; 2024 real level below the post-GFC peak per BIS. Long-window CAGR is modest.

Source: BIS residential property price statistics, Q4 2025; BIS residential property prices - data portal

Germany — property growth default 0% real (measured -0.1%, ~1995Q1-2024, BIS real Germany RPP index)next data review due 2027-06-30approximate
  • Two regimes: real decline 1995-2008, then a strong 2010-2022 boom and 2022-23 correction; net long-window real CAGR is low (~0.6-1%). Cross-check 2026-07-13: measured -0.09 vs sweep 0.8 — checker value adopted.

Source: BIS residential property prices - data portal; OECD housing prices (real HPI)

United Kingdom — property growth default 2.5% real (measured 3.2%, ~1995Q1-2024, BIS/OECD real (CPI-deflate)next data review due 2027-06-30approximate
  • Strong 1996-2007 real boom then plateau; ~2.5-2.7%/yr real over the window. Slight downward rounding for a conservative default given a high real level today. Cross-check 2026-07-13: measured 3.16 vs sweep 2.5 — checker value adopted.

Source: BIS residential property prices - data portal; OECD housing prices (real HPI)

Greece — property growth default 1.3% real (measured 1.3%, ~1995Q1-2024, BIS real Greece RPP index)next data review due 2027-06-30approximate
  • Boom to 2008 then a ~-40% real depression (2008-2017) and a sharp post-2018 rebound (+34% real over 5yr); 2024 real level still below the 2008 peak. Long-window real CAGR near zero-to-low. Cross-check 2026-07-13: measured 1.34 vs sweep 0.5 — checker value adopted.

Source: Global Property Guide - 5-year real house price change, Europe; BIS residential property prices - data portal

Ireland — property growth default 2.5% real (measured 3.4%, ~1995Q1-2024, BIS real Ireland RPP index)next data review due 2027-06-30approximate
  • Extreme Celtic-Tiger boom then ~-50% real crash (2007-2013) and recovery; window CAGR is positive but the path is among the most volatile in the sample. Cross-check 2026-07-13: measured 3.37 vs sweep 2 — checker value adopted.

Source: BIS residential property prices - data portal; OECD housing prices (real HPI)

Japan — property growth default 0% real (measured -1%, ~1995Q1-2024, BIS real Japan RPP index)next data review due 2027-01-31approximate
  • Japan is a genuine long-run real decliner post-bubble: ~-1.0%/yr real 1995-2024, still ~26% below the 1995 real level — the clamp-to-zero default hides that. Strong Tokyo/urban-led recovery since the 2010 trough (~+1.3%/yr real nationally; Tokyo condos far stronger) vs flat-to-declining rural: location matters more than in most markets.

Source: BIS real residential property prices for Japan (QJPR628BIS, via FRED — 1995Q1 160.15 vs 2024Q1 122.92); BIS residential property prices - data portal

Netherlands — property growth default 2.5% real (measured 3%, ~1995Q1-2024, BIS real Netherlands RPP i)next data review due 2027-06-30approximate
  • Boom to 2008, ~-25% real to 2013, then a strong recovery to new highs; volatile but net positive real CAGR. Cross-check 2026-07-13: measured 3 vs sweep 1.9 — checker value adopted.

Source: BIS residential property prices - data portal; OECD housing prices (real HPI)

New Zealand — property growth default 2.5% real (measured 4%, ~1995Q1-2024, BIS real New Zealand RPP i)next data review due 2027-06-30approximate
  • Very strong real appreciation (roughly tripled) with a sharp 2022-23 correction; trimmed for a conservative forward default off a still-elevated base. Cross-check 2026-07-13: measured 3.96 vs sweep 3.2 — checker value adopted.

Source: BIS residential property prices - data portal; OECD housing prices (real HPI)

Portugal — property growth default 1.85% real (measured 1.85%, 1988Q1-2025Q4, BIS real Portugal RPP ind)next data review due 2027-01-31approximate
  • The 1.85%/yr real blends two utterly different eras: real prices peaked ~1992, then declined for two decades to the 2012-13 austerity trough (~-30% real), before a relentless post-2015 boom (~+8%/yr real 2015-2025, +130% real in a decade) driven by foreign demand, tourism conversion and undersupply. Highly regional — Lisbon/Porto/Algarve captured most of it while much of the interior stagnated. The boom pace is deliberately NOT extrapolated.

Source: BIS real residential property prices for Portugal (QPTR628BIS, via FRED — 1988Q1 98.28 vs 2025Q4 196.18); BIS residential property prices - data portal

Sweden — property growth default 2.5% real (measured 4.1%, ~1995Q1-2024, BIS real Sweden RPP index)next data review due 2027-06-30approximate
  • One of the strongest real appreciations in the OECD (roughly tripled in real terms to 2021) then a 2022-23 correction; trimmed for conservatism. Cross-check 2026-07-13: measured 4.1 vs sweep 3.2 — checker value adopted.

Source: BIS residential property prices - data portal; Bank of Canada - long-term evolution of house prices

United States — property growth default 2.3% real (measured 2.3%, ~1995Q1-2024, BIS real US RPP index (Cas)next data review due 2027-06-30approximate
  • Two boom-bust cycles (2006 peak, 2012 trough, 2022 peak); very-long-run US real growth is closer to ~0.5-1%, so 1.4% reflects the specific 1995-2024 window ending near a high. Cross-check 2026-07-13: measured 2.31 vs sweep 1.4 — checker value adopted.

Source: BIS residential property prices - data portal; OECD housing prices (real HPI)

State-pension claim-age rules31

When each country's state pension can be claimed, deferred or taken early, and the published uplift/reduction factors. Countries marked "not yet coded" have no claim-age modelling — their state-pension timing simply isn't simulated yet.

WhatFlagWhy / what isn’t captured
Australia Age Pension — state-pension claim-age rulesnext data review due 2027-01-31medium confidence
  • No claiming-age lever: the Age Pension is means-tested (income + assets tests) and the Pension Bonus Scheme (a deferral incentive) closed to new entrants in 2014.

Source: Services Australia — Age Pension

Belgium statutory pension (pension légale / rustpensioen) — state-pension claim-age rulesnext data review due 2027-01-31medium confidence
  • No claiming-age lever in 2026 — a genuine gap year: the old pension bonus was abolished as of 1 Jan 2026 (last accrual 1 Jul 2024 – 31 Dec 2025) and the new birth-cohort bonus/malus regime (2%/4%/5% per year by birth cohort) only starts 1 Jan 2027, so this row needs re-review before 2027. Normal age is 66 for pensions starting 1 Feb 2025 – 31 Jan 2030, rising to 67 from 1 Feb 2030 (not modelled). Early claiming exists (63 with a 42-year career, 61/43, 60/44) but is contribution-history-dependent and simplified out per the FR/ES precedent. Worldwide inflation-indexation of payments abroad is assumed (no UK-style freeze) but was not verified against a primary SFPD source for non-EU/UAE residence.

Source: Loi du 10 août 2015 (legal pension age) — ejustice.just.fgov.be Justel; BDO Belgium — Social measures: Pension reform (bonus/malus 1 Jan 2027 + bands); Deloitte Belgium — Law including key employment and individual tax reforms approved by parliament (old-bonus abolition dates); Loyens & Loeff — Belgium's pension reform: early retirement and the bonus–malus impact for HR; SFPD (Federal Pensions Service) — retirement-age pages

Switzerland AHV/AVS state pension — state-pension claim-age rulesnext data review due 2027-07-31medium confidence
  • Early reduction of 6.8%/yr is exactly linear (official leaflet 3.04). The deferral supplement is CONVEX (5.2% at 1yr up to 31.5% at 5yr); the linear 6.3%/yr here is anchored at the 5-year cap and OVERSTATES years 1–4 by ~1–2pp — approximate, verify against the official AHV table for partial deferrals. Reference age 65 (men and women born 1964+); the women's transitional schedule (reference age below 65, early draw from 62 for those born 1961–1969, settled 65 from 2029) is not modelled. Partial-pension (20–80%) drawdown is not modelled.

Source: 3.04 OASI Benefits — Flexible retirement (official AHV/IV leaflet, position 1 Jan 2026); finpension — Everything you need to know about AHV; brag.ch — What is an AHV deferral? (deferral increment table)

Chile Pensión Garantizada Universal (PGU) — state-pension claim-age rulesnext data review due 2027-02-28medium confidence
  • No claiming-age lever: the PGU (Ley 21.419) is a flat, non-contributory, residency-based floor with no early claim and no actuarial deferral uplift. NOT modelled: the means test (must be in the poorest 90%; tapers to zero above a base pension of CLP 1,252,602/mo, full amount only below CLP 789,139/mo), the eligibility rules (≥20 years' Chile residence from age 20, ≥4 of the last 5 years before applying), the higher CLP 250,275/mo rate at age 82+, and the annual February uprating of the peso amounts. The gender-differentiated AFP capitalisation pillar (DL 3.500, 65M/60F) is a separate, unmodelled scheme.

Source: ChileAtiende — Pensión Garantizada Universal (PGU); ChileAtiende — Aumento de la Pensión Garantizada Universal (PGU); Superintendencia de Pensiones — AFP pillar retirement ages

Czech State Old-Age Pension (starobní důchod) — state-pension claim-age rulesnext data review due 2027-07-31medium confidence
  • normalAge 67 applies to those born 1989 or later (earlier cohorts follow a statutory sliding table — cohort simplification). Early claim (up to 3 years before statutory age since 1 Nov 2024) requires at least 40 years of pension insurance — eligibility years are not modelled. Both the ~6%/yr early reduction (−1.5% per started 90 days) and the ~6%/yr deferral uplift (+1.5% per started 90 days while working and not drawing) apply ONLY to the earnings-related component, not the flat base amount, so the effective change on the total pension is below the headline rate. From 2026 the early reduction is halved (~3%/yr) for claimants with 45+ insurance years — not modelled. 35 insurance years needed for entitlement — not modelled.

Source: ČSSZ — Retirement age (Důchodový věk); ČSSZ — Early old-age pension (Předčasný starobní důchod); portal.gov.cz — Adjustment of old-age pension for gainful activity after entitlement; OECD Pensions at a Glance 2025 — Czechia country note

Spain state pension (Seguridad Social) — state-pension claim-age rulesnext data review due 2027-01-31medium confidence
  • Modelled defer-only: the demora (deferral) bonus is ≈+4% per full year. Early-retirement reduction coefficients depend on contribution history and are simplified out — confidence low.

Source: Seguridad Social — jubilación demorada

France state pension (régime de base) — state-pension claim-age rulesnext data review due 2027-01-31medium confidence
  • Modelled defer-only: the surcote is +1.25% per quarter worked past full rate. The décote (early, quarter-dependent) is simplified out — confidence low.

Source: Service-Public.fr / retraitesdeletat — surcote

Greece state pension (e-EFKA primary old-age) — state-pension claim-age rulesnext data review due 2027-07-31medium confidence
  • No claiming-age lever modelled: Greece grants no actuarial uplift for deferring past 67 (confirmed for post-1993 insured / post-2011 vested rights), and the early routes (full pension at 62 with 40 years; reduced pension at 62 with 15 years) are contribution-history-dependent, so they are simplified out per the ES/FR convention. The 15-year (4,500-day) minimum insurance requirement is not modelled. Statutory ages are frozen until 2030 but rises are being prepared thereafter (possible adjustments flagged for 2027).

Source: Greek Ministry of Labour — Primary pension (e-EFKA); Max Planck Institute (MPISOC) pension map — Greece statutory old-age pension (no-deferral-uplift rule); gov.gr — Old age pension (EU/EEA/Switzerland pensions)

Ireland State Pension (Contributory) — state-pension claim-age rulesnext data review due 2027-01-31medium confidence
  • Flexible deferral to age 70 introduced January 2024; the uplift is approximate. Non-contributory (means-tested) pension is a different, unmodelled scheme.

Source: gov.ie — State Pension (Contributory): flexible pension age

Italy state pension (pensione di vecchiaia) — state-pension claim-age rulesnext data review due 2027-01-31medium confidence
  • No simple actuarial claiming-age lever modelled: Italy's notional-defined-contribution system recomputes the coefficient by age rather than applying a flat deferral bonus.

Source: OECD — Pensions at a Glance 2025 (Italy)

Netherlands state pension (AOW) — state-pension claim-age rulesnext data review due 2027-01-31medium confidence
  • No claiming-age lever: the AOW cannot be deferred and cannot be brought forward — it starts on the individual's personal AOW-leeftijd (SVB). The 5-8%/yr deferral sometimes cited for Dutch pensions applies only to SUPPLEMENTARY occupational pensions via a fund, not the state AOW.

Source: SVB — AOW pension; SVB — AOW-leeftijd (uw AOW-leeftijd)

Portugal Segurança Social old-age pension (pensão de velhice) — state-pension claim-age rulesnext data review due 2027-04-01medium confidence
  • Enter your Segurança Social pension forecast as the amount at the normal age. Modelled normal age 67 (statute: 66y9m in 2026, 66y11m in 2027, indexed at 2/3 of the 65+ life-expectancy gain — a claim at the true 2026 statutory age therefore models as ~3 months early, −1.5%). Early claim is modelled on the flexibilização route (60+ with ≥40 contribution years at 60): 0.5%/month reduction and — per the ISS Guia Prático's worked examples — NO fator de sustentabilidade on that route. Early claimants who had NOT completed 40 years at age 60 additionally suffer the sustainability factor (×0.8237 in 2026, a further −17.6%) — NOT modelled, so this row OVERSTATES their pension. The statute measures months early against the PERSONAL retirement age (normal age −4 months per career year beyond 40, floor 60); measuring against the normal age can materially overstate the penalty for long careers (ISS example: 44-year career claiming at 63 = 14.5% statutory vs 24% here — conservative direction). Very-long-career exemptions (48+ years, or 46+ with contributions from before age 17 — no penalties at all) and the work-conditioned deferral bonus are not modelled. Exportable and uprated abroad (EU/EEA/CH via Reg. 883/2004 Art. 7; bilateral agreements elsewhere). Old-age and survivor pensions are Category H income (dedução específica applies — see the PT tax pack).

Source: ISS Guia Prático — Pensão de Velhice (idade normal 66a9m em 2026; flexibilização 60/40 anos; 0,5%/mês; worked examples: SEM fator de sustentabilidade na flexibilização); Portaria n.º 476/2025/1 — idade normal 2027 = 66 anos e 11 meses; fator de sustentabilidade 2026 = 0,8237 (EMV 16,63/20,19) — APCMC legislative note; DL n.º 187/2007 Arts. 20, 35–36 (idade normal formula — Portaria 358/2024/1 fixes 2026 = 66a9m; fator de sustentabilidade; 0,5%/mês; bonificação) + Lei n.º 119/2018 (flexibilização 60/40 anos); Segurança Social — Pensão de velhice (guia prático: flexibilização, penalizações, carreiras muito longas)

Canada Pension Plan (CPP) — state-pension claim-age rulesnext data review due 2027-04-06approximate
  • Contributory earnings-related benefit. Post-70 deferral adds nothing.

Source: Canada.ca — CPP: how much you could receive (adjustment factors)

Canada Old Age Security (OAS) — state-pension claim-age rulesnext data review due 2027-04-06approximate
  • The OAS recovery-tax (clawback) above the income threshold is NOT modelled in v1 — the deferral factor is shown gross.

Source: Canada.ca — OAS: deferring your first payment

Germany statutory pension (GRV) — state-pension claim-age rulesnext data review due 2027-01-31approximate
  • Abschlag/Zuschlag are per-month. Early access at 63 assumes the long-insured pathway; eligibility depends on contribution years, which are not modelled.

Source: BMAS / Deutsche Rentenversicherung — Zu- und Abschläge

UK New State Pension — state-pension claim-age rulesnext data review due 2027-04-06approximate
  • No early claim and no lump-sum option; deferral adds ~5.8%/yr with no cap. Triple-lock uprating is modelled separately via the pension's indexation rule. Uprating STOPS while the recipient lives outside the EEA/Switzerland/Gibraltar and the reciprocal-agreement list (notably frozen in Australia, Canada, New Zealand and the UAE) — the payment stays at the rate first paid there.

Source: GOV.UK — Delay (defer) your State Pension; Royal London — Deferring the State Pension; GOV.UK — State Pension if you retire abroad (countries with yearly increases)

Japan National + Employees' Pension (kokumin/kōsei nenkin) — state-pension claim-age rulesnext data review due 2027-04-01approximate
  • Two-part system: flat basic pension (kokumin nenkin — FY2026 full ¥847,300/yr, pro-rated by contribution months/480) plus earnings-related kōsei nenkin (enter your nenkin-net forecast as the amount). Indexed annually (macroeconomic slide). Payable abroad without freezing. Old-age pension income is taxable (雑所得 after the public-pension deduction — the JP tax pack over-taxes it, see its caveats); survivor pensions are tax-exempt.

Source: MHLW — FY2026 pension revision press release (basic ¥847,300, +1.9%); Japan Pension Service — Old-age Basic Pension (claim-age adjustments 0.4%/0.7% per month); Japan Pension Service — FY2026 pension amounts from April 2026

Mexico Pensión para el Bienestar (Adultos Mayores) — state-pension claim-age rulesnext data review due 2027-01-31approximate
  • No claiming-age lever: the Pensión para el Bienestar is a universal non-contributory benefit paid from age 65 with no early claim and no deferral uplift. The amount (MXN 6,400 bimonthly in 2026) is set administratively each fiscal year via the Reglas de Operación, not primary statute, and payment requires Mexican residence — it stops for recipients living outside Mexico. The contributory IMSS/AFORE system (Ley 97 individual accounts, Vejez 65 / Cesantía 60, 875-week 2026 minimum rising to 1,000 by 2031, and the pensión garantizada) is a separate scheme and is NOT modelled.

Source: Programas para el Bienestar — ¿De cuánto es la Pensión para Personas Adultas Mayores en 2026?; Programas para el Bienestar — Pensión Bienestar Adultos Mayores (program page); IMSS — Solicitud de Pensión de Cesantía en Edad Avanzada o Vejez

New Zealand Superannuation (NZ Super) — state-pension claim-age rulesnext data review due 2027-07-31approximate
  • No claiming-age lever: NZ Super is a flat-rate universal pension with no early-claim mechanism and no actuarial deferral uplift — payments start once eligible at 65. It is residence-tested, not contribution-based: eligibility requires 12 years' NZ residence since age 20 (as of 1 July 2026, rising to 20 by 2042 under the Fair Residency Amendment Act 2021), which is NOT modelled — the engine assumes the user qualifies. Not means-tested.

Source: Work and Income NZ — Who can get NZ Super; Work and Income NZ — NZ Super and Veteran's Pension residency changes (Fair Residency step-up); NZ Superannuation and Retirement Income Act 2001, s.8 (residential qualification)

Sweden state pension (allmän pension: inkomstpension + premiepension + garantipension) — state-pension claim-age rulesnext data review due 2027-07-31approximate
  • No flat actuarial claiming-age lever modelled: Sweden's notional-defined-contribution system recomputes the benefit via a per-cohort life-expectancy annuity divisor at the exact withdrawal age (later claim pays more automatically, but there is no publishable X%/yr factor) — same rationale as IT/AU. The riktålder (67) applies to cohorts reaching it 2026–2031 and rises with life expectancy for younger cohorts (not legislated beyond the 6-year lock-in). Earliest 64 covers ONLY the income/premium pension (riktålder − 3); the means-adjacent garantipension, inkomstpensionstillägg and bostadstillägg cannot start before the riktålder itself (67) and are not separately modelled. Garantipension eligibility (minimum 3 years' Swedish residence, 1 year if combining EU/EEA periods; full amount needs 40 years' residence, pro-rated 1/40 per year) is not modelled.

Source: Pensionsmyndigheten — Riktålder / pensionsåldrar (birth-year table); Pensionsmyndigheten — Guarantee pension (English); Nordic cooperation — National public pension in Sweden (18.5% split)

Thailand SSO Old-Age Pension (Section 33) — state-pension claim-age rulesnext data review due 2027-07-31approximate
  • No claiming-age lever: the SSO old-age pension pays at a fixed age 55 with a 15-year minimum contribution trigger, not an actuarial claim window. The 15-year eligibility requirement and the wage-based benefit formula (20% of the final-60-month average wage at 15 years, +1.5% per additional year, wage ceiling THB 17,500 from 1 Jan 2026) are not modelled. Covers mandatory private-sector employees only — most expat TH residents are not SSO contributors.

Source: HLB Thailand — Social Security Contribution Changes 2026; SSA — Social Security Programs Throughout the World: Thailand; RLC Outsourcing — New SSO Salary Ceiling 2026

US Social Security (OASDI) — state-pension claim-age rulesnext data review due 2027-04-06approximate
  • Delayed-retirement credits stop accruing at 70. WEP/GPO adjustments and spousal/survivor benefits are not modelled in v1.

Source: SSA — Delayed Retirement Credits; SSA — Early or Late Retirement (reduction factors)

AE — state pension (not yet coded)not yet coded
  • no claim-age scheme coded; state-pension timing for this country is not modelled

Source: docs/tax/2026-06-22-tax-rulepack-dossier-DRAFT.md

AR — state pension (not yet coded)not yet coded
  • no claim-age scheme coded; state-pension timing for this country is not modelled

Source: docs/tax/2026-06-22-tax-rulepack-dossier-DRAFT.md

BR — state pension (not yet coded)not yet coded
  • no claim-age scheme coded; state-pension timing for this country is not modelled

Source: docs/tax/2026-06-22-tax-rulepack-dossier-DRAFT.md

CO — state pension (not yet coded)not yet coded
  • no claim-age scheme coded; state-pension timing for this country is not modelled

Source: docs/tax/2026-06-22-tax-rulepack-dossier-DRAFT.md

IN — state pension (not yet coded)not yet coded
  • no claim-age scheme coded; state-pension timing for this country is not modelled

Source: docs/tax/2026-06-22-tax-rulepack-dossier-DRAFT.md

PL — state pension (not yet coded)not yet coded
  • no claim-age scheme coded; state-pension timing for this country is not modelled

Source: docs/tax/2026-06-22-tax-rulepack-dossier-DRAFT.md

SG — state pension (not yet coded)not yet coded
  • no claim-age scheme coded; state-pension timing for this country is not modelled

Source: docs/tax/2026-06-22-tax-rulepack-dossier-DRAFT.md

VN — state pension (not yet coded)not yet coded
  • no claim-age scheme coded; state-pension timing for this country is not modelled

Source: docs/tax/2026-06-22-tax-rulepack-dossier-DRAFT.md

ZA — state pension (not yet coded)not yet coded
  • no claim-age scheme coded; state-pension timing for this country is not modelled

Source: docs/tax/2026-06-22-tax-rulepack-dossier-DRAFT.md

How confident is this data?

Every number in Ember’s country data carries a source, a confidence grade and an as-of date. High confidence means it’s been checked against primary sources — statutes, official rates — with an independent adversarial review before it’s wired into the planner. Medium confidence is drawn from reputable secondary sources we haven’t yet re-verified against the primary text, and low confidence is illustrative seed data awaiting verification — always yours to override (cost-of-living factors, for example, are editable suggestions, never silently applied to your numbers). Where a category has known gaps, we list them here openly rather than paper over them.

CategoryEntriesHigh / Med / LowKnown gaps
Tax treatiesoldest data as of 20267567 / 7 / 10
US state taxesoldest data as of 20255149 / 2 / 0169
Capital-gains taxoldest data as of 20263110 / 20 / 131
State pensionsoldest data as of 20263110 / 12 / 031
Cost-of-living factorsoldest data as of 2026300 / 27 / 30
Estate & inheritance taxoldest data as of 20263019 / 8 / 2159
Income-tax rulesoldest data as of 2026307 / 17 / 6250
Property feesoldest data as of 2025-04300 / 0 / 010
Property growth defaultsoldest data as of 20263010 / 19 / 130
Residency-transition rulesoldest data as of 20263026 / 4 / 0152
Wrapper drawdown recognitionoldest data as of 2026-07102 / 0 / 828

Every governed row above carries a next-review date, and a tripwire test suite fails the build if country coverage silently regresses — confidence is checked every time we ship, not a one-off label.

Honesty is the point

Ember shows its working. Every figure in the planner carries a confidence label and the maths behind it, and where a country’s rules are still approximate we say so — here and on the country page itself.