Where our tax figures are approximate

• GNI + deduccion especial ap.1 modelled as the single-filer allowanceMinor (annual-2026 stack ARS 27,088,521.14 = 6,019,671.36 + 21,068,849.78). Not modelled: cargas de familia (annual 2026 conyuge 5,669,323.06 / hijo 2,859,060.31 / hijo incapacitado 5,718,120.60), the ap.1 'nuevos profesionales/emprendedores' variant (24,078,685.46), the ap.2 self-employed variant (28,894,422.56), and the SAC relief (published as a 'Deduccion Especial Doceava parte' of the taxpayer's own computable a)+b)+c)-ap.2 deductions — a deduction, not an exemption). A filer entitled to any of these is over-taxed by the amount not modelled. APPROXIMATION: the deduccion especial statutorily requires employment/pension income (art. 30 inc. c), 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
• CPI INDEXING, THREE VINTAGES PER YEAR: ARCA publishes an ene-jun and a jul-dic withholding table (indexed each semester — Art. 94 penultimo parrafo / Art. 30 ultimo parrafo 'para el segundo semestre calendario', RG 4.003 art. 7 inc. b) and a separate liquidacion-final-y-anual table (indexed annually — Art. 94 segundo parrafo, RG 4.003 art. 7 inc. c / art. 21 incs. a-b) of the Ley de Impuesto a las Ganancias t.o. 2019 as amended by Ley 27.743. Ember computes an annual liability, so the ANNUAL vintage is wired; a semester table's December accumulated row is cumulative withholding, not the annual scale. The annual 2026 figures go stale once the annual 2027 table is published (around Jan-Feb 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), basis AR-INCOME: PwC WWTS — SECONDARY per the dossier's own source table (line 1787)); ARCA Tabla Art. 94 LIG — liquidación final y anual, período anual 2026 (RG 4.003 art. 7 inc. c / art. 21 incs. a-b; art. 94 2nd para) — THE table for an annual liability; ARCA Deducciones personales Art. 30 — liquidación anual 2026 (GNI 6,019,671.36; especial ap.1 21,068,849.78); ARCA Tabla Art. 94 LIG jul-dic 2026 — SEMESTER WITHHOLDING scale (RG 4.003 art. 7 inc. b); its December accumulated row is cumulative withholding, NOT the annual scale — do not wire for an annual liability; ARCA Deducciones Art. 30 jul-dic 2026 — SEMESTER WITHHOLDING vintage (a diciembre: GNI 5,585,736.93; especial ap.1 19,550,079.27); superseded for annual use by AR-ded-anual-2026; ARCA Deducción específica jubilados HMG 2026 (ANSES Res. 381/2025–186/2026 monthly ladder)

• aanvullende gemeentebelasting (municipal surcharge) not modelled — it is a percentage of the computed federal tax, not of income, so no band or credit here can express it; FOD's per-municipality table for aanslagjaar 2026 spans 0% to 9.0%, with most municipalities between 6% and 8.8%
• tax-free sum modelled as a 25% tax credit (belastingvermindering) — matches the reduction method
• belastingvermindering voor pensioenen en vervangingsinkomsten (art. 147 WIB92) is not modelled — pension and replacement income here carries only the belastingvrije som credit, so tax is over-stated for a Belgian retiree; the statutory reduction is a second, income-type-conditional reduction (KB 25.02.2024, aanslagjaar 2025: basic €2,151.72 plus supplementary €442.69) and art. 147 fourth para further empowers the King to raise the supplement so that a taxpayer living exclusively on pension/replacement income up to the statutory ceiling pays nothing
• savings-income regime not modelled — interest on regulated savings accounts is exempt up to €1,020 (unchanged for inkomsten 2025 and 2026) and the excess is taxed at 15%, not the 30% base roerende voorheffing rate; this is a schedular withholding regime outside the progressive scale
• 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 by this income-tax pack; disposal CGT for Belgium is charged from the separate country CGT table (10% above a €10,000 annual exemption), which does not model the 31 Dec 2025 rebase, the €1,000/yr carry-forward of unused exemption (€15,000 cap), the separate progressive scale for substantial holdings, or the long-holding exemption
• selfEmployment: no regime module — self-employed social contributions / business-income surcharges for this jurisdiction are not modelled

Source: Ember tax-rulepack dossier §5.12 (BE — PwC WWTS, secondary); FOD Financien — Tarieven (belastingschijven en belastingvrije som, inkomsten 2025 en 2026); FOD Financien — Spaargeld en beleggingen (€1,020 spaarvrijstelling, 15% op het excedent, 30% roerende voorheffing); FOD Financien — Vrijstellingen dividenden (€833, inkomsten 2025 en 2026); FOD Financien — Aanslagvoeten van de gemeentebelasting (%) voor het aanslagjaar 2026; KB 25.02.2024 tot uitvoering van art. 147, vierde lid WIB92 (belastingvermindering pensioenen/vervangingsinkomsten, aanslagjaar 2025)

• 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 indexed ANNUALLY for cold progression (DBG Art. 39 Abs. 2, index reading at 30 June before the tax period; no adjustment in deflation); the EFD ordinance for each following year is published in September.
• 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
• federal tax amounts under CHF 25 are not levied (DBG Art. 36 Abs. 3) — not modelled: the pack charges the banded amount from the first franc above the CHF 15,200 zero band, so modelled federal tax is overstated by up to CHF 25 on taxable incomes between roughly CHF 15,200 and CHF 18,450.
• the CHF 263-per-child/dependant reduction of the computed tax amount (DBG Art. 36 Abs. 2bis) rides the parent/married scale and is not modelled — the single-filer scale encoded here carries no child or dependant relief.
• the statutory presentation conventions are not modelled: income fractions under CHF 100 are disregarded, and the annual tax is rounded down to the next 5 Rp. (ESTV Form 58c 2026, notes 1 and 2), so modelled amounts differ from the published table by a few centimes.
• no federal deductions are modelled — the pack treats the income the engine supplies as already-taxable income. Deductions from income under DBG Art. 26 (Berufskosten), Art. 33 (including the insurance-premium/savings-interest cap of CHF 1,800, raised by half to CHF 2,700 for taxpayers without pillar 2/3a contributions; CHF 10,600 political-party donations; CHF 13,000 training costs) and the Art. 35 social deductions (CHF 6,800 per child, CHF 6,800 per supported person, CHF 2,800 for married couples) sit outside the pack, so modelled federal tax is overstated wherever they apply.

Source: Bundesgesetz über die direkte Bundessteuer (DBG), SR 642.11, Art. 36 Abs. 1 (Grundtarif) — Fassung gemäss Art. 2 Abs. 1 der V des EFD vom 10. Sept. 2025 über die kalte Progression (AS 2025 579), in Kraft seit 1. Jan. 2026; ESTV Form. 58c — Steuertarife direkte Bundessteuer natürliche Personen 2026 (official calculation table)

• UAE Free Zone 0% qualifying-income regime not modelled
• no personal income tax and no personal dividend tax (correct for UAE); no social charge on self-employment
• Small Business Relief (Ministerial Decision No. 73 of 2023) is not modelled: a resident person whose Revenue does not exceed AED 3,000,000 may elect to be treated as having no Taxable Income, for tax periods ending on or before 31 December 2026. Ember takes no revenue input and always applies the 9% rate above AED 375,000, so corporation tax is overstated for a person who makes the election.
• Corporate Tax on a natural person's business (Cabinet Decision No. 49 of 2023) is not modelled: a resident or non-resident natural person is a taxable person only where turnover exceeds AED 1,000,000 in a Gregorian calendar year, and wage, personal investment and real estate investment income are out of scope at any amount. Ember applies no tax to a UAE sole trader, so tax is understated above that turnover.
• GPSSA pension contributions (Federal Decree-Law No. 57 of 2023) are not modelled: an insured UAE national contributes 11% of pensionable salary and the employer 15%. Expatriate employees are outside the scheme. Ember takes no nationality input and treats UAE employment income as subject to no contributions, so net pay is overstated for a UAE-national employee.
• Unemployment insurance (ILOE) premiums are not modelled: a subscribing employee pays up to AED 5 per month where basic salary is below AED 16,000 and up to AED 10 per month above it.
• Domestic Minimum Top-up Tax (Cabinet Decision No. 142 of 2024, effective 1 January 2025) is not modelled: constituent entities of multinational groups with EUR 750 million or more of consolidated revenue are subject to a 15% minimum rate.

Source: Federal Decree-Law No. 47 of 2022 on the Taxation of Corporations and Businesses — Art. 3 (Corporate Tax Rate), Art. 21 (Small Business Relief); Cabinet Decision No. 116 of 2022 on the annual Taxable Income subject to Corporate Tax — Art. 2-3 (AED 375,000 threshold); Cabinet Decision No. 49 of 2023 — Businesses of natural persons subject to Corporate Tax (AED 1,000,000 turnover threshold); UAE Government Portal (u.ae) — Taxation: 'The UAE does not levy income tax on individuals.'

• 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 — for 2026-27 AU taxes capital gains at marginal rates with a 50% discount for assets held >12 months (handled in CgtRates, not here); for gains arising after 1 Jul 2027 the 50% discount is replaced by CPI cost-base indexation plus a 30% minimum tax on real gains (Treasury Laws Amendment (Tax Reform No. 1) Act 2026 Sch 1; Income Tax Rates Act 1986 s 12AA), with an election to keep the 50% discount for new builds — none of which is modelled here or in cgtByCountry.ts
• 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 scale — for the 2024-25 year of income and later, 30% on ordinary taxable income to A$135,000, 37% to A$190,000 and 45% above (Income Tax Rates Act 1986 Sch 7 Pt II, which sets the first two rows by cross-reference to the second and third resident personal tax rates, so they track the resident scale); the 32.5% first band last applied for 2023-24 — only the RESIDENT scale is encoded
• bracket indexing: Australia does not index brackets — the 16% rate stepped down to 15% for 2026-27 and is legislated to fall to 14% for 2027-28 and later years (Income Tax Rates Act 1986 Sch 7 Pt I holds all three tables); this pack holds the FY2026-27 15% rate. From the 2027-28 income year a non-refundable Working Australians Tax Offset also applies — the lesser of A$250 and the tax on the taxpayer's net labour income (ITAA 1997 Subdiv 61-E, inserted by Treasury Laws Amendment (Tax Reform No. 1) Act 2026 Sch 3) — and is not modelled
• 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
• standard deduction for work-related expenses (ITAA 1997 s 25-130, inserted by Treasury Laws Amendment (Tax Reform No. 1) Act 2026 (No. 49, 2026) Sch 4, applying to assessments for the 2026-27 income year and later) not modelled — an Australian resident who derives assessable labour income may deduct up to A$1,000 without substantiation, reduced by any work-related deductions actually claimed, so for such a user this pack OVER-states tax by roughly A$150 (15% band) to A$450 (45% band) per year; the deduction is confined to labour income and does not reach pension, rental, dividend or capital income

Source: Ember tax-rulepack dossier (AU — Ember tax-rulepack dossier §5.26 (AU) — PwC Worldwide Tax Summaries, Australia, ); Income Tax Rates Act 1986 (Cth), Compilation No. 66, compilation date 1 July 2026, includes amendments up to Act No. 50, 2026 — s 3 (tax-free threshold means $18,200); Sch 7 Pt I 'Tax rates for resident taxpayers for the 2026-27 year of income' (15%/30%/37%/45%); Sch 7 Pt II non-resident table; s 12AA; Medicare Levy Act 1986 (Cth), Compilation No. 53, compilation date 1 July 2026 — s 6(1): rate of levy on a taxable income is 2%; Treasury Laws Amendment (Tax Reform No. 1) Act 2026 (No. 49, 2026), assented 26 June 2026 — Sch 1 CGT adjustments (1 Jul 2027), Sch 3 Working Australians tax offset (2027-28), Sch 4 standard deduction for work-related expenses (2026-27)

• 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$3.561,50, health, private-pension PGBL up to 12%) are NOT modelled -- taxpayers whose legal deductions exceed the 20%-capped simplified discount pay LESS than this pack shows.
• Parcela isenta de aposentadoria/pensão for taxpayers aged 65 and over (Lei 9.250/1995 Art. 6o XV) is NOT modelled: Receita Federal's ano-calendario 2026 table states 'Rendimentos previdenciarios isentos para maiores de 65 anos: R$ 1.903,98' per month, and this pack has no age axis and no Brazilian-source-pension axis. A taxpayer aged 65+ with qualifying retirement or previdencia privada income is therefore shown MORE tax than is due. The exemption reduces rendimentos tributaveis, which is simultaneously the base for the annual table and the input to the Art. 11-A redutor, so it shifts the whole synthetic curve rather than adding to allowanceMinor.
• 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)

• 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 basic personal amount is reduced from CAD 16,452 to a CAD 14,829 floor across net income of CAD 181,440 to CAD 258,482 (ITA s.118(1.1), pegged to the paragraph 117(2)(d) and (e) amounts) — not modelled; the full BPA credit is applied at every income level, so this pack understates tax for incomes above CAD 181,440 by up to about CAD 227 per year.
• 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 indexation: the bracket thresholds and the basic personal amount are the enacted 2026 values (ITA s.117(2) and s.118(1.1) as adjusted by the s.117.1 factor of 1.020). They are a single-year snapshot and are not re-indexed for 2027 or later years, so projections beyond 2026 apply 2026 thresholds to later-year income.
• selfEmployment: no regime module — self-employed social contributions / business-income surcharges for this jurisdiction are not modelled

Source: Income Tax Act (RSC 1985 c.1 (5th Supp.)) s.117(2) — rates and statutory bracket amounts; Income Tax Act s.117.1 — annual adjustment (CPI 12-month averages to 30 September; factor to the nearest one-thousandth, amounts to the nearest dollar); Income Tax Act s.118(1)(c) and s.118(1.1) — basic personal amount, enhanced amount and high-income taper range; Making Life More Affordable for Canadians Act, SC 2026 c.2 s.2 — lowest federal rate 14.5% for 2025, 14% for taxation years after 2025; Statistics Canada Web Data Service — CPI all-items Canada, vector 41690973 (used to compute the 2026 s.117.1 factor of 1.020); Ember tax-rulepack dossier §5.16 (CA — Canada) — SECONDARY (from PwC WWTS Canada); superseded by the primary refs above

• 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)
• Dividends flow into the IGC carrying the first-category credit and are handled by the bands above. Chilean-listed shares and mutual/investment-fund units are NOT taxed that way — Art. 107 LIR imposes a separate flat 10% impuesto unico on the mayor valor (SII Circulares 39/2022 and 31/2023, declared on Linea 66) — and that flat rate is carried in the engine's CGT dataset, not in this pack. The 10 UTA per year non-habitual and 8,000 UF real-estate exemptions are not modelled anywhere.
• UTA/UTM indexing: the IGC cutoffs are fixed multiples of the Unidad Tributaria Anual (13.5/30/50/70/90/120/310 UTA) and reprice monthly with CPI, so the peso figures depend on which vintage you anchor to. This pack uses the IN-FORCE income-year-2026 reading (owner ruling 2026-08-03): UTA CLP 859,788, the latest published 2026 value annualised (UTM agosto 2026 = 71,649 x 12), corroborated by SII's Agosto-2026 monthly Segunda Categoria table whose limits x 12 reproduce every cutoff exactly. The alternative vintage is SII's published ANNUAL Art. 52 table for Ano Tributario 2026, anchored on UTA diciembre 2025 = CLP 834,504 (2.9% lower), which governs income year 2025. The anchor is a single constant and every threshold is derived from it, so the refresh is one line: UTA diciembre 2026 is not yet published, and these figures are re-based on it when SII publishes the AT-2027 table.
• 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
• Mandatory social/pension contributions are deductible before IGC and are NOT modelled, so the pre-tax base is over-stated: AFP approximately 10% plus the administrator commission and health (Fonasa or Isapre) 7%, both applied up to the tope imponible of 90.0 UF for 2026 (up from 87.8 UF in 2025, effective from February 2026 remunerations); unemployment insurance has a separate 135.2 UF cap.
• 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
• The 7% mandatory health contribution is deducted from PENSIONS as well as wages and is not modelled here, so projected net pension income is over-stated for a Chilean-resident retiree. The state bonification that covers it is narrow: automatic only for PBSI/APSV/APSI recipients, and otherwise conditional on receiving PGU/BAC/CEV, being in the 80% most vulnerable by Puntaje de Focalizacion Previsional, age 65+, AFP or equivalent affiliation, and at least 20 years' residency in Chile including four of the last five. Members on an Isapre plan costing more than 7% also fund the excess themselves.
• Statutory IGC deductions and credits are not modelled, so tax is over-stated for anyone who qualifies (AT-2026 annual limits): the Art. 55 bis mortgage-interest deduction, up to 8 UTA (CLP 6,676,032) at the 0-90 UTA income bracket with income-dependent limits above it; the Art. 42 bis voluntary-pension-saving (APV) deduction, up to 600 UF (CLP 23,836,776); the Art. 50 presumed-expenses deduction for independent workers, up to 15 UTA (CLP 12,517,560); and the Art. 55 ter education credit of 4.4 UF (CLP 174,803) per child.

Source: SII — Valores y Fechas, Renta AT 2026: tabla anual Impuesto Global Complementario (Art. 52 LIR) y limites anuales (UTA dic-2025 = CLP 834.504); SII — Impuesto Unico de Segunda Categoria, tablas mensuales 2026 (misma escala de factores sobre base UTM); SII — Serie UTM/UTA 2026 (UTA = UTM x 12); anchor for the CLP thresholds; Ember tax-rulepack dossier (CL — Ember tax-rulepack dossier 2026-06-22 §5.19 (CL — PwC WWTS, rev. 2025-12-19); UT)

• Cédulas modelled as one scale: since FY2023 (Art. 331 ET as replaced by Ley 2277 de 2022 art. 6) the work, capital, non-labour, pension and dividend cedular NET incomes are summed and the single Art. 241 table applies to the total — which is what this pack does. The Art. 206 num. 5 pension exemption IS now modelled (next entry). What remains unmodelled of the per-cédula depuration that precedes the sum is the Art. 336 num. 3 limit and the general-cédula costs, deductions and exempt income, so the taxable base is still over-stated for non-pension income. Ganancias ocasionales sit outside this scale entirely.
• Pension exemption (Art. 206 num. 5 ET, extended to pensions obtained abroad or from multilateral bodies by parágrafo 3 as amended by Ley 2277 de 2022 art. 2) MODELLED, as an annual approximation (owner ruling 2026-08-03). The statute exempts the part of each MONTHLY payment up to 1,000 UVT — COP 52,374,000 per month at UVT 2026, COP 628,488,000 across twelve payments — and this pack applies that COP 628,488,000 as ONE ANNUAL ceiling across all of a recipient's pensions: exact for a level twelve-payment pension, approximate for any other payment pattern (a lumpy or non-twelve-instalment schedule can be relieved more, or less, than the statute's per-payment test would give). The Art. 336 num. 3 40%/1,340-UVT limit does not restrict it, because pensions are depurated in their own cédula under Art. 337. Two eligibility judgements are baked in and could be wrong in the UNDER-tax direction: DC-pot drawdown is treated as qualifying 'renta vitalicia' savings under parágrafo 3, which the statute text does not settle, and parágrafo 3's Ley 100 de 1993 requirements for accessing the pension are assumed met.
• Cedular deductions/exempt income cap (40% of net income, max 1,340 UVT for the general cedula) NOT modelled
• Dividends: since FY2023 (Art. 242 ET as replaced by Ley 2277 de 2022 art. 3) resident dividends out of profits not taxed at company level form part of the ordinary base at the Art. 241 rates — which is how this pack already treats them — while dividends out of taxed profits bear the Art. 240 corporate rate first. Not modelled: the Art. 254-1 descuento tributario on the dividend cédula (added by Ley 2277 art. 5), whose absence over-states tax for a resident with dividend income.
• 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) not modelled: Art. 294-3 ET (added by Ley 2277 de 2022 art. 36) charges net wealth of 72,000 UVT or more at 0.5%–1.5%, and the parágrafo to Art. 296-3 (art. 38) limits the 1.5% rate to 2023–2026, with a lower table from 2027; Art. 295-3 excludes the first 12,000 UVT of the main home. The 40,000 UVT / up-to-5% version that circulated in 2025 was in the Government's ley de financiamiento, archived by the Comisiones Económicas on 9 December 2025, and then in decrees issued under the emergency declared by Decreto 1390 de 2025, which the Corte Constitucional declared inexequible in Sentencia C-075/26 (9 April 2026); it is not law for 2026.
• 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: Ley 2010 de 2019 art. 34 — Estatuto Tributario art. 241 (tarifa personas naturales residentes); Ley 2277 de 2022 — arts. 2 (ET 206 par. 3), 3 (ET 242), 5 (ET 254-1), 6 (ET 331), 7 (ET 336), 36/38 (ET 294-3, 296-3); Decreto Ley 624 de 1989 — Estatuto Tributario consolidado (arts. 206 num. 5, 336, 337); DIAN — UVT 2026 = COP 52.374 (Resolución 000238 de 15 de diciembre de 2025); Ember tax-rulepack dossier (CO) 2026-06-22 §5.18

• mínimo personal (€5,550) modelled as a tax credit at 19% (scale(base)−scale(5,550) mechanic) — matches Spain's method; the over-65/over-75 increments ride the ageRebate module at the same 19% valuation; regional (autonómico) mínimo variation is still not modelled
• work-income reductions not modelled — the €2,000 'otros gastos' (Art. 19.2.f LIRPF, available to all recipients of rendimientos del trabajo, pensions included) and the Art. 20 reducción por obtención de rendimientos del trabajo (€7,302 where net work income ≤ €14,852, tapering 7,302 − 1.75 × (RNT − 14,852) to €17,673.52 then 2,364.34 − 1.14 × (RNT − 17,673.52) to nil at €19,747.50, and only where other non-exempt income ≤ €6,500) are both absent: salary and pension income is taxed here on the full gross, so ES tax is OVER-stated for lower-income residents — by roughly the €2,000 deduction's value for any pensioner, and by materially more for a filer whose non-work income stays under €6,500
• autonomous-community scale variation not modelled (single combined default scale; Madrid lower, Catalonia/Valencia higher)
• interest income is not a separate category — dividends run on the statutory savings scale (dividendTax: 19/21/23/27/30 at €6,000/€50,000/€200,000/€300,000) and capital gains on the same scale via the CGT table, but interest has no category of its own and joins the ordinary general-scale stack, which over-states it above the 19% band and under-states it below
• 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 (RD-ley 5/2026 art. 28 / DA 61ª LIRPF is cited from the reconciliation note only; no BOE identifier has been verified in-pack, and the deduction is restricted to income from a relación laboral o estatutaria so it does not reach pensioners)
• 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 capped banded charge fitted to the DEFAULT tramo-minimum base (Orden PJC/297/2026 art. 18; 31.50% = 28.30 contingencias comunes + 1.30 profesionales + 0.90 cese de actividad + 0.10 formación profesional + 0.90 MEI — of which art. 18 itemises the comunes, profesionales and MEI legs verbatim, 30.50 of that aggregate; cese de actividad and formación profesional, 1.00 percentage point between them, are taken from practitioner readings of the same Orden, corroborated by art. 18.9 exempting religious-institute members from contributing for exactly those two), banded on rendimientos netos COMPUTABLES rather than on profit (art. 308.1.c LGSS regla 2.ª: an uncapped 7% generic-expense deduction ⇒ computable = profit × 0.93), with the reduced table's €2,470.57/yr tramo-1 cuota applied as a floor, so the modelled charge runs from €2,470.57 to €7,289.93/yr as the statute bounds the default election — €7,289.93 is the FIT's ceiling, not the statute's: €1,928.10 × 31.50% × 12 = €7,288.22/yr, so every profit at or above €77,419.37 is OVER-charged by €1.71/yr, an artefact of the 4-dp band rates. Residual approximations, all disclosed: (a) the real charge is a quota on a base the contributor CHOOSES inside their tramo (minimums €653.59–€1,928.10/mo, maximum €5,101.20/mo), so anyone electing above the tramo minimum pays MORE than modelled — up to €19,282.54/yr, a ceiling the pack does not represent; (b) the fit is piecewise-LINEAR between tramo entry points while the statutory cuota is CONSTANT inside each tramo, so it lands within +€0.60–€1.71 of statute at each anchored tramo entry (the 4-dp band rates leave it fractionally ABOVE, not exact) and OVER-states increasingly toward each tramo's top — worst +19.1% at ≈€21,935 profit where general tramos 1–3 share near-identical minimum bases (statute €3,631.75, modelled €4,324.22); the error is a RAMP inside each tramo, not a level, so the €52,258–€77,419 tramo-11 window below the ceiling runs +0.02% at its entry, +3.5% at €60,000 and +11.3% only at its top; (c) the fit's under-statute residuals, re-measured 2026-08-07 by a 1-cent sweep of the shipped engine against the statutory step: the model sits BELOW statute in FOUR profit windows — €8,645.17–€11,379.19 (worst −€247.06 / −9.1% at €8,645.17, where the reduced table steps up to its tramo 2 while the floor is still binding), €11,612.91–€13,448.16 (worst −€438.31 / −13.6% at €11,612.91, the global worst), €23,870.98–€24,429.94 (worst −€55.21 / −1.2%) and €26,193.56–€26,931.41 (worst −€72.88 / −1.5%) — and is at or above statute everywhere else, including between the first two windows; (d) the floor assumes the REDUCED-table election, available only where declared expected net earnings are below €1,166.70/mo (subject to regularización) — a low-profit autónomo left on the general table pays that table's tramo-1 minimum, €3,594.70/yr, €1,124.13 more; (e) tarifa plana (€80/mo for new autónomos in their first 12–24 months) is not modelled, so a first/second-year autónomo is OVER-stated by up to €1,510.57/yr; (f) autónomos societarios get a 3% deduction, not 7% (computable = profit × 0.97, i.e. a higher tramo at the same profit) — Ember has no company-director axis on business income and assumes 7% universally; (g) the cuota attaches to RETA MEMBERSHIP, not to profit, but Ember drives it off annual profit, so a dormant or loss-making autónomo models €0 where the statute still charges the floor; (h) the cuota is a deductible expense of the activity under Art. 30 LIRPF and this pack does NOT net it off the income-tax base, so ES sole-trader income tax is separately OVER-stated (≈€469 at €10,000 of profit rising to ≈€3,280 at €80,000) — tracked as its own cross-cutting engine item, not a defect of this module
• reduced corporate rates not modelled — corporationTax charges the flat 25% general rate for every ES company. Ley 7/2024 (DT 44ª LIS) phases lower rates the pack cannot apply because it has no turnover axis: microempresas (cifra de negocios < €1M) pay 19% on the first €50,000 and 21% on the remainder in 2026 (21%/22% in 2025, 25% from 2027); entidades de reducida dimensión (< €10M) pay 23% in 2026, stepping 22%/21% in 2027–28 and 25% from 2029. ES company profits are therefore OVER-taxed for both tiers — re-verify against DT 44ª before roadmap item #11 (corp-tax relief on company pension contributions) consumes this module
• 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: BOE — Ley 19/1991, del Impuesto sobre el Patrimonio (state Art. 30 scale); BOE — Ley 38/2022 (Impuesto Temporal de Solidaridad de las Grandes Fortunas), texto consolidado — art. 3 apdos. nueve (mínimo exento €700.000) y veintiocho (vigencia); BOE — Real Decreto-ley 8/2023, DA 5ª.2 (prórroga del ITSGF hasta la revisión de la tributación patrimonial) y modificación del art. 3.9 de la Ley 38/2022 (mínimo exento €700.000 para todos los sujetos pasivos); 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); AEAT Manual práctico Renta — gravamen estatal de la base liquidable general (state half of the scale; the pack doubles it for the autonomic default); AEAT Manual práctico Renta — mínimo del contribuyente (€5.550; +€1.150 >65; +€1.400 further >75); AEAT Manual práctico Renta — gravamen estatal de la base liquidable del ahorro (savings scale underlying dividendTax); BOE — Orden PJC/297/2026, art. 18 (bases y tipos de cotización RETA 2026: tramos, todas las bases mínimas, base máxima €5.101,20/mes; tipos itemizados verbatim: 28,30 comunes + 1,30 profesionales + 0,90 MEI = 30,50%. Cese de actividad 0,90 y formación profesional 0,10 NO se itemizan en el art. 18 — proceden de lecturas de práctica de la misma Orden, corroboradas por la exención del art. 18.9 a los miembros de institutos religiosos ⇒ agregado 31,50%); BOE — RD-ley 13/2022 (nuevo sistema de cotización RETA por rendimientos), que da su redacción vigente al art. 308.1.c) del TR LGSS (RDLeg 8/2015) — rendimientos netos computables: regla 1.ª rendimiento neto + cuotas de la Seguridad Social; regla 2.ª deducción por gastos genéricos del 7%, sin límite (3% para los del art. 305.2.b) y e)) ⇒ computable = beneficio × 0,93; AEAT — IRNR sin establecimiento permanente, tipos de gravamen (24% general / 19% UE-IS-NO-LI)

• 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
• savings income has no separate schedule: the Personal Savings Allowance (£1,000 basic rate / £500 higher rate / £0 additional rate) and the 0% starting rate for savings (up to £5,000, reduced £1 for £1 by other income above the personal allowance) are not modelled — interest entered as ordinary income is charged on the 20/40/45 scale from the first pound, overstating tax for a user holding cash or bonds
• the £1,000 trading allowance and £1,000 property allowance are not modelled; small trading and property receipts are taxed in full (the rental expense haircut partly offsets the latter)

Source: GOV.UK Income Tax rates and Personal Allowances; GOV.UK National Insurance rates and categories; HMRC — Income Tax rates and allowances: current and past (2026 to 2027 table, column 'Income after allowances'); GOV.UK — Tax on dividends (2026-27: £500 allowance, 10.75% / 35.75% / 39.35%); HMRC — Rates and allowances: Corporation Tax (FY beginning 1 April 2026); HMRC — Rates and allowances: National Insurance contributions (Class 2 SPT £7,105, Class 4 6%/2%); GOV.UK — Rates and thresholds for employers 2026 to 2027 (Class 1 PT £12,570/yr, UEL £50,270/yr)

• 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 (ειδική εισφορά αλληλεγγύης, άρθρο 43Α ΚΦΕ) — abolished for all income of that article arising from 1 January 2023 onwards, so nothing is modelled and nothing is due for the modelled years.
• 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 NOT modelled (€900 / €1,120 / €1,340 / €1,580 / €1,780 for one to five dependent children, plus €220 per child beyond the fifth; the €20-per-€1,000 taper does not apply at all to taxpayers with five or more dependent children); 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
• schedular routing not modelled — any rental or business item routed to a Greek residence is pooled into the άρθρο 15 scale above and receives the άρθρο 16 credit. Statutorily, income from immovable property is taxed on its own separate scale (αυτοτελώς) and the άρθρο 16 reduction does not apply to profits from business activity, which are taxed on this scale but without the reduction (professional farmers excepted). The modelled charge on those two classes therefore differs from the statutory one; only employment and pension income ride this scale exactly.

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); Υπουργείο Εθνικής Οικονομίας και Οικονομικών — announcement of the ν.5246/2025 (ΔΕΘ) bill: 2026 scale 9/20/26/34/39/44 at €10k/20k/30k/40k/60k edges; Υπουργείο Εθνικής Οικονομίας και Οικονομικών — Έκθεση Φορολογικών Δαπανών, Προϋπολογισμός 2026 (Νοέμβριος 2025), pp. 6–8: άρθρο 16 ΚΦΕ €777 childless reduction, €20-per-€1,000 taper over €12,000, non-refundable clamp, and the άρθρο 43Α abolition from 1.1.2023. CAUTION: records law as at 30/9/2025 — its άρθρο 15 and rental tables are the PRE-ν.5246/2025 ones and must NOT be used to check this pack's bands

• 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) applies on top of income tax and is NOT modelled: 2026 standard scale 0.5% on the first €12,012, 2% on the next €16,688, 3% on the next €41,344 and 8% on the balance; no USC where total income is €13,000 or less, and once that limit is exceeded USC applies to the full income; a reduced 0.5% (first €12,012) / 2% (balance) scale applies where you are aged 70 or over, or hold a full medical card, and income is €60,000 or less; a further 3% applies to non-PAYE income above €100,000. Irish-resident years therefore show less tax than the total charge on that income.
• PRSI (Class A) applies on top for working-age earners and is NOT modelled. The employee rate rises in steps each 1 October under a legislated multi-year schedule, so any single figure dates quickly; it generally does not apply to occupational pension or drawdown income and ceases at age 66. Irish-resident working years therefore show less deduction than the total charge on that income.
• 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: Revenue.ie — Tax rates, bands and reliefs (2026: single standard rate cut-off €44,000 @ 20%, balance @ 40%; personal credit €2,000; employee credit €2,000; earned income credit €2,000 — unchanged from 2025); 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); Ember tax-rulepack dossier §5.8 (IE) — internal working note, itself sourced from PwC Worldwide Tax Summaries (secondary; corroborating only)

• §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 up to Rs 50,000 (its own deduction is one-third of the income or Rs 25,000, whichever is less)
• Health & Education Cess of 4% is applied on top of tax+surcharge; not modelled (understates total liability by ~4% of tax).
• Surcharge on high incomes is not modelled: under the new default regime it runs 10% (total income over Rs 50L up to Rs 1cr), 15% (over Rs 1cr up to Rs 2cr) and 25% (over Rs 2cr, excluding the dividend and s.196-198 capital-gains component, which is itself capped at 15%), with marginal relief throughout; the 37% rate does not apply under this regime.
• OLD regime (with Chapter VI-A deductions such as 80C, 80D and HRA, a standard deduction of Rs 50,000, and its separate slab structure 0/5/20/30 with a Rs 2,50,000 basic exemption — Rs 3,00,000 for residents aged 60-79 and Rs 5,00,000 for residents aged 80 or over) is not supported; only the NEW default regime is encoded. Rs 75,000 is the new-regime standard deduction only.
• 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
• The rebate is available only to a resident individual; the engine applies it on the residence stack only, so Indian-source income held by a non-resident is outside the modelled path.

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); Memorandum explaining the provisions in the Finance Bill 2026 (Ministry of Finance) — Part II: rates for tax year 2026-27 under Income-tax Act 2025 s.202; slabs 0/5/10/15/20/25/30, surcharge 10/15/25 with 37% inapplicable, 4% Health & Education Cess; Memorandum explaining the provisions in the Finance Bill 2025 (Ministry of Finance) — §87A rebate for a resident individual: Rs 7,00,000 to Rs 12,00,000 and Rs 25,000 to Rs 60,000, special-rate income excluded; Memorandum explaining the provisions in the Finance (No.2) Bill 2024 (Ministry of Finance) — s.16(ia) standard deduction Rs 50,000 to Rs 75,000 for the new regime only; s.57(iia) family pension Rs 15,000 to Rs 25,000

• regional (base 1.23%, up to 3.33% in ordinary regions and higher in regions under a healthcare deficit plan) and municipal (up to 0.8%, Roma Capitale 0.9%) IRPEF surcharges are not modelled — the Italian income tax shown is understated by up to roughly 4.2% of taxable income, depending on the user's region and comune
• 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
• 2026 high-income sterilisation (L. 199/2025 art. 1 co. 4, art. 16-ter co. 5-bis TUIR): for reddito complessivo above €200,000 the detrazioni for 19%-rate oneri are cut by €440 — not modelled, and immaterial here because no detrazioni are modelled at all
• dividends and financial capital gains: Italy's flat 26% imposta sostitutiva (unchanged for 2026; crypto-assets are the exception: 33% from 1 January 2026, except euro-denominated e-money tokens under Regulation (EU) 2023/1114, which stay at 26% (L. 199/2025 art. 1 co. 28)) 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 §5.6 (IT — MEF/Agenzia Entrate); Agenzia delle Entrate — Aliquote e calcolo dell'Irpef (aggiornato 13 gennaio 2026); Legge 30 dicembre 2025 n. 199 (Legge di Bilancio 2026), art. 1 co. 3 — seconda aliquota IRPEF 35% → 33%

• Territorial basis IS modelled; remittance is NOT, and is defaulted. Malaysia charges income tax under s.3 ITA on income accruing in or derived from Malaysia AND on foreign-source income received in (remitted to) Malaysia by a resident — Sch 6 para 28, as rewritten by Finance Act 2021 [Act 833], leaves that exemption only for non-residents — but the Income Tax (Exemption) (No. 5) Order 2022 [P.U.(A) 234/2022], as amended by P.U.(A) 451/2024 (made 11 December 2024, in operation 1 January 2027), exempts a resident individual from tax on gross income from all s.4 sources received in Malaysia from outside Malaysia, from 1 January 2022 to 31 December 2036. This pack now declares that exemption as a territorial scope (owner rulings T-D1 to T-D4 of 2026-08-07 and T-D5 to T-D11 of 2026-08-08, docs/decisions/2026-08-08-owner-rulings.md), so a Malaysian-resident user's FOREIGN pensions, dividends, rental and other foreign-source income carry NO Malaysian charge for years of assessment up to and including 2036 — the whole liability that the pre-primitive pack would have charged. Malaysian-source income is untouched. FOUR RESIDUAL GAPS, each deliberate: (1) REMITTANCE IS NOT AN INPUT (ruling T-D2). Unremitted foreign income is outside s.3 altogether and remitted foreign income is exempt by the order, so while the exemption runs both routes give nil and this pack assumes a non-remitting resident. That assumption becomes load-bearing only at the sunset, and it is why this pack carries the defaulted-scope-inputs badge. (2) THE PARTNERSHIP CARVE-OUT IS NOT ENCODED. Para 3(1) excludes 'a source of income from a partnership business in Malaysia'; Ember's income categories have no partnership axis, and excluding business income wholesale would wrongly deny the exemption to a genuinely foreign business, so a Malaysian partnership's foreign-source income received in Malaysia is exempted here when the order says it should not be. (3) THE PARA 3(2) 'SUBJECT TO TAX' CONDITION IS NOT MODELLED AS A GATE — deliberately: the LHDN Director-General guideline that para 3(3) makes it turn on treats the condition as met even where the source country levied nothing, because its tax system does not tax that income, because the income fell below its taxable threshold, or because an incentive exempted it (its worked examples include Brunei employment income and a withdrawal from an approved Singapore retirement fund). (4) THE SUNSET IS A HARD FLIP (ruling T-D3). From YA2037 the full resident scale returns to foreign-source income. Enacted law is modelled and renewal is not, even though the original order has already been extended once (P.U.(A) 451/2024, gazetted two years ahead of the old expiry) — the flip is the conservative, over-tax direction. TREATY INTERACTION (ruling T-D4): while the exemption runs, a treaty row that made Malaysia the only taxing state has its relief withdrawn on the source side, because UK-Malaysia DTA Art. 25(1) limits relief to 'so much of the income as is taxed in the other contracting state' and none is. So a UK private or occupational pension of a Malaysian resident is UK-taxed until YA2036 and Malaysia-taxed from YA2037, which is the two-period answer a treaty row (no time axis) could not express. Rows relieved by CREDIT — UK rental, the UK State Pension — are untouched by that withdrawal: the UK charge already stood and the Malaysian credit was simply nil. WHICH CATEGORIES THAT WITHDRAWAL CAN REACH: the allocator consults a treaty row only for business, salary, rental and pension items — dividends and portfolio drawdown route domestically — so the withdrawal can only ever fire on those four categories. The GB→MY DIVIDEND row is therefore never consulted, and a foreign dividend simply falls out of charge with no relief to withdraw. That is the right answer for the UK specifically, because the UK levies no withholding on dividends paid to non-residents; a source country that DOES withhold would keep charging in reality while this model shows nil — see the foreign-withholding entry below.
• Foreign SOURCE withholding is not modelled, and business/salary source is the payer's REGISTRATION country. Two limits of the territorial modelling above, both in the UNDER-tax direction, both disclosed rather than modelled. (i) NO FOREIGN WITHHOLDING. Once this pack puts a resident's foreign-source income outside the Malaysian charge, Ember books tax at source only where a treaty row or a model default routes a source leg. Distributions from a foreign-INCORPORATED company route DOMESTICALLY as dividends (the allocator takes its cross-border branch for business, salary, rental and pension only), so a Malaysian resident's distribution from a US company shows zero tax here while the United States would in reality withhold 30% of the gross under its FDAP rules absent treaty relief — and the same holds for any source country that withholds on outbound distributions. Ember has no withholding axis for dividends, so this is a real under-statement, not a rounding. (ii) SOURCE IS WHERE THE PAYER IS REGISTERED, NOT WHERE THE WORK IS DONE. For business and salary items Ember reads sourceISO from the entity's registration country. Malaysian law asks a different question: s.3 ITA charges income 'accruing in or derived from Malaysia', so services physically performed in Malaysia are MALAYSIAN-source however the payer is registered — and Malaysian-source income is outside the foreign-source exemption entirely. A resident consultant working in Malaysia for a foreign-registered client is therefore exempted here where the statute charges. Modelling it would need a place-of-performance input Ember does not collect.
• Personal reliefs beyond RM9,000 are not modelled. Only the s.46(1)(a) RM9,000 individual-and-dependent-relatives deduction is modelled. Malaysia grants a long list of receipt-driven reliefs — parents' medical RM8,000; disabled individual RM7,000; self-education RM7,000; serious-disease and fertility medical RM10,000; lifestyle RM2,500 plus RM1,000 sports; SSPN RM8,000; spouse or alimony RM4,000; child reliefs; life insurance and EPF and the s.49(1D) PRS/deferred-annuity relief; education and medical insurance; childcare — and Finance Act 2025 [Act 874] adds more for YA2026 (s.46(1)(sa), RM1,000 for tourist-attraction entrance fees and cultural or arts programmes; a RM2,500 EV-charging / food-waste / CCTV bundle; a re-cut childcare relief; s.46(1)(ha) raised from RM6,000 to RM10,000). None of them is evidenced by anything Ember holds, so chargeable income here is over-stated — and the tax with it — for anyone entitled to them. Do not copy a YA2026 relief figure from any secondary listing without checking Act 874.
• Dividend tax — the RM100,000 is a threshold with a cliff, and the competing reading is disclosed. ITA Sch 1 Part XXII (inserted by Finance Act 2024 [Act 862] s.16, effective YA2025 onwards and unchanged for YA2026) charges 2% on an individual shareholder's chargeable income in respect of dividends deemed derived from Malaysia by s.14 'in excess of one hundred thousand ringgit', while Sch 6 para 12B(2) exempts dividends to an individual 'amounting to one hundred thousand ringgit or less'. OWNER RULING D2 (2026-08-07) reads those together as a CLIFF, and that is what this pack models: at or under RM100,000 the dividend is exempt outright, and one ringgit above it the 2% falls on the WHOLE apportioned chargeable dividend income D = A × C / B (P.U.(A) 148/2025 r.2(1)), with the C − D remainder returned to the Part I scale (r.2(4)). Primary authority points that way: Part XXII para 1 charges the 2% 'on every ringgit of the chargeable income in respect of such dividend', i.e. the whole apportioned base once the dividend exceeds RM100,000; Sch 6 para 12B(2)'s exemption of a dividend 'amounting to one hundred thousand ringgit or less' is all-or-nothing rather than a first-RM100,000 slice, and its Act 874 sibling for LLP distributions (Sch 6 para 12D) is drafted identically; P.U.(A) 148/2025 ascertains that base as D = A × C / B with no RM100,000 anywhere in the formula; and MOF's own Budget-2025 appendix describes it the same way ('nilai ambang: pendapatan dividen tahunan yang melebihi RM100,000', with the 2% then applied to the chargeable dividend income after reliefs and deductions). THE COMPETING PRACTITIONER READING, disclosed rather than dismissed: most commentary (Azmi & Associates, L&Co, ClearTax) reads the RM100,000 as an ALLOWANCE — 2% on the excess only — parsing 'in excess of one hundred thousand ringgit' as qualifying the charge base. LHDN's own worked example (the e-BE explanatory notes) is a dead link, so nothing on hasil.gov.my settles it, and the ruling took the evidence-weighted and conservative side of a genuine ambiguity. Where the allowance reading is right this pack over-taxes a resident shareholder with more than RM100,000 of Malaysian-source dividends: RM36,037.14 charged against RM33,150 due — RM2,887.14, 8.7% of the allowance-reading bill, on RM150,000 of dividends alongside RM200,000 of other income. That is one worked case, not the exposure. Differencing the two readings in closed form — this pack charges 2% of D = A × C / B and puts the C − D remainder back on the Part I scale (P.U.(A) 148/2025 r.2(1) and r.2(4)), the allowance reading charges 2% of the dividend above RM100,000 — gives a gap of 2% × RM100,000 plus (the ordinary marginal rate less 2%) × RM9,000 × A/B. It therefore does NOT scale with dividend income: RM1,820 at the floor, RM2,887.14 on the case above, and never more than RM4,520 a year however large the dividend. What scales, and the other way, is the gap's share of the bill, which grows as the dividend approaches the RM100,000 threshold — 0.9% for RM150,000 of dividends beside RM1,000,000 of other income, 8.7% on the case above, 182% for a dividend-only filer on RM150,000, and 910% on RM110,000 of dividends alone, where RM2,020 is charged against RM200 on the allowance reading. NOW MODELLED, so no longer a gap: the P.U.(A) 148/2025 A × C / B apportionment of the relief pool between the dividend and non-dividend parts — the dividend leg takes its A/B share of the RM9,000 (RM3,857.14 on the case above) instead of the whole relief staying on the ordinary base, so the ≤RM180-a-year dividend-leg over-tax the earlier stacked shape carried is gone. Still not modelled: the exclusions for dividends out of pioneer-status, reinvestment-allowance or exempt-shipping profits, co-operative dividends, closed-end-fund declarations and Labuan-entity dividends, and distributions by EPF, LTAT, ASNB or any unit trust; and the identical 2% charge on limited-liability-partnership profit distributions to an individual partner above RM100,000 (ITA Sch 1 Part XXIII, Finance Act 2025 [Act 874] s.17, effective YA2026), which Ember has no income category for. Foreign-source dividends are outside this charge entirely — they are foreign-source income, see the first entry.
• Pensions: the Sch 6 para 30 exemption is deliberately NOT modelled (owner decision D3). ITA Sch 6 para 30 exempts a pension derived from Malaysia, paid on reaching age 55 or the compulsory retirement age specified under written law or on ill-health retirement, in respect of services rendered in exercising a former employment in Malaysia and (where not paid under written law) out of an approved scheme — and where a person is paid more than one pension it applies to the higher or highest pension only. Ember knows neither the source-employment of a pension nor how to rank several of them, so modelling it would be a large silent under-tax; omitting it is a bounded over-tax confined to genuinely Malaysian-source pensions. A FOREIGN pension is unaffected by this choice: it is covered by the foreign-source-income entry above instead, which is where its real exemption comes from. Also not modelled: Sch 6 para 30A (parliamentary and state-assembly pensions and gratuities), the retirement-gratuity exemptions of Sch 6 paras 25, 25A, 25B and 25D, the non-taxability of EPF withdrawals and EPF dividends (no s.4 charge, plus the Sch 6 para 20 exemption of an approved scheme's own income), and the 8% withholding under ITA s.109G with Sch 1 Part XVI on withdrawal from a private retirement scheme or deferred annuity before age 55.
• selfEmployment: researched, and there is nothing mandatory to model — this module is null by design, not by omission. Unlike Spain's RETA or the UK's Class 2/4, Malaysia imposes no mandatory social contribution on self-employment profit. EPF is an employer–employee obligation under the Employees Provident Fund Act 1991; a self-employed person's route in is i-Saraan, an expressly voluntary facility (government incentive 20% of the contribution, capped RM500 a year and RM5,000 lifetime or age 60). PERKESO's Self-Employment Social Security Scheme under the Self-Employment Social Security Act 2017 (Act 789) is compulsory only in the passenger-transport sector — taxi, e-hailing and bus drivers — from 1 June 2017, extended to 19 further informal sectors from 1 January 2020 (PERKESO's page does not say whether contribution in those added sectors is compulsory or merely available), and even where it bites it is a fixed contribution by chosen insured-earnings plan (RM157.20 / RM232.80 / RM442.80 / RM592.80 a year), never a percentage of profit.
• Rental: resident letting rides the ordinary progressive scale as s.4(d) income — there is no flat schedular rate for residents, hence no `residentRentalFlat` module. The statutory deductions are the direct expenses of Public Ruling 12/2018 para 8.2: assessment and quit rent, interest on the loan financing the property, fire-insurance premium, rent-collection costs, tenancy-renewal costs and ordinary repairs. The engine's vacancy and maintenance haircuts stand in for that list — and note that unlike Portugal, Malaysian mortgage interest IS deductible, so the haircut under-states the deduction for a leveraged landlord. Not modelled: the denial of initial expenses (first-tenant advertising, first tenancy-agreement legal fees, stamp duty, agent's commission — para 8.3); the ring-fencing of a s.4(d) adjusted loss, which cannot reduce aggregate income and cannot be carried forward (para 7); the two-year limit on deducting the expenses of an untenanted period (para 8.4.2); and the s.4(a) business-source treatment where comprehensive maintenance and support services are provided, which changes capital-allowance eligibility. The 50% exemption for residential rents up to RM2,000 a month expired after YA2020 and has no YA2026 successor.
• Capital gains and RPGT are outside this pack. Malaysia's capital gains tax (Finance (No. 2) Act 2023 [Act 851], in force 1 January 2024) charges only a company, limited liability partnership, trust body or co-operative society — ITA Sch 1 Part XXI and LHDN's Director-General guideline of 21 July 2025 para 4 — so an individual pays no CGT on shares, listed or unlisted, and the zero-CGT MY row in cgtByCountry is correct for individuals. Real property is different and is not modelled here: RPGT Act 1976 Sch 5 charges an individual citizen or permanent resident 30% / 20% / 15% / nil for a disposal within 3 years / in the 4th / in the 5th / in the 6th year or later, but a disposer who is neither a citizen nor a permanent resident pays 30% for the first five years and 10% from the sixth year, with no taper to nil — the likely position of a non-Malaysian Ember user owning Malaysian property, and the opposite of the intuition a 'Malaysia has no CGT' headline creates. Also not modelled: the Sch 4 para 2 exemption of RM10,000 or 10% of the chargeable gain, whichever is greater, available to individuals; the once-in-a-lifetime private-residence exemption (s.8 RPGTA); no-gain-no-loss transfers between spouses or to a controlled company; and the acquirer's retention-and-remittance duty under s.21B.
• Interest: Ember has no interest income category, so Malaysia's interest exemptions are not modelled. ITA Sch 6 para 35 exempts interest or discount paid to an individual on Government-issued or Government-guaranteed securities, on Securities Commission-approved or authorised debentures and sukuk, and on Bon Simpanan Malaysia; para 34A exempts Merdeka Bond interest; and interest on deposits with licensed banks, Islamic banks and prescribed development financial institutions is exempt for resident individuals by exemption order. Interest entered under any taxable category rides this pack's resident scale and is over-taxed.
• Joint assessment and spouse reliefs are out of scope. s.45 ITA lets a married couple elect combined assessment, and P.U.(A) 148/2025 r.2(3) aggregates spouse income for the dividend formula. Ember models a single filer here (no `jointFiling` module), so the s.47 spouse deduction (RM4,000), the s.45A separately-assessed-wife rebate and the s.6A(2)(b) and s.6A(2)(c) rebates are not modelled.
• The RM400 rebate is an untapered cliff. Under s.6A(2)(a) it is withdrawn entirely one ringgit past RM35,000 of chargeable income, so RM100 more chargeable income can cost RM406 more tax. That is the statute, not a bug. Engine shape: the taxRebate primitive tests TOTAL income (the stack base before this pack's allowance), so the statutory chargeable-income test is re-expressed exactly as total income of RM 44,000 — RM35,000 plus the RM9,000 s.46(1)(a) deduction. The two are identical under this pack's single-relief model; if a second relief is ever modelled, the threshold must move with it. Not modelled: s.6A(2)(b) and (c) (the s.47 husband-or-wife and separately-assessed-wife rebates), the s.6A(2A) departure-levy rebate for umrah and religious pilgrimage, and the s.6A(3) zakat and fitrah rebate, which is a real reduction for Muslim taxpayers.
• Basis period and indexation. Malaysia assesses on a current-year basis: an individual's basis period for a year of assessment is the basis year, i.e. the calendar year (ITA ss.20–21), so YA2026 taxes calendar-2026 income and this pack is keyed by income year like every pack except SG. The bands, the RM9,000 deduction, the RM400 rebate and the RM100,000 dividend threshold are static ringgit amounts with no statutory indexation — they move only when a Finance Act moves them. LHDN's rate page is still labelled 'Year of Assessment 2023, 2024 & 2025'; that is a page-labelling lag, not a rate change, because Finance Act 2025 [Act 874] does not touch Sch 1 Part I.
• The non-resident flat rate is modelled for RENTAL ONLY. ITA Sch 1 Part I para 1A charges a non-resident individual 30% on every ringgit of chargeable income, with no s.46(1) personal deductions and no s.6A rebate (both are limited by statute to a resident). The engine can express that only through the nonResidentRental module, which this pack sets to 30% on the net figure for both cohorts. Any OTHER Malaysian-source income of a non-resident — a Malaysian pension, salary or business profit routed to a non-Malaysian residence — rides this pack's resident progressive scale WITH the RM9,000 allowance instead of the flat 30%, and is therefore UNDER-taxed. Malaysian rent is assessed, not withheld; that conclusion is argued from LHDN's exhaustive withholding table plus the absence of any s.109-series provision for rent of immovable property rather than from an express negative statement, and it affects only the collection mechanism, which Ember does not model. Residence itself is the s.7 ITA day-count test (182 days, the linked-period rule, the 90-day plus three-of-four-years rule, and the following-year rule after three resident years) — Ember does not compute Malaysian residence, it is told the residence jurisdiction.

Territorial scope modelled: Malaysia does not tax a resident individual's foreign-source income for YA2022–YA2036: P.U.(A) 234/2022 para 3(1), as extended to 31 December 2036 by P.U.(A) 451/2024, exempts the gross income from all section 4 sources received in Malaysia from outside Malaysia, and unremitted foreign income is outside the ITA s.3 charge altogether. This pack models the EXEMPTION only and assumes the resident does not bring foreign income into charge; remittance is not an input (owner ruling T-D2, 2026-08-07 — while the exemption runs both routes give the same nil charge). Excluded from the order but NOT from this model: a source of income from a partnership business in Malaysia, which the engine's income categories cannot express. From YA2037 the full resident scale returns to foreign-source income (owner ruling T-D3 — enacted law is modelled, renewal is not, even though the 2022 order has been extended once). Authority: Income Tax (Exemption) (No. 5) Order 2022 [P.U.(A) 234/2022] paras 1(2), 2, 3(1)–3(4), as amended by the Income Tax (Exemption) (No. 5) Order 2022 (Amendment) Order 2024 [P.U.(A) 451/2024] (made 11 December 2024, in operation 1 January 2027, substituting '31 December 2036' for '31 December 2026' in para 1(2)); ITA 1967 (Act 53) s.3 and Sch 6 para 28 as rewritten by Finance Act 2021 [Act 833]; LHDN Director-General guideline 'Layanan Cukai Berhubung Pendapatan yang Diterima dari Luar Negara' (Pindaan Jun 2024) para 5.2.2.2; MOF Budget 2026 Lampiran 8. Provenance next reviewed 2027-04-06.

Source: Income Tax Act 1967 (Act 53), consolidated text as at 21 May 2024 — LHDN copy (Sch 1 Parts I/XVI/XXI, ss.3, 4, 6A, 7, 20–21, 33, 45, 46, 109G, Sch 6 paras 20, 25–25D, 28, 30, 30A, 34A, 35). This consolidation PREDATES Finance Act 2024 [Act 862]: Sch 1 Part XXII and the YA2025 re-cut of Sch 6 para 12B are not in it, and are cited to MY-FA-862 instead; LHDN — Individual → Tax Rate (resident scale and cumulative tax; page still labelled 'Year of Assessment 2023, 2024 & 2025', updated 26/06/2026); LHDN — Individual → Tax Relief (relief table incl. the RM9,000 individual and dependent relatives deduction); LHDN — Individual → Residence Status (the s.7 ITA day-count tests); LHDN — Legislation → Withholding Tax (rate/forms table; no line for rent of immovable property); Finance Act 2024 [Act 862] — ss.3(1), 4 (ITA s.6(1)(r)), 16 (Sch 1 Part XXII, 2% dividend tax) and 17 (Sch 6 para 12B); LHDN's own PDF is an image scan, text read from Moore Malaysia's gazette reproduction; Finance Act 2025 [Act 874], royal assent 27 December 2025 — the Budget-2026 finance act (Sch 1 amendment inserts Part XXIII only; Part I untouched; s.46(1) amended at (ca)/(g)/(ha)/(r)/(v) with new (sa)); Income Tax (Exemption) (No. 5) Order 2022 [P.U.(A) 234/2022] — the resident-individual foreign-source-income exemption; Income Tax (Exemption) (No. 5) Order 2022 (Amendment) Order 2024 [P.U.(A) 451/2024], made 11 December 2024, in operation 1 January 2027 — extends the individual FSI exemption to 31 December 2036; Income Tax (Determination of Chargeable Income of an Individual in Respect of Dividend) Rules 2025 [P.U.(A) 148/2025] — the A × C / B apportionment, YA2025 onwards; LHDN Director-General guideline — Layanan Cukai Berhubung Pendapatan yang Diterima dari Luar Negara (Pindaan Jun 2024), the guideline P.U.(A) 234/2022 para 3(3) makes conditional; LHDN Director-General guideline — Garis Panduan Cukai Keuntungan Modal bagi Saham Tidak Tersenarai, 21 July 2025 (para 4: the persons chargeable to CGT are companies, LLPs, trust bodies and co-operatives); Real Property Gains Tax Act 1976 (Act 169), consolidated text as at 1 June 2023 (Sch 5 rates Parts I/II/III, Sch 4 para 2 exemption, s.8, s.21B); LHDN — RPGT → Real Property Gains Tax (RPGT) Rates (page updated 23/06/2026; Part I nil from the 6th year since 1.1.2022); LHDN — RPGT → Exemption (Sch 4 para 2: RM10,000 or 10% of the chargeable gain, whichever is greater, for individuals); LHDN Public Ruling No. 12/2018 — Income from Letting of Real Property, 19 December 2018 (paras 4–5, 7, 8.2–8.5); MOF Budget 2025 — Langkah Cukai 2025, Lampiran 10 (dividend-tax scope, threshold wording and the exhaustive exclusion list incl. EPF, LTAT, ASNB and unit trusts); MOF Budget 2026 — Lampiran 7 (the LLP-partner 2% charge) and Lampiran 8 (individual FSI exemption 1 January 2022 to 31 December 2036); PERKESO — Self-Employment Social Security Scheme (Act 789): compulsory passenger-transport sector, 19 further informal sectors from 1 January 2020, fixed contribution plans; Self-Employment Social Security Act 2017 (Act 789), online updated text (located, not opened — the compulsory-scope conclusion rests on PERKESO's own scheme page); EPF (KWSP) — i-Saraan voluntary contribution facility for the self-employed (403 to automated fetch; the incentive figures come from KWSP's own Budget-2026 article, the voluntariness from the scheme's statutory basis); Ember MY pack build — primary-source dossier and owner decision sheet (D1–D8)

• 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
• interest income has no engine category — art. 30a ust. 1 pkt 1–3 taxes interest and discount at the same 19% schedular rate as dividends, so bank/bond interest entered under any other category rides the 12%/32% scale instead
• private rental ryczałt not modelled — since 2023 the lump-sum regime on GROSS rental revenue is the only form of taxation for najem prywatny (8.5% to PLN 100,000, 12.5% above; PLN 200,000 threshold for spouses filing one joint rental declaration), with no expense deduction and no kwota wolna; this pack routes rental income through the 12%/32% scale with the PLN 30,000 allowance, so a landlord below the threshold is under-taxed and one whose other income already fills the 32% band is over-taxed
• ulga dla pracujących seniorów (art. 21 ust. 1 pkt 154 PIT) not modelled — employment, umowa-zlecenia, maternity-benefit and business revenue received by a woman aged 60+ or a man aged 65+ who is subject to social insurance on that revenue and who, despite being entitled, draws no pension is exempt up to PLN 85,528 per tax year (a ceiling shared with the 4+ families and return reliefs); this pack taxes that revenue in full on the scale, so an eligible senior who defers drawing a pension is over-taxed by up to about PLN 6,700 a year. The exemption does not reach pension or rental income.
• joint-filing eligibility bars (art. 6 ust. 6–8 PIT) not modelled — the wspólne opodatkowanie election requires a subsisting marriage and community of property for the whole tax year and is unavailable where either spouse is taxed under podatek liniowy (art. 30c) or ryczałt other than on private rental; this pack applies the splitting tariff whenever the household joint-filing gate is on

Source: Ustawa o podatku dochodowym od osób fizycznych — tekst jednolity, Dz.U. 2026 poz. 592 (obwieszczenie Marszałka Sejmu z 17.04.2026): art. 27 ust. 1 (skala 12%/32%, kwota zmniejszająca 3 600 zł), art. 30a ust. 1/6/7/9 (19% zryczałtowany), art. 6 ust. 2 (wspólne opodatkowanie), art. 21 ust. 1 pkt 154, art. 30h (danina solidarnościowa 4%); Ministerstwo Finansów (podatki.gov.pl) — PIT: stawki i limity (strona zaktualizowana 15.12.2025); Ministerstwo Finansów (podatki.gov.pl) — Dochody z najmu: ryczałt 8,5%/12,5%, jedyna forma opodatkowania od 2023; Ministerstwo Finansów (podatki.gov.pl) — Ulga dla pracujących seniorów (strona zaktualizowana 24.06.2026); Ember tax-rulepack dossier §5.10 (PL)

• 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) 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). EBF Art. 45.º-C (added by DL 97/2026, effects from 1 January 2026) sets a 10% autonomous rate, in place of the 25% modelled here, on income from leases used exclusively for housing whose monthly rent does not exceed 2.5 × the 2026 guaranteed minimum monthly wage (DL 97/2026 Art. 2.º(2)(a); the limit may be updated by portaria under Art. 2.º(3), is measured as the annual value divided by the months elapsed under Art. 3.º(3), and is tested against the total rent where there are several tenants under Art. 3.º(2)). The rate applies to income earned up to 31 December 2029 and is not an election. Because the engine holds one flat rate, rental income from leases within that limit is modelled 15 percentage points higher than the statutory charge — on the resident leg and equally on the non-resident leg, since Art. 45.º-C is drafted by reference to the CONTRACT and carries no residence condition. A ceiling-gated fix is queued as an engine slice (owner ruling 2026-08-03).
• 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); Decreto-Lei n.º 97/2026, de 20 de maio (autorização: Lei n.º 9-A/2026, de 6 de março) — Art. 9.º adds EBF Art. 45.º-C: 10% autonomous rate on residential-lease Cat F income with monthly rent within the Art. 2.º(2)(a) limit, income earned to 31 Dec 2029; Art. 5.º adds the matching 10% withholding at CIRS Art. 101(1)(f); Art. 18.º(2) — effects from 1 Jan 2026; 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)

• 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 collapsed to the 32.38% national average: 2026 total kommunal skattesats ranges from 28.93% (Österåker) to 35.65% (Dorotea), so a resident's actual municipal rate can differ from the modelled figure by roughly ±3.3 percentage points (SCB, Kommunalskatterna 2026)
• ISK and kapitalförsäkring (KF) schablonbeskattning not modelled: both wrappers are taxed on a deemed yield rather than on realised gains, sharing one skattefri grundnivå of SEK 300,000 from 1 January 2026, with a 2026 schablonintäkt of 3.55% (statslåneränta 2.55% + 1.0pp) taxed at 30% ⇒ 1.065% effective. Holdings in these wrappers are modelled on the ordinary realised-gain 30% basis instead (Skatteverket, Investeringssparkonto; Belopp och procent 2026)
• selfEmployment: no regime module — self-employed social contributions / business-income surcharges for this jurisdiction are not modelled
• age-dependent brytpunkt not modelled: the 20% national layer is anchored at the under-66 brytpunkt SEK 660,400 (skiktgräns SEK 643,000 + the SEK 17,400 grundavdrag floor). Someone who has turned 66 by the start of the income year has a brytpunkt of SEK 760,500 (förhöjt grundavdrag floor SEK 117,500), so a 66+ Swedish resident is modelled as entering the national layer SEK 100,100 of gross income earlier than statute provides (Skatteverket, Skiktgränser och brytpunkter 2020–2026, tabell 3–4)
• jobbskatteavdrag (skattereduktion för arbetsinkomst) not modelled: a tax reduction on arbetsinkomst, deductible only against kommunal inkomstskatt and built into Skatteverket's tax tables, worth up to SEK 53,147 (under 66) or SEK 37,313 (66+) in 2026. Employment and business income is therefore modelled without it and is over-taxed by up to those amounts. Pension income does not qualify for jobbskatteavdrag, so drawdown projections are unaffected (Skatteverket, Jobbskatteavdrag; Skiktgränser och brytpunkter 2020–2026, tabell 2)

Source: Ember tax-rulepack dossier §5.11 (SE — Skatteverket); Skatteverket — Belopp och procent inkomstår 2026 (kommunal genomsnittssats 32,38%; skiktgräns 643 000; statlig 20%; ISK/KF schablonintäkt 3,55%); Skatteverket — Skiktgränser, brytpunkter, prisbasbelopp m.m. 2020–2026 (PDF; tabell 1 skiktgräns, tabell 2 jobbskatteavdrag, tabell 3–4 brytpunkt + grundavdrag); SCB — Kommunalskatterna 2026 (average 32,38%; range Österåker 28,93% – Dorotea 35,65%)

• CPF contributions not modelled (employment only; not applicable to pension income)
• selfEmployment: no regime module — self-employed social contributions / business-income surcharges for this jurisdiction are not modelled
• Singapore's territorial basis IS now modelled, with its exceptions disclosed. IRAS treats income earned in or derived from Singapore as chargeable, while overseas income received in Singapore by a resident individual is generally not taxable; this pack declares that as a territorial scope (owner ruling T-D1, 2026-08-07 — docs/decisions/2026-08-08-owner-rulings.md), so a Singapore resident's foreign-source income now carries no Singapore charge instead of the full resident scale it was previously given. That is a downward change to any existing Singapore figure with foreign-sourced income, made on the owner's explicit live-number sign-off. STILL NOT MODELLED, all in the under-tax direction: the three IRAS exceptions under which overseas income received in Singapore IS taxable — receipt through a partnership in Singapore, income from an overseas trade or business incidental to a Singapore trade or business, and overseas employment incidental to Singapore employment. Each turns on facts Ember does not hold, so this pack assumes none of them applies; a resident in any of those positions is under-taxed here. Also not modelled: the receipt/remittance mechanics themselves — the model asks only whether income is foreign-sourced, never whether or when it was brought into Singapore.
• Foreign SOURCE withholding is not modelled, and business/salary source is the payer's REGISTRATION country. Two limits of the territorial modelling above, both in the UNDER-tax direction, both disclosed rather than modelled. (i) NO FOREIGN WITHHOLDING. Once this pack puts a resident's foreign-source income outside the Singapore charge, Ember books tax at source only where a treaty row or a model default routes a source leg. Distributions from a foreign-INCORPORATED company route DOMESTICALLY as dividends (the allocator takes its cross-border branch for business, salary, rental and pension only), so a Singapore resident's distribution from a US company shows zero tax here while the United States would in reality withhold 30% of the gross under its FDAP rules absent treaty relief — and the same holds for any source country that withholds on outbound distributions. Ember has no withholding axis for dividends, so this is a real under-statement, not a rounding. (ii) SOURCE IS WHERE THE PAYER IS REGISTERED, NOT WHERE THE WORK IS DONE. For business and salary items Ember reads sourceISO from the entity's registration country. IRAS asks a different question — income 'earned in or derived from Singapore' is chargeable — so services physically performed in Singapore are SINGAPORE-source however the payer is registered, and Singapore-source income is outside the foreign-source exemption entirely. A resident consultant working in Singapore for a foreign-registered client is therefore exempted here where IRAS would charge; this compounds the unmodelled 'incidental to a Singapore trade or employment' exceptions in the entry above. Modelling it would need a place-of-performance input Ember does not collect.
• Interest has no engine income category, so Singapore's interest exemptions are not modelled: IRAS treats interest from deposits with approved banks in Singapore, from finance companies licensed in Singapore, from debt securities (unless partnership-owned or trading inventory) and from foreign sources (unless earned by a partnership) as not taxable for individuals. Interest entered under any taxable category rides this pack's resident scale.
• Singapore retirement-wrapper drawdown is not modelled: IRAS taxes only 50% of a Supplementary Retirement Scheme withdrawal made on or after the prescribed retirement age (100% for earlier withdrawals, which also attract a 5% penalty), and retirement benefits received from CPF or designated funds are not taxable. Any Singapore pension wrapper drawn in this model is taxed on 100% of the withdrawal.
• Personal reliefs are not modelled: IRAS grants personal income tax reliefs (including CPF Cash Top-up Relief and SRS Relief), subject to an overall personal income tax relief cap of SGD 80,000 per Year of Assessment in effect from YA 2018. Chargeable income here is gross of all reliefs, so the charge is overstated for anyone entitled to them.

Territorial scope modelled: Singapore taxes income earned in or derived from Singapore; overseas income received in Singapore by a resident individual is generally not taxable, so foreign-source income of a Singapore resident carries no Singapore charge here. Three IRAS exceptions are NOT modelled and would be taxable: overseas income received through a partnership in Singapore, income from an overseas trade or business incidental to a Singapore trade or business, and overseas employment incidental to Singapore employment. Modelled on the assumption that none of those applies (owner ruling T-D1, 2026-08-07). Authority: IRAS, 'What is taxable, what is not' (this pack's sourceRef SG-iras-taxable-2026): income earned in or derived from Singapore is chargeable, while overseas income received in Singapore by a resident individual is generally not taxable. Statutory section reference not yet verified in this repo — due at the next review (see quality.nextReviewDue). Provenance next reviewed 2027-01-01.

Source: IRAS — Individual Income Tax rates (Resident tax rates, From YA 2024 onwards; Non-resident tax rates; Personal Income Tax Rebate YA2024/YA2025); IRAS — What is taxable, what is not (territorial basis: overseas income received in Singapore generally not taxable); IRAS — Dividends (one-tier, foreign and REIT distributions not taxable for individuals); IRAS — Interest (non-taxable interest for individuals); IRAS — Tax on SRS withdrawals (50% concession on or after the prescribed retirement age; 100% before); IRAS — Tax reliefs (SGD 80,000 overall personal income tax relief cap, from YA 2018); Ember tax-rulepack dossier §5.19 (SG — IRAS)

• 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. The territorial half IS now modelled (owner rulings T-D1/T-D2, 2026-08-07 — docs/decisions/2026-08-08-owner-rulings.md): foreign-source income of a Thai resident is treated as outside the Thai charge, so it no longer rides the resident scale. Because remittance itself is NOT an input, what that encodes is an ASSUMED NON-REMITTING RESIDENT — right for the non-remitting retiree the old wording named, and an UNDER-TAX by the whole Thai charge for a resident who does remit. Thai-source income is unaffected. This is a downward change to any existing Thai figure with foreign-sourced income, made on the owner's explicit live-number sign-off, and it is why this pack carries the defaulted-scope-inputs badge. The Revenue Department instrument behind the 2024 change has not been read in this repo — the scope's sourceRef is secondary and a primary citation is due at the next review. CORRECTED 2026-08-08 (GB→TH row research+fix, ruled 2026-08-08): a UK private or State pension of a Thai resident is UK-TAXED under this model, not taxed nowhere. The 1981 UK–Thailand Convention (SI 1981/1546, as modified by the MLI) has NO pensions article and NO other-income catch-all — verbatim-verified on the GOV.UK in-force and MLI-synthesised texts, where 'pension' appears in the Convention body only inside Art. 19 — so nothing displaces the UK domestic charge (ITEPA 2003 s. 579A registered-scheme pensions, s. 577 UK social security pensions) and Thailand gives an ordinary credit under Art. 23(3). The GB→TH pension row was corrected the same day from 'residence_only' to 'credit'. This scope then removes the (nil) Thai leg, so the item is source-taxed in the UK: the earlier double-non-taxation is closed from the UK SIDE, by the row itself rather than by a Malaysia-style treaty-withdrawal flag — no UK–Thailand limitation-of-relief article is engaged, so `withdrawsTreatyReliefWhenExempt` stays unset here.
• Foreign SOURCE withholding is not modelled, and business/salary source is the payer's REGISTRATION country. Two limits of the territorial modelling above, both in the UNDER-tax direction, both disclosed rather than modelled. (i) NO FOREIGN WITHHOLDING. Once this pack puts a resident's foreign-source income outside the Thai charge, Ember books tax at source only where a treaty row or a model default routes a source leg. Distributions from a foreign-INCORPORATED company route DOMESTICALLY as dividends (the allocator takes its cross-border branch for business, salary, rental and pension only), so a Thai resident's distribution from a US company shows zero tax here while the United States would in reality withhold 30% of the gross under its FDAP rules absent treaty relief — and the same holds for any source country that withholds on outbound distributions. Ember has no withholding axis for dividends, so this is a real under-statement, not a rounding. (ii) SOURCE IS WHERE THE PAYER IS REGISTERED, NOT WHERE THE WORK IS DONE. For business and salary items Ember reads sourceISO from the entity's registration country. Thai domestic law sources employment and business income by where the duties are performed or the business is carried on rather than by where the payer is registered, and such income is Thai-source and taxable whether or not it is brought into Thailand — so a resident consultant working in Thailand for a foreign-registered client is exempted here where the Revenue Code charges. The Revenue Code section has NOT been read in this repo (the same limitation as the scope's own SECONDARY sourceRef), and modelling it would need a place-of-performance input Ember does not collect.
• 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
• Long-Term Resident (LTR) visa regimes are not modelled — the Board of Investment's LTR programme grants holders (including the Wealthy Pensioner and Wealthy Global Citizen categories) an exemption from Thai personal income tax on overseas income, and highly-skilled professionals a 17% flat rate; visa status is not an input to this pack, so the ordinary resident scale is applied to every Thailand year

Territorial scope modelled: Thailand taxes a resident's foreign-source income only where it is brought into Thailand in the year. Remittance is not an input to this model (owner ruling T-D2, 2026-08-07), so foreign-source income is modelled as OUTSIDE the Thai charge — i.e. an assumed non-remitting resident. A resident who does remit foreign income is under-taxed here by the whole Thai charge on the remitted amount; Thai-source income is unaffected. The Long-Term Resident visa exemptions and the 2025 easing proposals remain unmodelled separately. Authority: Ember TH pack research (this pack's sourceRef TH-dossier-2026, dossier §5.22) and this pack's own knownUnsupportedRules entry: Thai tax on foreign-source income turns on remittance — foreign pension/investment income is taxed ONLY if remitted to Thailand in the year (2024 rule change + 2025 easing proposals). SECONDARY: the Revenue Department instrument has not been read in this repo — due at the next review (see quality.nextReviewDue). Provenance next reviewed 2027-01-01.

Source: Ember tax-rulepack dossier §5.22 (TH); Queue-B verification record (TH: 50%/100k expense + 60k allowance + 65+ 190k exemption — primary-sourced, recheck 5/5); Revenue Department of Thailand — personal income tax rate table, tax year 2560 onwards; Revenue Department of Thailand — allowances and exemptions (taxpayer THB 60,000; age 65+ exemption up to THB 190,000); Revenue Department of Thailand, Legal Affairs Division — Guide to Personal Income Tax Return (ภ.ง.ด.91): A item 4 expense = 50% of item 3 or 100,000 baht whichever is lower

• 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)
• employee and employer FICA on W-2 wages is not modelled; self-employment social contributions on sole-trader business income are modelled (OASDI 12.4% up to the wage base, Medicare 2.9%, Additional Medicare 0.9%), with the Additional Medicare threshold applied at $200,000 for every filing status while IRC 1401(b)(2) sets $250,000 for a joint return and $125,000 for married filing separately, so joint filers' self-employment contributions are over-stated in that band
• 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
• 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; IRS Publication 15 (2026), Employer's Tax Guide — What's New: social security wage base limit $184,500

• 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) applying from the WHOLE 2026 tax period under Điều 29.2 (not from 1 July, which is the Điều 29.1 date for the non-employment provisions) — wired 2026-07-15
• 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); Điều 4.1 additionally exempts transfers of real estate between spouses, natural/adoptive parents and children, parents-in-law and children-in-law, both sets of grandparents and grandchildren, and full siblings, and Điều 4.2 exempts the transfer of an individual's sole house / residential land in Vietnam — neither exemption is modelled, so for a seller within either exemption the CGT/sale path charges where the statute charges nothing, 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
• pension income exemption NOT modelled — Law 109/2025/QH15 Điều 4.9 exempts 'tiền lương hưu do Quỹ bảo hiểm xã hội chi trả; thu nhập do quỹ bảo hiểm hưu trí bổ sung, quỹ hưu trí tự nguyện chi trả' (the prior law's 'hàng tháng' qualifier is absent, so lump sums from those funds read as exempt too). Neither Điều 4 (22 khoản) nor Điều 5 contains an exemption for a pension paid by a FOREIGN entity to a VN tax resident; the previous basis for that treatment was Circular 111/2013/TT-BTC art. 3(k), which implements Luật 04/2007/QH12 — repealed by Điều 29.3 — and the Điều 4.22 implementing decree has not yet published. This pack routes ALL pension drawdown through the progressive 5–35% schedule, so a VN-resident drawing a Vietnamese Social-Insurance or supplementary/voluntary fund pension is over-taxed by this pack; the treatment of a foreign-paid pension is unresolved on the face of the Law and is to be re-checked when the decree publishes.
• selfEmployment: no regime module — self-employed social contributions / business-income surcharges for this jurisdiction are not modelled
• open-ended fund certificates: Law 109/2025/QH15 Điều 5.4 exempts from PIT the transfer of chứng chỉ quỹ mở established under the securities law and held 02 years or more from the date of purchase, with no time limit on the exemption. schedularInvestment applies the Điều 13.2 flat 0.1% of gross transfer price to every drawdown item, and the engine carries no instrument-type or holding-period input, so a holder of qualifying long-held open-ended fund units is charged 0.1% of proceeds where the statute charges nothing. Điều 5.5's 50% PIT reduction on lợi tức distributed to individual investors by securities and real-estate investment funds is also unmodelled and applies only 'trong thời hạn do Chính phủ quy định', which the implementing decree has not yet fixed.
• residential rental regime NOT modelled: Law 109/2025/QH15 Điều 7.1 charges no personal income tax on annual business revenue of VND 500 million or less, and Điều 7.4 taxes an individual letting real estate (other than a lưu trú/accommodation business) at 5% of the revenue exceeding that threshold, expressly outside the Điều 7.2 net-profit method and outside the Điều 10 giảm trừ gia cảnh. This pack has no VN rental primitive, so rental income is pooled into the progressive 5–35% schedule and draws on the VND 186m personal deduction: rent below VND 500m/yr is charged here where the statute charges nothing, and rent above it is charged on a pooled progressive basis rather than 5% of the excess revenue. The existing residentRentalFlat module carries no revenue threshold, so encoding this regime requires a threshold primitive.
• Điều 11 deductions NOT modelled: charitable, humanitarian and study-promotion contributions (Điều 11.1) and the taxpayer's and dependants' medical and education-training spending (Điều 11.2) are deducted from tiền lương, tiền công before the progressive scale, as are compulsory professional-liability insurance premiums and supplementary/voluntary pension and life-insurance contributions (Điều 8.2). Only the Điều 10.1(a) personal deduction is encoded here, so a taxpayer claiming any of these is over-taxed by this pack. The Điều 11.2 and Điều 8.2 ceilings are set 'theo mức do Chính phủ quy định' and the implementing decree has not yet published, so no figure can be encoded.

Source: Luật Thuế thu nhập cá nhân số 109/2025/QH15 (Quốc hội khoá XV, kỳ họp thứ 10, thông qua 10/12/2025) — Công báo số 37, 22/01/2026; Luật số 109/2025/QH15 — official signed PDF, Công báo CDN; Ember tax-rulepack dossier (VN — Ember tax-rulepack dossier 2026-06-22 §5.24 (VN — PwC WWTS Vietnam, rev. 2026-03)

• Primary rebate modelled as an effective 0% tax-free band (R99,000 = R17,820 / 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: SARS — Rates of tax for individuals (2027 year of assessment: rate table, tax rebates, tax thresholds); Ember tax-rulepack dossier §5.28 (ZA — PwC WWTS South Africa, 2026/27, rev. 2026)

• 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 section 4(1)(g) is conservatively NOT exempted (over-tax direction); statutory section-16 rounding (tax base down to the whole hundred CZK, tax up to the whole CZK) is not modelled, worth up to about CZK 15 of over-tax per filer per year in the 15% band and about CZK 23 in the 23% band
• Dividends: modelled as a flat 15% separate charge — the §36 odst. 2 zvláštní sazba daně (final withholding on Czech-source dividends, §8 odst. 3) and the §8 odst. 8 / §16a samostatný základ daně (foreign dividends). Neither is on the progressive §16 15/23 scale. Not modelled: for FOREIGN dividends the §16a separate base is an ELECTION — §8 odst. 4 makes the general §16 base the default, and that default is cheaper whenever the sleva na poplatníka would otherwise go unused, so a filer with little or no other §16 income is over-taxed here by up to the sleva, CZK 30,840/yr. The §16a odst. 2 round-down of the separate base to whole hundreds of CZK is not modelled either. Foreign withholding tax and treaty credit relief on the separate base are not modelled.
• social insurance contributions not modelled
• selfEmployment: no regime module — self-employed social contributions / business-income surcharges for this jurisdiction are not modelled
• personal reliefs beyond the sleva na poplatnika are not modelled: the section 35ba spouse credit (CZK 24,840, spouse-income limit CZK 68,000) and the disability / ZTP-P credits, the section 35c child credits (CZK 15,204 / 22,320 / 27,840 for a first / second / third child) and the refundable child tax bonus, and the section 15 nezdanitelne casti zakladu dane (tax-supported retirement-product contributions, mortgage interest, donations). A filer entitled to any of these is over-taxed by this pack; the engine has no household, dependants or contributions input to apply them from.

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; Financni sprava - 2026 employment-income Q&A (sleva na poplatnika CZK 30,840; section 6(9)(g) non-cash benefit cap CZK 24,483.50 = half the 2026 average wage of CZK 48,967, so the 36x band seam is CZK 1,762,812); Generalni financni reditelstvi - danove novinky pro rok 2026 (15% to 36x prumerne mzdy, 23% above); Financni sprava - PIT Q&A quoting section 4(1)(g) verbatim: regularly paid pension exempt up to 36x the minimum wage; MPSV - minimum wage CZK 22,400/mo from 1 January 2026 (36x = the CZK 806,400 pension-exemption ceiling); PRIMARY - Zakon c. 586/1992 Sb. (ZDP) §36 odst. 2, Zvlastni sazba dane. CONFIRMED VERBATIM 2026-08-07: "Zvláštní sazba daně z příjmů pro poplatníky uvedené v § 2 a 17, pokud není v odstavci 1 nebo 5 stanoveno jinak, činí 15 %, a to a) z podílu na zisku z účasti na obchodní společnosti nebo v podílovém fondu, je-li podíl v nich představován cenným papírem, a z plnění ze zisku svěřenského fondu nebo rodinné fundace; ... b) z podílu na zisku z účasti na společnosti s ručením omezeným, z účasti komanditisty na komanditní společnosti, c) z podílu na zisku a obdobného plnění z členství v družstvu, d) z podílu na zisku tichého společníka nebo jiného poplatníka, než je člen obchodní korporace," - the flat 15% final charge on Czech-source dividends; PRIMARY - Zakon c. 586/1992 Sb. (ZDP) §8 odst. 3, 4 a 8, Prijmy z kapitaloveho majetku. CONFIRMED VERBATIM 2026-08-07. §8 odst. 3: "Příjmy uvedené v odstavci 1 písm. a) až f) a i) ... plynoucí ze zdrojů na území České republiky, jsou samostatným základem daně pro zdanění zvláštní sazbou daně (§ 36)." §8 odst. 4 DISCONFIRMS the pack's previous citation - it puts FOREIGN dividends in the GENERAL base, not a separate one: "Plynou-li příjmy uvedené v odstavci 1 písm. a) až d) a i) ze zdrojů v zahraničí, jsou nesnížené o výdaje základem daně (dílčím základem daně)." The separate-base route for foreign dividends is §8 odst. 8, and it is ELECTIVE and all-or-nothing: "Příjem podle odstavce 4 ... plynoucí ze zdrojů v zahraničí lze zahrnout do samostatného základu daně zdaňovaného sazbou daně podle § 16a. Zahrne-li se takový příjem do tohoto základu daně, zahrnou se do tohoto základu daně veškeré příjmy podle věty první."; PRIMARY - Zakon c. 586/1992 Sb. (ZDP) §16a, Sazba a vypocet dane pro samostatny zaklad dane. CONFIRMED VERBATIM 2026-08-07: "(1) Sazba daně pro samostatný základ daně činí 15 %. (2) Daň se vypočte jako součin samostatného základu daně zaokrouhleného na celá sta Kč dolů a sazby daně pro tento základ daně." NOTE the §16a odst. 2 round-down of the separate base to whole hundreds of CZK is NOT modelled (up to about CZK 15/yr of over-tax, same class as the unmodelled §16 rounding already disclosed); CORROBORATION - PwC WWTS Czech Republic, Individual - Taxes on personal income: income already taxed by the final Czech WHT at source is excluded from the progressive rates; foreign investment income may go in a separate flat 15% base or, at the filer's option, the general progressive base (corroborates the flat-15% dividendTax module and the unmodelled general-base default; the statutory sections are CZ-zdp-* above); CORROBORATION - PwC WWTS Czech Republic, Corporate - Withholding taxes: 15% final WHT on dividends (section 36 zvlastni sazba dane); CORROBORATION - NeoTax - Dividendy ze zahranici: vysvetleni 15% a 23% dane (samostatny zaklad dane at the section 16a 15% rate, Priloha c. 4, reintroduced 2021, elective). This source labels the route "section 8(4)"; the statute itself puts the election in §8(8) - see CZ-zdp-8-3-4-8

• 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
• age-related reliefs not modelled: the Altersentlastungsbetrag (§24a EStG — a cohort-fixed percentage of Arbeitslohn plus the positive sum of non-employment income, up to an annual cap; the 2026 cohort row is 12.8% capped at €608, and Versorgungsbezüge and §22 Leibrenten are outside its base) and the Versorgungsfreibetrag with its Zuschlag (§19 Abs. 2 EStG — for a Versorgungsbeginn in 2026, 12.8% of Versorgungsbezüge capped at €960 plus a €288 Zuschlag), each fixed for life by the taxpayer's cohort year. Modelled German tax is therefore over-stated for an affected user by up to the marginal rate on €608 and on €1,248 respectively
• 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); SolzG 1995 §3 Abs. 3 (Freigrenzen €40,700 in Fällen des §32a Abs. 5 und 6 EStG / €20,350 in den anderen Fällen) and §4 (5.5% Zuschlagsatz; Milderungszone capped at 11.9% des Unterschiedsbetrages); §32d EStG (Abgeltungsteuer — Abs. 1 Satz 1 '25 Prozent', 26.375% incl. 5.5% Soli; Abs. 6 Günstigerprüfung); §20 Abs. 9 EStG (Sparer-Pauschbetrag €1,000 single / €2,000 gemeinsam); §24a EStG (Altersentlastungsbetrag cohort table — 2026 row 12.8% / €608); §19 Abs. 2 EStG (Versorgungsfreibetrag cohort table — Versorgungsbeginn 2026: 12.8%, Höchstbetrag €960, Zuschlag €288); §51a EStG (Kirchensteuer as a Zuschlagsteuer on the income-tax base; the section sets NO rate — 8–9% is Landesrecht, hence deliberately stated as a range)

• 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 / 18.6% on most investment income from 1 Jan 2026 — CSG on capital rose 9.2% → 10.6%; the previous 17.2% total is retained for revenus fonciers, real-estate capital gains, assurance-vie and PEL/CEL/PEP) not modelled
• CEHR high-income surtax (3–4% over €250k single / €500k couple) not modelled
• CDHR (contribution différentielle sur les hauts revenus, BOI-IR-CDHR) not modelled — where impôt sur le revenu + CEHR come to less than 20% of the revenu fiscal de référence, a differential top-up brings the effective rate to 20% for RFR above €250,000 (célibataire/veuf/séparé/divorcé) or €500,000 (imposition commune). Loi de finances pour 2026 extended it from 2025 income until the income year in which the general-budget deficit falls below 3% of GDP, so it is no longer a one-off measure; a large single-year crystallisation modelled in FR is therefore under-taxed. Computed on top of IR + CEHR, so it must be sequenced after any future CEHR implementation
• décote (CGI Art. 197-I-4) not modelled — over-states tax for modest incomes; the couple/imposition-commune décote (base €1,483, = €1,483 − 45.25% × impôt brut, applies while impôt brut ≲€3,277) is ~1.65× the single décote (€897 / ≲€1,982), so a modest-income spouse household's FR tax can be over-stated by up to ~€1,483/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
• abattement spécial personnes âgées ou invalides (CGI Art. 157 bis) not modelled — €2,822 off revenu net global where RNG is below €17,670, €1,411 where RNG is between €17,670 and €28,430, doubled (max €5,644) where both members of the foyer qualify; 2026 figures for 65+ or invalid at 31 December 2025, non-cumulable with the other special abatement. Direction is conservative (over-statement), and it stacks with the two other unmodelled reliefs disclosed here — the 10% pension abattement and the décote — so a modest over-65 French retiree's FR tax can be over-stated by the sum of all three
• 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 F415). 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 on financial income is a separate schedule, not modelled — 31.4% from 1 Jan 2026 (12.8% impôt sur le revenu + 18.6% prélèvements sociaux); the effective rate remains 30% for instruments whose social charges stay at 17.2% (assurance-vie, PEL/CEL/PEP)
• 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); service-public.gouv.fr A18045 — Impôt sur le revenu : barème 2026 (LOI n° 2026-103 du 19 février 2026 de finances pour 2026, indexation +0,9 %); service-public.gouv.fr F1419 — Barème progressif de l'impôt sur le revenu 2026; service-public.gouv.fr F34328 — décote, plafonnement du quotient familial, abattement personnes âgées/invalides; service-public.gouv.fr F2329 — prélèvements sociaux sur les revenus du capital (18,6 % / 17,2 % à compter de 2026); BOFiP BOI-IR-CDHR — contribution différentielle sur les hauts revenus

• 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 base (所得税法第86条 as amended for 令和8年分以後) — the 租税特別措置法第41条の16の2 additions are not applied: +¥420,000 below ¥4.89M total income and +¥50,000 from ¥4.89M to ¥6.55M for 2026–2027 (over-states tax by up to ≈¥128k/yr at the top of the ¥4.89M tier), and from 令和10年分 (2028) the PERMANENT +¥370,000 for total income ≤¥1,320,000, which makes the deduction ¥990,000 there — so the over-statement below ¥1.32M (≈¥56k/yr) does not end with the temporary tiers; the high-income taper (¥480k→¥320k→¥160k→0 above ¥23.5M total income) is also 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)
• from 令和9年分 (2027) a combined cap applies where a person has both 給与等 and 公的年金等 revenue: any excess of (給与所得控除額 + 公的年金等控除額) over ¥2,800,000 is deducted from the 公的年金等控除額 (令和8年度税制改正) — not modelled; this pack applies no 給与所得控除, so the two deductions never co-exist here and the cap can never bind, but any future 給与所得控除 must carry it or the pension deduction will be over-stated
• employment-income deduction (給与所得控除) not modelled at all — retiree-focused pack, so salaried users are over-taxed by the whole deduction; its minimum is ¥740,000 for 2026–2027 (permanent ¥690,000 floor plus the 令和8・9年 +¥50,000 特例) and ¥690,000 from 令和10年分 (2028), CPI-indexed thereafter
• 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
• the high-income minimum-tax measure (極めて高い水準の所得に対する負担の適正化措置, 措法41条の19) is not modelled — from 令和9年分 (2027) it applies to individuals whose 基準所得金額 exceeds ¥165,000,000 (previously ¥330,000,000) at a 30% rate (previously 22.5%), so the flat 20.315% modelled on listed-securities dividends and gains is not the all-in rate for a taxpayer above that threshold (under-states tax there)
• 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

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% surtax multiplicative on 基準所得税額; from 令和9年分 re-split into 復興 1.1% (period extended to 令和29年/2047) + 防衛特別所得税 1.0% for 令和9年以後の当分の間 — combined 2.1% unchanged); NTA 令和8年4月 源泉所得税の改正のあらまし (post-enactment: 基礎控除 62万+加算, 給与所得控除 最低保障額 74万/69万, 防衛特別所得税 1% + 復興 1.1% = 合計2.1%); NTA 令和8年度税制改正（所得税の基礎控除の引上げ等関係）Q&A, 令和8年5月 — 所得税法第86条 基礎控除 62万円 (改正前58万円), 措法41条の16の2 加算額; 施行 令和8年12月1日, 令和8年分以後; MOF 令和8年度税制改正の大綱 (閣議決定 2025-12-26) — 一1 基礎控除/給与所得控除/特例, 六 防衛特別所得税・復興特別所得税; enacted as 所得税法等の一部を改正する法律, 成立・公布 2026-03-31; 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)

• cuota fija (the per-row fixed quota in SAT's tarifa) is not stored — the engine walks the same 11 rows as marginal slices. Each row's statutory cuota fija equals the cumulative marginal tax at that row's lower limit, so both produce the same annual ISR to within MXN 0.05 on incomes up to MXN 12,000,000 (reconciled against Anexo 8 RMF 2026, section C.II, DOF 28-dic-2025).
• IMSS/ISSSTE social security not modelled
• the 11 annual bands are the statutory 2026 tarifa (Anexo 8 RMF 2026, section C.II, arts. 97 y 152 LISR, DOF 28-dic-2025), not illustrative figures. SAT republishes the tarifa in Anexo 8 of each year's RMF; the 2026 values are the 2025 values re-expressed by a factor of 1.1321, so the table does not necessarily change every year — check the current year's Anexo 8 at review time.
• 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 are not modelled, and the Régimen Simplificado de Confianza for personas físicas (LISR art. 113-E, optional where the prior year's own activity income did not exceed MXN 3,500,000) is not offered — MX business and professional income is taxed on the art. 152 tarifa only.
• subsidio para el empleo (Decreto DOF 31-dic-2025, in force 1-ene-2026) is not modelled: employment income up to MXN 11,492.66 per month attracts a monthly amount of 15.02% of the monthly UMA (15.59% for January 2026), creditable against ISR. Ember taxes MX employment income without it, so ISR for a low-earning MX employee is stated higher than the decree produces.

Source: SAT — Anexo 8 de la RMF 2026, C.II tarifa anual 2026 (arts. 97 y 152 LISR), DOF 28-dic-2025; INEGI — Comunicado de prensa 1/26, valores de la UMA 2026 (diario 117.31 / mensual 3,566.22 / anual 42,794.64, vigentes desde 1-feb-2026); SAT — LISR Artículo 93 fracciones IV y V (exención de jubilaciones, pensiones y haberes de retiro); DOF/SIDOF — Decreto que modifica el diverso que otorga el subsidio para el empleo (vigor 1-ene-2026); Ember tax-rulepack dossier §5.17 (MX — SAT Art. 152)

• 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
• AOW-age bracket 1 uses the €38,883 ceiling the Belastingdienst publishes for filers born on or after 1 January 1946; a second 2026 AOW-age table with a €41,123 bracket-1 ceiling applies to filers born before 1 January 1946, which the module's single cohort-less band set cannot express — that cohort is charged 37.56% instead of 17.85% on the €2,240 slice (~€441/yr over-tax)
• in the calendar year a filer REACHES AOW age the Belastingdienst applies a month-dependent bracket-1 rate (17.85% when AOW age is reached in January, rising to 34.26% in December); the pack carries only the full-year 17.85% rate and the engine keys off a whole-year age, so the AOW-crossing year is UNDER-taxed by up to ~€6,381 (€38,883 × 16.41pp) — the opposite direction to this pack's other simplifications
• alleenstaandeouderenkorting (2026: €540, flat, no income taper, for AOW-age filers entitled to a single-person AOW) is not modelled — single AOW-age residents are over-taxed by €540/yr at every income level; the credit primitive requires a taper rate in (0,1) and the module carries no single/partnered entitlement flag, so applying it unconditionally would under-tax partnered retirees by the same amount

Source: Ember tax-rulepack dossier §5.9 (NL — PwC WWTS); Belastingdienst — Box 1: tarieven 2026 (three tables incl. born-before-1946 and the AOW-crossing-year rates); Belastingdienst — Voorlopige aanslag 2026: tarieven en heffingskortingen; Belastingdienst — Tabel algemene heffingskorting 2026 (AOW-age variant €1.556 / 3,195%); Belastingdienst — Premies volksverzekeringen 2026 (AOW 17,90% / Anw 0,10% / Wlz 9,65%); Belastingdienst — Berekening box 3-inkomen 2026 (forfaits, heffingsvrij vermogen, schuldendrempel); Rijksoverheid — AOW-leeftijd (67 in 2026-2027; 67 jaar en 3 maanden from 2028)

• ACC earners' levy is not modelled: 1.67% of liable earnings up to NZ$152,790 (maximum NZ$2,551.59) for 1 April 2025 to 31 March 2026, and 1.75% up to NZ$156,641 (maximum NZ$2,741.22) for 1 April 2026 to 31 March 2027. It is a compulsory deduction on top of income tax and applies only to earnings from work — not to NZ Superannuation, other pensions, or investment income — so modelled tax is understated by up to about NZ$2,741 a year while earning, and unaffected once those earnings stop.
• Independent Earner Tax Credit (IETC, up to $520/yr for earners between $24,000 and $70,000 without certain benefits) — a credit, not modelled
• 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: Inland Revenue (NZ) — Tax rates for individuals, table 'From 1 April 2025'; Ember tax-rulepack dossier §5.27 (NZ) — corroborating secondary: PwC WWTS New Zealand, taxes on personal income

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

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

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

Source: UK–Malaysia DTA 1996 (SI 1997/2987) Art. 19(1): 'pensions and other similar remuneration paid in consideration of past employment to a resident of a contracting state and any annuity paid to such a resident shall be taxable only in that State'; relief limited by Art. 25(1); Malaysian credit at Art. 24(2).

Source: UK–Singapore DTC 1997 Art 10

Source: UK–US DTC 2001

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

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

Source: UK–Malaysia DTA 1996 (SI 1997/2987) Art. 19(1).

• No CGT for individuals on financial assets.

• 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.

• 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.

• NEW 10% CGT on financial assets from 1 Jan 2026 (in force; €10k annual exemption).

• 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.

• 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).

• No CGT for private investors on moveable assets.

• 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.

• '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.

• Gains on the 15/23 scale; securities exempt if held >3yrs (time test). Two-slot approximation.

• 25% Abgeltungsteuer + solidarity surcharge ≈ 26.4% effective. €1,000 annual exemption.

• 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.

• 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.

• 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.

• Listed shares 10% flat; real estate/unlisted 25–35%. Two-slot approximation.

• 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.

• Flat 19% 'Belka' on capital gains/dividends/interest; no allowance.

• 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.

• LTCG 0/15/20% + 3.8% NIIT; short-term = ordinary. Plus state CGT.

• 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.

• No capital gains tax under current UAE rules.

• 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).

• 18% basic / 24% higher. £3,000 annual exempt amount (2026-27).

• 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.

• 26% flat on financial gains; some govt bonds 12.5%. Real estate exempt if >5yrs / main home.

• 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. AT DEATH there is NO basis step-up: 所法60①一 carries the decedent's acquisition cost AND acquisition date to the heir, so a later sale is taxed on the whole latent gain and the ≤5yr/>5yr real-estate test runs from the DECEASED's purchase; 措法39 adds part of the inheritance tax charged on the asset to its cost where it is sold within about 3 years 10 months of death, capped at the gain. Neither is modelled — Japan charges inheritance tax at death (see the JP estate pack) and the latent gain again on sale. entryStepUp:false above is the separate question of rebasing on BECOMING resident.

• No CGT on financial assets for INDIVIDUALS: an individual is not a chargeable person under the capital-gains regime introduced from 1 Jan 2024 (LHDN Director General's CGT guideline, 21 Jul 2025) — it reaches companies, LLPs, trusts and co-operatives only, so gains on shares, funds and ETFs are untaxed however large. REAL PROPERTY IS DIFFERENT: Real Property Gains Tax (RPGTA 1976 Schedule 5) applies to Malaysian real property and shares in real-property companies, and a NON-CITIZEN NON-PERMANENT-RESIDENT disposer sits in Part III — 30% for a disposal within the first five years and 10% from the sixth year onwards (a Malaysian citizen/PR in Part I instead pays 30/30/20/15% in years 1-5 and 0% from year six). The 6th-year-and-after Part III rate is 10%, NOT the 5% carried by the pre-2019 column. RPGT is not modelled by this row — Ember models property disposals through the property/estate path.

• 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%.

• 30% flat on capital income. ISK accounts have a separate flat-yield regime (not modelled).

• No CGT; territorial (foreign income untaxed unless received via SG partnership).

• 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). AT DEATH s9HA deems a disposal of every asset at market value on the date of death, with the annual exclusion raised to R440,000 in the year of death — so a ZA death triggers CGT BEFORE estate duty (the CGT is itself deductible in arriving at the net estate under s4(b)), while assets accruing to a South African-resident surviving spouse roll over at base cost instead (s9HA(2)). The heir/estate acquires at that market value, so death DOES give a step-up. Not modelled — see the matching gap in the ZA estate pack.

• 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); a São Paulo user — the largest single state cohort — is over-taxed by this pack by up to a factor of two at the top of the scale
• the five identical relationship classes are a RIO-SPECIFIC, time-anchored fact, not a national one: RJ art. 26 carries no kinship term, but Brazilian states have — Santa Catarina's Lei 13.136/2004 art. 9, V charged a flat 8% wherever the heir was a parente colateral or had no kinship with the de cujus, a provision the TJSC Órgão Especial held unconstitutional in November 2020 (differentiating by absence of kinship offends capacidade contributiva) and Lei SC 19.053/2024 revoked with effect from 01/01/2025; if any state's post-LC-227/2026 progressive schedule reintroduces a relationship axis, every class entry here is wrong for that state and not merely mis-rated
• 2026 per-state band tables are a moving target post-EC 132/2023 (LC 227/2026 made progressivity obligatory from 13 Jan 2026 but left rate-setting to state law, and most states' progressive schedules are still in their legislatures) — re-verify per-state tables at wiring time
• RJ art. 26 caput applies the rate 'considerando-se a totalidade dos bens e direitos transmitidos' (one rate on the whole base), while LC 227/2026 art. 156 §2º mandates a marginal band walk from 13 Jan 2026 and RJ has not yet amended its law; this pack encodes the marginal reading (the only one the engine expresses, and the one national law now commands), which is ~24% lower than the literal state-law cliff on a mid-band share (equivalently, the cliff is ~31% higher) — R$45,862.86 against R$60,000 on a R$1,000,000 quinhão
• band thresholds are UFIR-RJ-indexed (70,000 / 100,000 / 200,000 / 300,000 / 400,000 UFIR-RJ) and re-based every January by SEFAZ resolution — the BRL figures here are anchored to UFIR-RJ 2026 = R$4.9604 (Resolução SEFAZ-RJ nº 849/2025, secondary-sourced only: the SEFAZ portal is IP-locked) and must be re-anchored annually; every threshold shifts proportionally if that factor is wrong
• cross-border nexus is simplified to 'Brazil taxes worldwide': LC 227/2026 (in force 13 Jan 2026) allocates ITCMD by art. 158 for immovables (Brazilian-situs property to the situs State even where the de cujus was domiciled abroad; foreign-situs property to the de cujus's State if they were Brazil-domiciled, otherwise to the successor's State) and by art. 159 for movables, títulos, créditos and incorpóreos irrespective of where they sit (causa mortis: the de cujus's State if Brazil-domiciled, otherwise the successor's State; doação: the donor's State if Brazil-domiciled, otherwise the donee's State; both parties abroad: the State where the Brazilian assets are). This pack models only the case the engine can express — a user dying Brazil-domiciled, taxed on worldwide assets under art. 159 I(a) — and does not model a Brazil-resident heir of a foreign deceased, which is a distinct charge on the heir's State.
• 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
• Rio de Janeiro's cliff isenções are not modelled: Lei 7.174/2015 art. 8 exempts a transmissão causa mortis whose total monte-mor does not exceed 13,000 UFIR-RJ (R$64,485.20 at UFIR-RJ 2026) and causa mortis transfers of residential property to individuals whose summed value does not exceed 60,000 UFIR-RJ (R$297,624.00), with the monte-mor test computed excluding that property (art. 8 §1º). These are all-or-nothing thresholds rather than allowances, so they cannot be expressed as allowanceMinor; small Rio estates are over-taxed here. Also not modelled: art. 8 XII (the single-residence transmissão to herdeiros necessários, CC art. 1.845, of police/prison officers killed in service, Decreto RJ 49.952/2025) and XVI (the same cohorts under 'pensionista' status) — narrow, occupation-conditioned exemptions distinct from the value-based thresholds above.
• The surviving spouse's meação is not carved out: under the default comunhão parcial de bens only the deceased's half of the common estate is transmitted, and RJ Lei 7.174/2015 art. 8 III separately exempts the transfer to the spouse arising from the marital property regime. The engine's inheritance-model branch (estateTaxAtDeath) applies the bands to the whole in-scope household estate rather than the deceased's share, so a married Brazilian is over-taxed by more than a factor of two once progressivity is counted.
• private pension and insurance proceeds are wrongly inside the base: LC 227/2026 art. 150, III provides that ITCMD does not apply to benefits due under a contrato de previdência privada complementar (aberta ou fechada), de seguro or de pecúlio, even where the beneficiary is a third party, codifying STF Tema 1214 (RE 1.363.013, thesis published 08/01/2025) that ITCMD on VGBL and PGBL balances passing on the holder's death is unconstitutional — a ruling given against Rio de Janeiro, whose Lei 7.174/2015 art. 23 still places those balances in the base. This pack has no asset-class carve-out, so pension wrappers assembled into the estate are charged the 4-8% schedule they are exempt from.
• no basis step-up is modelled, and the federal charge that buys one is not levied: Lei 9.532/1997 art. 23 lets assets pass either at the deceased's declared cost or at market value, and where market value is elected the uplift is subject to imposto de renda at 15% (art. 23 §1º), payable by the inventariante with the declaração final de espólio (§2º, I, red. Lei 9.779/1999); the heir's acquisition cost is whatever value was used (§4º). This pack models only the state ITCMD, so a Brazilian estate that elects the uplift faces a federal capital-gains charge the engine never shows, and an estate that does not carries the deceased's original basis into the heir's hands.
• the per-heir basis is not modelled: ITCMD produces a separate fato gerador for each sucessor (LC 227/2026 art. 148 §2º) and the mandatory progressivity is by the value of each quinhão or legado (CF art. 155 §1º VI; Senate Resolution 9/1992 art. 2), so a Rio estate divided between several heirs is taxed on several smaller shares at lower marginal rates. The engine runs the whole estate through one child-class band walk, which over-taxes any multi-heir estate — a R$3m estate to three children is charged at a 6.4% effective rate here against 4.6% in law.

Source: RJ Lei nº 7.174/2015 art. 26 (redação da Lei nº 7.786/2017 — six-band ITD scale 4/4.5/5/6/7/8% on 70k/100k/200k/300k/400k UFIR-RJ) and art. 8 (isenções), ALERJ consolidated text; CF art. 155, I and §1º (VI added by EC 132/2023 — mandatory progressivity by quinhão), Planalto; LC 227/2026 arts. 146-164 (national ITCMD norms — art. 150 III previdência/seguro carve-out, art. 152 base, art. 156 progressividade and marginal method, arts. 158-159 sujeição ativa), Planalto; Senate Resolution nº 9/1992 art. 1 (8% ceiling); Lei 9.532/1997 art. 23 (succession basis and the 15% uplift charge); UFIR-RJ 2026 = R$4.9604 per Resolução SEFAZ-RJ nº 849/2025 de 23/12/2025 (effective 01/01/2026), confirmed by the owner on 2026-08-07 against legisweb.com.br/legislacao/?id=488617, whose reproduction of the resolution reads verbatim "para o exercício de 2026, será de R$ 4,9604", corroborated by normasbrasil (same text) — STILL SECONDARY-SOURCED: portal.fazenda.rj.gov.br is IP-locked to this network and to the owner's browser alike, so the Diário Oficial primary was never reached; CONFIRM AT NEXT REVIEW, and re-anchor every band if the factor differs. RELATIONSHIP-NEUTRALITY (C2, 2026-08-09), read verbatim: art. 26 as amended provides only "O imposto é calculado aplicando-se, sobre o valor fixado para a base de cálculo, considerando-se a totalidade dos bens e direitos transmitidos, a alíquota de: I - 4,0% ... para valores até 70.000 UFIR-RJ; ... VI - 8% (oito por cento) para valores acima de 400.000 UFIR-RJ" — value bands only, no kinship term (ALERJ consolidated text of Lei 7.174/2015 at alerjln1.alerj.rj.gov.br/CONTLEI.NSF, corroborated by legisweb's reproductions of Lei 7.174/2015 (id=314557) and of the amending Lei 7.786/2017 (id=352586)); art. 8's isenções key off value or person-type — VII "a transmissão causa mortis de bens e direitos integrantes de monte-mor cujo valor total não ultrapasse a quantia equivalente a 13.000 (treze mil) Unidades Fiscais de Referência do Estado do Rio de Janeiro (UFIRs-RJ)" and XI "a transmissão causa mortis de imóveis residenciais a pessoas físicas, desde que a soma do valor dos mesmos não ultrapasse o valor equivalente a 60.000 (sessenta mil) UFIRs-RJ" — the only inciso keyed to the spouse/companheiro relationship as such being III "a transmissão dos bens ao cônjuge, em virtude da comunicação decorrente do regime de bens do casamento, assim como ao companheiro, em decorrência de união estável" — XII (single-residence transmissão to herdeiros necessários, CC art. 1.845, of police/prison officers killed in service, Decreto RJ 49.952/2025) and XVI (the same cohorts under 'pensionista' status) additionally condition on herdeiro-necessário/pensionista status of that narrow occupational cohort and are not modelled; and LC 227/2026 art. 156 keys the now-mandatory progression to the value of the quinhão, legado or doação alone (SECONDARY-SOURCED THIS PASS — planalto.gov.br was unreachable from this network on 2026-08-09; re-read the primary at next review).

• 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 now have their own class: CHF 200,000 allowance (§21(1)(a) 'Fr. 200 000 für den Elternteil des Erblassers oder Schenkers') applied to the UNMULTIPLIED §22 base scale (§23(1)(a) 'Eltern — den einfachen Betrag'; marginal max 7%, effective cap 6%). This replaces the former collapse into 'other', which charged a bereaved Zurich parent CHF 140,400 on a CHF 500,000 inheritance against a statutory CHF 12,000 — an 11.7× over-tax. Scope is FIRST-DEGREE ONLY: grandparents and remoter ascendants are §23(1)(b) ×2 (CHF 15,000 allowance, §21(1)(b)) and step-parents are §23(1)(d) ×4, and all of them still fall in 'other' at ×6 — conservative over-tax, per the intermediate-relatives caveat below. The ×1 / CHF 200,000 treatment is Zurich's: other cantons differ (Solothurn, for one, exempts parents from the Erbanfallsteuer entirely)
• 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; roughly 8 per mille of the net estate (reiner Rücklass) up to ~CHF 500,000, rising progressively to ~12 per mille — i.e. 0.8-1.2%, small but unavoidable, and due even where every heir is exempt from the Erbanfallsteuer
• 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-children/registered partner's children/godchildren/foster children and 10-year domestic employees also CHF 15k (§21(1)(d)); CHF 30k for support-dependent persons unfit for work (§21(2)(b))), 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 (6% parent / 18% sibling / 36% other) after the 7%/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) does not reconcile as a SIBLING rate (statutory 13.5% on CHF 500k); 28.1% is within rounding of the ×6 unrelated-heir rate (28.08%), so the figure was most likely a mislabelled class — 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
• No basis step-up at death, and the CGT side is not modelled here: private capital gains on moveable assets are tax-free anyway (StHG Art. 7(4)(b), matching cgtByCountry CH noCgt), but Swiss REAL ESTATE carries a deferral, not an exemption — StHG Art. 12(3)(a) suspends the cantonal Grundstückgewinnsteuer on 'Eigentumswechsel durch Erbgang (Erbfolge, Erbteilung, Vermächtnis), Erbvorbezug oder Schenkung', so the heir inherits the deceased's Anlagekosten AND holding period and the whole latent gain is taxed on the heir's later sale by the canton where the property lies. An inheritance that is tax-free at death (descendants are exempt in ZH) can therefore carry a large embedded gains-tax charge.
• Class mapping trap: ESchG ZH §11 exempts all NACHKOMMEN — grandchildren and great-grandchildren as much as children, and §25 puts adopted descendants on the same footing — so the engine's 'child' class must be selected for any descendant of the deceased. Choosing 'other' for a grandchild applies the ×6 stranger scale to an inheritance the statute taxes at zero (CHF 500,000 from a Zurich grandparent: statutory CHF 0 vs CHF 140,400 modelled). Step-children are NOT descendants (×2, CHF 15,000 allowance under §§21(1)(d)/23(1)(b)) and correctly belong in 'other'.

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, §23(1) multipliers ×1 parent (lit. a) / ×3 sibling (lit. c) / ×6 unrelated (lit. f), §21(1) allowances CHF 200,000 parent (lit. a) and CHF 15,000 sibling (lit. b)); 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).

• 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 on the cuota is not representable in the flat-band model, so EVERY class here can be understated: the coefficient keys off the HEIR's own pre-existing wealth, which this model does not hold, and is 1.0000 for Groups I–II only up to €402,678.11 of heir wealth, rising to 1.0500 / 1.1000 / 1.2000 above €402,678.11 / €2,007,380.43 / €4,020,770.98 (so a spouse, an adult child or a PARENT — all Grupo II — can be understated by up to 20%). Group III runs 1.5882–1.9059 and Group IV 2.0000–2.4000, so sibling and unrelated-heir liability is understated by up to ~2.4x
• regional Group III collateral-relative reliefs not modelled: Comunitat Valenciana bonifica 25% of the Group III quota for deaths from 1 Jun 2026 and 50% from 1 Jun 2027 (Ley 5/2025 de la Generalitat, DOGV 31 May 2025, consanguine siblings/uncles/aunts/nephews/nieces only); Madrid bonifica 50% of the whole Group III from 1 Jul 2025 (Ley 2/2025 de la Comunidad de Madrid, 25 Jun 2025, up from 25%). CATALONIA HAS NO GROUP III BONIFICACIÓ — its bonificació de la quota reaches Grups I and II only, so a Catalan sibling pays the full quota after the €8,000 Catalan kinship reduction
• the `parent` class is FIRST-DEGREE ONLY while Spain's Grupo II is broader: Art. 20.2.a puts every 'ascendiente' (grandparents and remoter ascendants included) and every 'adoptante' in Grupo II with the same €15,956.87 reduction, but this engine class means the deceased's mother or father alone (first-degree semantics are forced by other packs — JP 相法18, IE CATCA Sch 2 — where a grandparent genuinely is treated worse). A Spanish grandparent-heir therefore routes to `other`, gets NO reduction instead of €15,956.87, and is OVER-taxed by roughly that reduction at their marginal rate (up to ~€5,425 at the 34% top bracket). Adoptive parents route correctly only if entered as `parent`. Separately, 'ascendientes por afinidad' — a parent-in-law — are Grupo III (€7,993.46, the sibling figure here) and likewise route to `other` with zero reduction, so they are over-taxed too
• 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)
• territorial scope not modelled: a Spain-resident heir is taxed on the WORLDWIDE acquisition (Art. 6, obligación personal) while a non-resident heir is taxed only on Spanish-situs assets, rights exercisable in Spain and Spanish-insurer life policies (Art. 7, obligación real). Nor is the non-resident's right to autonomous-community rules modelled: since art. 4.6 of Ley 11/2021 (in force 11 Jul 2021) struck the EU/EEA limitation from disposición adicional segunda, EVERY non-resident — third countries included — may apply the rules of the Comunidad Autónoma holding the greatest value of the Spanish estate. A UAE- or UK-resident heir of Madrid- or Valencia-situs assets is therefore entitled to that community's Group I–II bonificación (up to 99%) and this pack charges them the full state scale
• lifetime gifts are inside this same tax but outside this pack: ISD charges donations and other gratuitous inter-vivos transfers on the donee (Ley 29/1987 Arts. 3.1.b, 5.b, 9.1.b), and the Art. 20.2 kinship reductions encoded here apply ONLY to mortis-causa acquisitions — a gift is taxed on the Art. 21 scale from the first euro under state rules, before regional gift bonificaciones
• death-time CGT position not modelled here (it is a CGT-layer fact, but it is the one FIRE users ask about): Spain charges NO capital gain on death — LIRPF Art. 33.3.b treats 'transmisiones lucrativas por causa de muerte del contribuyente' as producing no ganancia or pérdida patrimonial — and LIRPF Art. 36 gives the heir a stepped-up acquisition value equal to the ISD value, capped at market value. A LIFETIME gift gets no such relief: the donor realises a taxable gain on the same valuation. Since Ley 11/2021 the step-up is clawed back where a beneficiary of a pacto sucesorio with present effect sells within five years of the pact or of the death, subrogating them into the deceased's basis
• plusvalía municipal (IIVTNU) not modelled: inheriting URBAN land triggers a separate municipal charge on the land's value increase, payable by the heir on top of ISD — TRLRHL (RDL 2/2004) Art. 104 taxes transfer of urban land 'por cualquier título', which includes succession (rural land is outside it). Rates, the objective-vs-real-gain calculation choice and any habitual-residence bonificación are set per ayuntamiento, so no figure can be encoded here; this pack shows zero for a cost that is real
• valuation basis not modelled: for devengos from 1 Jan 2022 the taxable value of REAL ESTATE is the Catastro's 'valor de referencia' (Ley 29/1987 Art. 9.3, as recast by Ley 11/2021), not the heir's or the market's valuation — other assets take market value, or the declared value if higher (Art. 9.2). Whatever property value this model is fed flows straight into the bands, so the base can diverge from the real liquidación in either direction
• foral territories are outside this pack entirely: ISD is a tributo concertado de normativa autónoma (Concierto Económico, Ley 12/2002 art. 25), so Araba, Bizkaia and Gipuzkoa each apply their OWN Norma Foral del ISD — own scale, own groups, own exemptions — and Navarra its own Ley Foral under the Convenio Económico. Competence generally follows the deceased's habitual residence at devengo (subject to a five-year seasoning rule) or, for immovables gifted, their situs. Neither the Art. 21 state scale nor the Art. 20.2 reductions encoded here apply in those four territories

Source: Ley 29/1987 (ISD), BOE consolidated text https://www.boe.es/buscar/act.php?id=BOE-A-1987-28141 — Art. 20.2.a–c (reductions; Grupo II quoted verbatim from the BOE consolidated text, re-checked 2026-08-09: «Grupo II: adquisiciones por descendientes y adoptados de veintiuno o más años, cónyuges, ascendientes y adoptantes, 15.956,87 euros» — ascendientes, i.e. parents, share the spouse/adult-child group; «Grupo III: adquisiciones por colaterales de segundo y tercer grado, ascendientes y descendientes por afinidad, 7.993,46 euros»; «Grupo IV: en las adquisiciones por colaterales de cuarto grado, grados más distantes y extraños, no habrá lugar a reducción»), Art. 21.2 (state scale, all 16 brackets verified row-by-row against BOE 2026-08-07), Art. 22 (multiplier coefficients), Arts. 6–7 (obligación personal/real), disposición adicional segunda as amended by art. 4.6 of Ley 11/2021 (non-residents' right to autonomous-community rules, EU/EEA limitation removed 11 Jul 2021). Regional exemplars: Agència Tributària de Catalunya (bonificació Grups I–II only); Generalitat Valenciana Hisenda / Ley 5/2025 (Grupo III 25% from 1 Jun 2026, 50% from 1 Jun 2027); Ley 2/2025 de la Comunidad de Madrid, BOE-A-2025-19345 (Grupo III 50% from 1 Jul 2025).

• 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. Since the per-heir splitting slice this reaches the OWN-ESTATE path too: declaring several 'other'-class beneficiaries of a Belgian estate now charges each on their own small share, at a lower point on the 25/45/55% scale than the group's combined acquisition would reach. Accepted and disclosed for v1 (owner ruling D7, 2026-08-08); the category-aware fix travels with the C7 Belgian engine wave
• 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%)
• ASCENDANT SCOPE narrower than the statute: Flanders' rechte lijn is the WHOLE opgaande lijn, so grandparents and great-grandparents take exactly the same TABEL I 3/9/27 scale as a parent, and VCF art. 2.7.4.1.1 §2 confirms the code also carries persons 'die voor de toepassing van het tarief met een rechtverkrijgende in de rechte lijn wordt gelijkgesteld' (the stiefouder/zorgouder assimilations). Ember's 'parent' class is first-degree ONLY, so a grandparent, step-parent or zorgouder falls to 'other' and is materially OVER-taxed here — a €300,000 share is charged €150,500 instead of the statutory €33,000
• WETTELIJKE TERUGKEER not modelled (VCF art. 2.7.6.0.4): property an ascendant gave the deceased inter vivos is fully EXEMPT from erfbelasting when it returns to that ascendant, provided the property is still in the estate in natura (or, if disposed of, a claim for it is), and the deceased died without descendants — claimed in the aangifte van nalatenschap. A parent inheriting back their own gift is therefore over-taxed here
• 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' not modelled (VCF art. 2.7.4.2.5, from 1 Jan 2026: a testator leaving no partner and no descendants can designate beneficiaries in an unrevoked will for up to €100,000 per estate taxed at 3% ≤€50,000 / 9% €50,000–€100,000 instead of the collateral scale); nor is the €15,000-at-3% 'vriendenerfenis' it supersedes, which is grandfathered rather than abolished — it still applies to wills drawn up before 1 Jan 2026 regardless of the date of death, and cannot be combined with the singlevermindering, which takes precedence
• 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: a Belgian resident's (rijksinwoner's) WORLDWIDE estate is taxable, with the region fixed by the deceased's last fiscal domicile (if that moved inside the last five years, the region lived in longest in those five years); a non-resident is charged only on Belgian immovables under the recht van overgang, and liabilities are deductible there only where the deceased was domiciled inside the EEA AND the debt was specifically incurred to acquire or keep that immovable (VCF art. 2.7.3.4.1, in force 1 Jan 2026, post-Eckelkamp C-11/07) — a deceased domiciled outside the EEA is still charged on gross value; unregistered gifts made in the five years before death are added back (VCF art. 2.7.1.0.5, Flanders 3→5 years for gifts from 1 Jan 2025)
• automatic Flemish reliefs on the computed tax not modelled: VCF art. 2.7.5.0.1 reduces the charge by €500 × [1 − (net acquisition / €50,000)] for a direct-line or partner acquisition of at most €50,000 (fully neutralising it at about €12,500), by €2,000 × (net / €20,000) up to €18,750 or €2,500 × [1 − (net / €75,000)] from €18,750 to €75,000 for siblings, and by the same collateral formula on the SUM of the acquisitions for 'anderen'; VCF art. 2.7.5.0.2 reduces a child's tax by €75 for each full year until age 21, with the surviving partner receiving half of the common children's reductions. Small acquisitions are therefore over-taxed here, capped at about €500 in the direct line and €2,500 in the collateral line.

Source: Vlaamse Codex Fiscaliteit (consolidated, codex.vlaanderen.be) — art. 2.7.4.1.1 §1 TABEL I (rechte lijn/partners 3/9/27 at €50k/€250k) and TABEL II (broers en zussen 25/30/55, anderen 25/45/55 at €35k/€75k), §2 (per acquirer, movable and immovable separately; partner family-home carve-out), §3 (group aggregation for 'anderen'); art. 2.7.6.0.6 §2 (partner €75,000 movables foot-exemption, in force 1 Jan 2026); art. 2.7.5.0.1–2.7.5.0.2 (modest-acquisition and under-21 reductions); art. 2.7.4.2.2 (family business 3%/7%, in force 1 Jan 2026); art. 2.7.4.2.5 (singlevermindering, in force 1 Jan 2026); art. 2.7.3.4.1 (liabilities, in force 1 Jan 2026); art. 2.7.1.0.5 (five-year gift add-back, in force 1 Jan 2025). Cross-read against the Vlaamse Belastingdienst's own pages on vlaanderen.be (algemeen tarief; partnerabattement; belastingkredieten; singlevermindering; vriendenerfenis; gezinswoning; wanneer/waar verschuldigd), which restate the same figures and confirm the abattement is a voetvrijstelling taxed at 9% and then 27% above €75,000. Headline rate cuts trailed in the Vlaams Regeerakkoord 2024-2029 and the Septemberverklaring 2025 are NOT enacted — the tariff page states information will be added once formal decisions are taken. Wallonia and Brussels tables in gaps[0] from Fednot/notaire.be (neither regional administration publishes a tariff table). Verified 2026-08-07. PARENT class (added 2026-08-09, C2 5th RelationshipClass): art. 2.7.4.1.1 §1 heads TABEL I 'Tarief voor een verkrijging in rechte lijn en tussen partners'; §2 opens 'Tabel I, vermeld in paragraaf 1, bevat het tarief voor een verkrijging in rechte lijn en tussen partners'; §3 confines TABEL II to 'een verkrijging tussen andere personen dan personen in rechte lijn en tussen partners'. The rechte lijn is a civil-law concept, not a fiscal one: Burgerlijk Wetboek art. 735-738 (recodified into Boek 4 by the wet van 19 januari 2022) — 'men noemt rechte lijn de opvolging van graden tussen personen die de ene van de andere afstammen, en in de rechte lijn onderscheidt men de rechte nederdalende lijn en de rechte opgaande lijn', the opgaande lijn linking a person to those from whom they descend. A parent therefore takes TABEL I unchanged (3% ≤ €50,000 / 9% to €250,000 / 27% above), and no ascendant abattement exists anywhere in the VCF — art. 2.7.6.0.6 §2's €75,000 voetvrijstelling is partner-only. Cross-read against Fednot/notaris.be ('de erfbelasting in het Vlaamse Gewest') and DELA's rechte-lijn page, which both enumerate ouders and grootouders inside the direct line at 3/9/27 with no allowance. Parent leg verified 2026-08-09.

• thresholds are UT-indexed and reindex MONTHLY, not annually: Ley 16.271 art. 2 applies the unidad tributaria in force at the date of death ('la que rija al momento de la delación de la herencia'), and SII published UTM 69,751 in January 2026 rising to 71,649 in July–August 2026. This pack freezes one reading — UTA = UTM agosto 2026 × 12 = CLP 859,788 (owner ruling 2026-08-03) — so deaths earlier in the year are served bands that are slightly too generous and deaths after the next uprating bands that are slightly too tight; the intra-2026 spread is about 2.7%
• 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
• second-death relief for couples not modelled: Ley 16.271 art. 2 inciso segundo (added by Ley 21.210, in force 01.03.2020) EXEMPTS — not merely reduces — the part of a surviving spouse's or conviviente civil's estate passing to the legitimarios of both, where the survivor dies within 5 years of the first death and the first estate actually paid the tax, capped at the UTM-equivalent of the first causante's assets that bore it. Irrelevant while the engine models inheritance-model jurisdictions as a single child heir; it must be built before CL is given two-death household modelling.
• per-heir 'asignación' basis: tax applies to each recipient's share, not the aggregate estate — the engine must apply bands per recipient — the terminal-estate overlay models a single child heir, which over-states the charge for any estate split between several heirs because each heir would carry their own 50-UTA mínimo and start the progressive scale afresh.
• territorial scope is modelled as worldwide, which over-states the charge for foreign nationals: Ley 16.271 art. 1 collates foreign-situs assets by default, BUT 'en las sucesiones de extranjeros los bienes situados en el exterior deberán colacionarse … sólo cuando se hubieren adquirido con recursos provenientes del país' (confirmed by SII Oficio Ord. N°1702 de 2016). A foreign national dying resident in Chile is therefore chargeable, in principle, only on Chilean-situs assets plus foreign assets bought with Chilean-sourced resources. The engine taxes the whole worldwide estate for a Chilean death, because it carries no nationality axis — for an expatriate retiree this can be substantially the entire modelled Chilean liability.
• the art. 1 credit for death taxes paid abroad on collated foreign assets — creditable against the Chilean charge, but floored at the tax that Chilean-situs assets alone would have borne — is not modelled; the engine's situs relief (estateSitusRelief.ts) only adds legs for estate-model situs jurisdictions and never credits foreign inheritance tax against the Chilean leg.
• valuation bases (fiscal vs market value for real estate, vehicles at SII appraisal) not modelled
• ascendants ABOVE the first degree still have no relationship class: Ley 16.271 art. 2 gives cada ascendiente — at any degree — plus adoptante and adoptado the same 50-UTA mínimo exento and the same unsurcharged scale as the spouse and children. The 2026-08-09 fifth relationship class ('parent') closes this for a mother/father or adoptante heir, who now gets the 50-UTA allowance on the base scale. It is deliberately first-degree only (JP 相法18 surcharges a grandparent and IE CATCA Sch 2 puts one in Group B, so a wider 'ascendant' class would under-tax elsewhere), so a GRANDPARENT or remoter ascendiente heir is still routed to 'other' — no allowance, the +40% unrelated scale — roughly a 2.3× over-charge on that narrower cohort (CLP 200m assignment: 7,740,743 charged against 3,379,632 statutory). Conservative direction, but wrong; widening it needs a further cross-pack class, not a CL-only edit.
• the disability rebate is not modelled: Ley 16.271 art. 2 final inciso (added by Ley 21.210, in force 01.03.2020) gives an heir or donee registered in the Registro Nacional de Discapacidad a 30% reduction of the tax determined, capped at 8,000 UF per year. The engine has no heir-attribute axis and no UF index, so a qualifying heir is over-charged by 30% of their whole liability.
• life-insurance death proceeds are not modelled: since Ley 21.420 (D.O. 04.02.2022) sums payable to beneficiaries on the insured's death are deemed acquired by succession and bear the inheritance tax (policies perfected up to 03.02.2022 grandfathered unless later modified; DL 3.500 survivorship/disability cover, DL 3.500 rentas vitalicias, APV, cuota mortuoria and desgravamen hipotecario excluded). Ember's estate assembly carries no life-insurance component at all, so such proceeds are absent from the base — an under-statement for anyone holding a post-2022 Chilean life policy.
• the art. 4 'asignación líquida' deductions are not modelled: Chile computes the base after deducting last-illness and funeral costs, probate/partition costs and albacea and partidor fees within published scales, hereditary debts, forced alimony assignments and the porción conyugal. The engine deducts only unsecured non-mortgage debt, so the Chilean base is over-stated by the remaining heads.

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 arts. 1, 2, 4, 18, 20, 46 — SII consolidated text https://www.sii.cl/normativa_legislacion/ley16271.pdf (CAUTION: this SII copy is current only to Ley 21.210/2020; art. 2's scale, mínimos exentos and surcharges are unaffected, but its art. 20 is superseded — Ley 21.420, D.O. 04.02.2022, brought life-insurance death proceeds into the inheritance-tax base via art. 17, per SII Circular N°20 de 2022 https://www.sii.cl/normativa_legislacion/circulares/2022/circu20.pdf); cross-checked https://www.sii.cl/preguntas_frecuentes/herencias/001_160_0332.htm; UTA = UTM julio–agosto 2026 (71,649) × 12 = CLP 859,788; https://www.sii.cl/valores_y_fechas/utm/utm2026.htm)

• ET Art. 307 num. 4 (20% of what a non-legitimario, non-spouse recipient receives, capped at 1,625 UVT = COP 85,107,750) is modelled as a flat allowance at the cap on the sibling and other classes, because the classes shape has no percentage-with-ceiling primitive. Exact at or above COP 425,538,750 of gross; below that it over-relieves, understating tax by at most COP 5,106,465 — reached at gross COP 255,323,250, the point where the flat allowance first stops zeroing the charge — and tapering to zero at both ends of the window COP 212,769,375–425,538,750 (below COP 212,769,375 the statutory charge is itself nil, so there is no under-tax there)
• structural mismatch: ET Art. 307 nums. 1-2 are asset-type exemptions, not relationship-based, so they cannot be expressed in the per-recipient classes shape (same spirit as the ES Art. 22 gap). Only num. 4 splits by recipient class here — spouse, child and parent share the num. 3 allowance alone (Código Civil Art. 1240 makes descendants AND ascendants the legitimarios, so a parent is excluded from num. 4 exactly as a child is; the surviving spouse is not a legitimario but is named separately in num. 4)
• grandparents and remoter ascendants are 'ascendientes' — legitimarios under Código Civil Art. 1240 num. 2 on the same footing as parents — but the engine's parent class is first-degree only, so they fall to 'other' and receive the ET Art. 307 num. 4 relief the statute denies them, understating tax by up to COP 12,766,162.50 (15% of 1,625 UVT = COP 85,107,750) per inheritance. This is the one CO class mapping that errs toward UNDER-tax. It is narrow in practice: Código Civil Art. 1241 excludes a remoter ascendant while a nearer one survives, so the case arises only where both parents predeceased the deceased and a grandparent inherits.
• asset-type exemptions not modelled: the deceased's dwelling ('vivienda de habitación') up to 13,000 UVT = COP 680,862,000 and, separately, real estate OTHER than that dwelling up to 6,500 UVT = COP 340,431,000 in aggregate (ET Art. 307 nums. 1-2 as replaced by Ley 2277 de 2022 art. 30 — the pre-2022 'rural only' framing and its recreational-property carve-out are repealed). Only the per-heir 3,250-UVT exemption is encoded, so any estate containing real property is overstated.
• exemption concurrency is supported by the structure of ET Art. 307 (five independent items, no shared ceiling, asset-based nums. 1-2 vs recipient-based nums. 3-4) and by DIAN Oficio 49408 de 2014, but the Oficio has not been retrieved from an official DIAN host — treat concurrency as doctrine rather than settled primary law.
• territorial scope (verified 2026-08-07 against ET Arts. 9, 265 and 316): the worldwide-vs-Colombian-source test applies to each taxpayer separately — the sucesión ilíquida by the deceased's residence at death, and the heir, who is the person realising the ganancia ocasional under Art. 302, by the heir's OWN residence. A CO-resident recipient is taxed on an inheritance wherever situated; a non-resident recipient only on assets 'poseídos en el país' under Art. 265 (real rights over property located or exploited in Colombia, shares in Colombian entities, and the rest of that list), at the same 15% under Art. 316. Double-tax relief on a foreign inheritance taxed abroad is not modelled.
• UVT-denominated thresholds are revalued annually (2026 UVT = COP 52,374, DIAN Res. 000238/2025); COP figures are 2026-only
• 2026 was a volatile CO tax year (two economic-emergency declarations, Constitutional Court reversals) — annual re-check required
• gananciales are not modelled: ET Art. 47 provides that 'No constituye ganancia ocasional lo que se recibiere por concepto de gananciales, pero sí lo percibido como porción conyugal'. Under the Colombian sociedad conyugal the surviving spouse first takes their own half of the community property entirely outside this tax; only the porción conyugal or inherited share above that is charged. This model taxes a spouse on the whole inheritance above the 3,250-UVT allowance, so a spouse-class figure for a community-property couple can be up to about twice the statutory charge.
• ET Art. 307 num. 5 not modelled: the deceased's books, clothing, personal-use items and household furniture are exempt without limit. Immaterial for portfolio-scale estates, listed for completeness of Art. 307.
• life-insurance proceeds not modelled separately: ET Art. 303-1 (as replaced by Ley 2277 de 2022 art. 29, down from 12,500 UVT) taxes indemnities under life policies at the ganancia ocasional rate only above 3,250 UVT = COP 170,215,500, an exemption distinct from the per-heir allowance of Art. 307 num. 3. Ember has no life-policy component, so a policy entered as an ordinary asset receives no separate exemption here.
• lifetime gifts not modelled: ET Art. 302 treats donaciones and other gratuitous inter vivos transfers as the same ganancia ocasional, taxed to the recipient at 15% (Arts. 314/316). The 3,250-UVT allowance of Art. 307 num. 3 covers only porción conyugal, herencia or legado and does NOT extend to lifetime gifts; only the Art. 307 num. 4 relief (20%, capped 1,625 UVT, non-legitimario/non-spouse recipients) applies. There is no cumulation of lifetime gifts into the charge at death. This pack models the death transfer only.

Source: Estatuto Tributario Arts. 302 (herencias, legados y donaciones son ganancia ocasional), 303 y 303-1 (base gravable; seguros de vida), 307 (ganancias ocasionales exentas, nums. 1-5 per Ley 2277 de 2022 art. 30), 314/316 (tarifa única 15% para personas naturales residentes / sin residencia, per Ley 2277 de 2022 arts. 33-34), 9 y 265 (ámbito territorial), 47 (gananciales) — http://www.secretariasenado.gov.co/senado/basedoc/estatuto_tributario.html (Avance Jurídico, compilación al 31 de julio de 2026); Código Civil Arts. 1240 y 1241 (legitimarios) — Art. 1240 «<Artículo modificado por el artículo 3 de la Ley 1934 de 2018> Son legitimarios: 1. Los descendientes personalmente o representados. 2. Los ascendientes», Art. 1241 «Los legitimarios concurren y son excluidos y representados según el orden y reglas de la sucesión intestada» (http://www.secretariasenado.gov.co/senado/basedoc/codigo_civil_pr038.html); ET Art. 307 num. 4 «El veinte por ciento (20%) del valor de los bienes y derechos recibidos por personas diferentes de los legitimarios y/o el cónyuge supérstite … sin que dicha suma supere el equivalente a mil seiscientos veinticinco (1.625) UVT»; UVT 2026 = COP 52,374 per DIAN Resolución 000238 del 15 de diciembre de 2025. Retrieved 2026-08-07; Código Civil Arts. 1240-1241 and ET Arts. 307/314/316 re-retrieved verbatim 2026-08-09 for the ascendant (parent) class.

• Only 5 relationship classes. Nephews/nieces (CGI art. 777 Tableau III 55% after the €7,967 abattement of art. 779 V) collapse into 'other' and are OVER-taxed at 60% after €1,594 — €8,425 too much on a €100,000 legacy. Grandchildren are always direct-line (Tableau I, 5–45%): routed to 'other' they are heavily over-taxed, routed to 'child' they are under-taxed unless they inherit by representation, since a grandchild taking directly gets only the €1,594 of art. 788 IV.
• The 'parent' class is FIRST-DEGREE ONLY, but French ligne directe is not. Art. 777 Tableau I taxes ascendants of every degree on the 5–45% direct-line scale, and BOI-ENR-DMTG-10-50-20 (24/05/2023) § 40 confirms the art. 779 I abattement «s'applique sans limitation de degré aux ascendants» — so a grandparent or great-grandparent heir is statutorily €100,000 free then 5–45%, yet is routed here to 'other' and charged 60% after the €1,594 of art. 788 IV: €59,043.60 instead of €0 on a €100,000 legacy to a surviving grandmother. Over-taxes (conservative) and rare — ascendants inherit only where the deceased left no descendants, and grandparents only where the parents predeceased — but the line is drawn at the first degree deliberately, because JP 相法18 and IE CATCA Sch 2 Pt 1 both surcharge/downgrade grandparents and a broader class would under-tax there.
• Barème thresholds and the €100,000 child allowance are frozen INDEFINITELY — annual indexation was repealed, not suspended, so there is no expiry date; they can only move in a finance law (none did in LOI n° 2026-103 du 19 février 2026, which touched art. 787 B but not arts. 777/779).
• Handicap allowance (€159,325) and prior-gift/15-year rappel fiscal not modelled
• Assurance-vie is not modelled. Death benefits on premiums paid BEFORE age 70 sit outside droits de succession under CGI art. 990 I: €152,500 abattement per beneficiary, then a 20% prélèvement and 31.25% on the top tranche, with the surviving spouse/PACS partner exempt. Premiums paid AFTER age 70 fall under CGI art. 757 B and ARE added to the succession, taxed at the ordinary relationship barème above a single €30,500 allowance shared between all beneficiaries. This engine taxes the whole contract inside the estate at the relationship barème, so a user with a pre-70 contract is over-taxed and the post-70 branch is modelled by accident rather than by rule.
• Non-resident situs (CGI art. 750 ter) not modelled, and the omission UNDER-taxes. Limb 1° (French-domiciled deceased ⇒ worldwide) is modelled. Limb 2° is not: French-situs assets — notably French real property — of a deceased domiciled elsewhere are chargeable in France, but this engine adds a situs leg only for estate-model jurisdictions (estateSitusRelief), so France levies nothing on them here; a €500,000 French property to one child is ~€78,194 of real droits de succession modelled as €0. Limb 3° is not modelled either: an heir who has been French-domiciled for 6 of the last 10 years is taxable in France on assets received worldwide, whoever the deceased was.
• Spouse exemption encoded via a €10bn sentinel rather than a structural flag
• Sibling total exemption (CGI art. 796-0 ter) not modelled: a brother or sister who is single, widowed, divorced or separated, is over 50 or unable to work through infirmity, AND was constantly domiciled with the deceased for the 5 years before death, is wholly exempt from droits de succession. The sibling class here always charges 35/45% above €15,932, so a qualifying sibling is over-taxed by the entire liability.
• Principal-residence 20% abattement (CGI art. 764 bis) not modelled: where the deceased's main home is still occupied at death as a main residence by the surviving spouse, the PACS partner, or a minor/protected child of the deceased, spouse or partner, its taxable value is reduced by 20% before any allowance or barème. This engine values the home at full net equity, so an occupied French main residence is over-taxed — roughly €24,000 on a €600,000 home at the 20% direct-line band.
• Dutreil pacte (CGI art. 787 B) not modelled: 75% of the value of qualifying company shares is exempt from droits de mutation à titre gratuit under a 2-year collective conservation engagement plus an individual holding commitment, lengthened from 4 to 6 years by LOI n° 2026-103 du 19 février 2026 art. 8, with an active-function condition. Business value enters this estate at full value, so an eligible owner-manager is over-taxed on up to three quarters of it.
• Per-heir splitting not modelled: CGI art. 777 taxes each heir's own net share and art. 779 I gives the €100,000 abattement to EACH child, but the terminal estate overlay taxes the whole estate as one child's share, losing every allowance after the first and pushing the base up the progressive scale. A €1,000,000 estate left to two children is modelled at €212,962 against a statutory €156,389 — 36% too high — and the error grows with the number of children. The réserve héréditaire and any usufruit/nue-propriété split (CGI art. 669) are likewise not modelled.
• Stepchildren (enfants du conjoint/partenaire PACS) have no class of their own and are charged as 'other' — €1,594 then 60%, which is the pre-2026 statutory treatment. French practice commentary reports that the loi de finances pour 2026 created a €15,932 abattement for them (CGI art. 788 III bis) while leaving the 60% rate; this could not be confirmed against the consolidated CGI text on Légifrance as at 2026-08-07 and is flagged for re-check at the next review. If in force, a stepchild legacy is over-taxed here by a flat €8,603.

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. Annual indexation of the art. 777 tariffs and art. 779 abattements was repealed (loi n° 2012-958 du 16 août 2012 art. 5, which also set the €100,000 direct-line abattement and the 15-year rappel fiscal); the figures are frozen indefinitely and unchanged since 2011/2012. `parent` class (C2): CGI art. 779 I, version en vigueur depuis le 1er janvier 2013 — «Pour la perception des droits de mutation à titre gratuit, il est effectué un abattement de 100 000 € sur la part de chacun des ascendants et sur la part de chacun des enfants vivants ou représentés par suite de prédécès ou de renonciation.»; CGI art. 777 Tableau I, version en vigueur depuis le 30 décembre 2014, «Tarif des droits applicables en ligne directe» — fraction de part nette taxable n'excédant pas 8 072 € : 5 %; comprise entre 8 072 € et 12 109 € : 10 %; entre 12 109 € et 15 932 € : 15 %; entre 15 932 € et 552 324 € : 20 %; entre 552 324 € et 902 838 € : 30 %; entre 902 838 € et 1 805 677 € : 40 %; au-delà de 1 805 677 € : 45 %; BOI-ENR-DMTG-10-50-20 du 24/05/2023 § 40 — «si l'abattement s'applique sans limitation de degré aux ascendants, il est limité aux enfants du défunt et à leurs représentants».

• Disabled-beneficiary allowance €1,500,000 (any relationship) not modelled
• Italy has FOUR beneficiary brackets and Ember's five-class axis still reaches three of them (spouse/child/parent → 4% above €1,000,000, sibling → 6% above €100,000, other → 8%), and parents now land in the right one — they were previously mis-routed to the 8% 'other' class: art. 7 c.1 lett. c) TUS taxes other relatives to the 4th degree, in-laws in the DIRECT line (son/daughter/parent-in-law) and collateral in-laws to the 3rd degree at 6% with NO allowance — distinct from siblings (6% WITH €100,000) and from unrelated persons (8%). All of them are still mapped to Ember's `other` class and so are OVER-taxed by two percentage points of the whole inheritance. A parent-IN-LAW is an affine in linea retta and belongs in that 6% bracket — the `parent` class is blood parents only.
• Italy's direct line has no degree limit — parenti in linea retta (art. 75 c.c.) covers grandparents and great-grandparents as well as parents — but Ember's `parent` class is the FIRST-DEGREE ascendant only, grandparents staying in `other` by design because other jurisdictions treat them worse than parents. So a grandparent heir, statutorily in the 4% / €1,000,000 bracket, is charged 8% with no franchigia here: €80,000 on a €1,000,000 share the statute leaves untaxed. The descendant limb is unaffected in practice — the selector labels the child option 'Child / lineal descendant', so a grandchild is entered as `child` and lands on the statutorily correct 4% above €1,000,000. That reassurance rests entirely on the current selector label: it is a HELD owner question (packages/shared/src/schemas/relationship.ts) whether that label changes, so IT grandchildren must be re-checked if it does.
• Family-business / qualifying-shareholding exemption not modelled
• Imposta ipotecaria (2%) and catastale (1%) on inherited real property are separate transfer taxes, not captured: each carries a €200 minimum, both are charged on the CADASTRAL value rather than market value, and where a beneficiary qualifies for 'prima casa' both drop to a fixed €200 each (€400 total).
• Lifetime gifts are not modelled at all: the succession-side coacervo was abrogated from 1 January 2025 (so treating each death independently is correct), but gift tax on lifetime transfers — same rates, same franchigie (art. 56 TUS), with prior gifts still eroding the franchigia under art. 57 TUS — is outside this pack.
• Assets Italy leaves OUT of the attivo ereditario are not modelled (art. 12 TUS): Italian and EU/EEA State and State-guaranteed securities including BOT, BTP and CCT (lett. h-i); indemnities and insurance sums due iure proprio to heirs under artt. 1751 and 2122 c.c. and under compulsory or occupational policies taken out by the deceased (lett. c); and vehicles registered in the PRA (lett. l). Every one of these is taxed here, so an estate holding Italian government bonds or life cover is over-taxed.
• Real property is valued at MARKET value here, not the Italian succession base: art. 34 c.5 TUS bars rectification of an immovable declared at not less than the statutory multiple of its cadastral income, so in practice the taxable value of a home is its cadastral value, typically far below market. This over-states the base for any Italian estate containing property.
• Territorial scope is modelled on the death-jurisdiction side only. Art. 2 TUS charges an Italian-RESIDENT deceased on worldwide assets (correct here) but also charges a NON-resident deceased on Italian-situs assets — Italian immovables, shares in companies seated or administered in Italy, securities issued by Italian entities, credits against Italian-resident debtors (art. 2 commi 2-3). Ember levies no Italian situs charge for a deceased resident elsewhere (situs legs are computed for estate-model jurisdictions only), so an Italian holiday home owned by a non-resident is UNDER-taxed above the beneficiary's franchigia.
• The €1,000,000 and €100,000 franchigie are PER BENEFICIARY, but the death-jurisdiction estimate assumes the whole estate passes to a single child-class heir and subtracts one franchigia. Because Italy's direct-line franchigia is large, this over-taxes any estate split between two or more children by up to 4% of each additional €1,000,000 — a €3m estate to two children is charged €80,000 here against a statutory €40,000.

Source: Art. 7 commi 1-2 D.Lgs. 346/1990 (TUS), as rewritten by art. 1 c.1 lett. h) D.Lgs. 139/2024 (rates moved into the TUS from art. 2 c.48 D.L. 262/2006); Agenzia delle Entrate, 'Imposta di successione — Aliquote e franchigie' (https://www.agenziaentrate.gov.it/portale/schede/pagamenti/imposta-di-successione/aliquote-e-franchigie-cittadini). Re-verified 2026-08-07 against both. NOTE: D.Lgs. 1 agosto 2025 n. 123 approved a Testo unico of registration tax and other indirect taxes whose Part III re-houses the imposta sulle successioni e donazioni; the rates and franchigie are carried over unchanged (compilative testo unico under the L. 111/2023 delega), but the article numbering above will need re-basing onto the new TU at the next review.

• Flat per-class band model approximates Japan's statutory-share two-step method. The 20% surtax (二割加算, 相法18) — an acquirer who is neither the spouse nor a 一親等の血族 (children and PARENTS, plus a 代襲 lineal descendant) pays 1.2× the schedule figure — is encoded for the sibling class, and the parent class correctly escapes it (相法18 一親等; NTA No.4157 父母). It is still NOT applied to 'other', and with parents moved to their own class 'other' now holds almost only acquirers the statute DOES surcharge — grandparents and remoter 直系尊属 (an ascendant beyond the first degree is 二親等 or further and IS surcharged, which is why the parent class is first-degree only), nephews/nieces, unrelated legatees, and a non-代襲 grandchild adopted by the decedent (相法18②). The single un-surcharged acquirer left in 'other' is a 代襲 lineal descendant. 'other' is therefore UNDER-stated by one sixth for every acquirer it now carries except a 代襲 lineal descendant
• Single-heir approximation: the ¥36,000,000 allowance is exact for one statutory heir (相法15①, 相法16). Estates with several statutory heirs get ¥30,000,000 + ¥6,000,000 × n and have their residue split across statutory shares before the 10–55% schedule applies, so a multi-heir Japanese estate is OVER-stated here — materially so where the shares straddle a bracket. 法定相続人の数 counts disclaiming heirs and caps adopted children at one (natural children present) or two (none) — 相法15②-③
• Declared heirs move the basic exemption ONLY — Japan is excluded from per-share splitting in v1 (owner ruling D6(a), 2026-08-08, docs/decisions/2026-08-08-owner-rulings.md §B). Where a Japanese estate declares n beneficiaries, this pack computes the exemption as ¥30,000,000 + ¥6,000,000 × n and charges the whole post-exemption residue as ONE child-class slice; the beneficiaries' relationships are not read at all. READ THE COUNT CAREFULLY: 相法15① scales on 法定相続人の数 — the number of STATUTORY HEIRS, counted as if none had disclaimed and with adopted children capped at one or two (相法15②-③) — whereas the count used here is the number of beneficiaries the USER declared. The two coincide for the ordinary family will and diverge the moment a user names people who are not statutory heirs (legacies to grandchildren while a child survives, nephews, unrelated legatees, charities): each extra declared beneficiary adds ¥6,000,000 of exemption Japan would not give, so the exemption is OVER-stated and the tax UNDER-stated. That is a NEW direction of error for this pack and is HELD for an owner ruling; until it is ruled, treat a Japanese figure with non-statutory beneficiaries declared as optimistic. The 相法16 statutory-share algorithm the tax actually follows — notionally splitting the 課税遺産総額 by the 民法900 shares, applying the 10–55% schedule to each notional share, summing, then reapportioning by actual acquisition, and only then applying the 相法19の2 spouse credit and the 相法18 二割加算 — is a candidate future slice, not modelled here. In the ordinary case (declared beneficiaries = statutory heirs) the residue is still run as one slice rather than split across statutory shares, which keeps the effective rate too high, so a declared multi-heir Japanese estate remains OVER-stated — by less than before the exemption scaled. Splitting the shares naively per declared heir was rejected as under-tax-by-design: each heir would carry a full ¥36,000,000 (¥108,000,000 for three heirs against the statutory ¥48,000,000)
• Relationship is not read on the OWN-ESTATE path at all (ruling D6(a)), so the spouse relief this pack models elsewhere cannot reach it: a Japanese estate declared 100% to a surviving spouse is charged as a sole CHILD-class heir — ¥12,200,000 on a ¥100,000,000 estate — where 相法19の2①二イ makes the statutory-share leg of the spouse credit the WHOLE aggregate for a sole-heir spouse and the real charge is ¥0. The error is conservative (over-tax) and is the price of not pretending to model 相法16/18/19の2 piecemeal; it is held with the same owner question as the count caveat above, and is fixed properly only by the full statutory-share slice. Note the spouse class allowance sentinel (¥100,000,000,000,000) is untouched and still correct on the inheritance-RECEIVED path
• The parent class inherits that same single-heir approximation, and for parents the multi-heir configuration is the ORDINARY one: 直系尊属 take only where the decedent left no 直系卑属 (民法889①一), and where both parents survive they share equally (民法900④). Two surviving parents give a ¥42,000,000 basic exemption (¥30,000,000 + ¥6,000,000 × 2) and split the 課税遺産総額 into two ½ statutory shares before the 10–55% schedule applies — statutory 相続税の総額 ¥7,700,000 on a ¥100,000,000 estate (2 × [¥29,000,000 share ⇒ ¥3,850,000]) against the ¥12,200,000 charged here for a parent modelled as sole heir. 相法18 is not in issue either way: a parent is 一親等の血族 and is never surcharged, whichever way the estate divides
• 'other'-class over-relief where the decedent leaves NO statutory heir: 相法15① is ¥30,000,000 + ¥6,000,000 × 法定相続人の数, and 法定相続人 counts statutory HEIRS, not legatees. An unrelated legatee taking under a will from a decedent with no statutory heir is entitled to ¥30,000,000 flat, where this pack grants the single-heir ¥36,000,000 — an over-relief of ¥6,000,000, worth roughly ¥600,000 to ¥3,300,000 of tax depending on the bracket the top of the acquisition sits in. It runs the SAME direction as the missing 二割加算 on that class (first gap above), so a nephew or unrelated legatee is under-stated on both counts at once
• Spouse modelled as fully exempt, exact for the sole-heir case the engine models (相法19の2①二イ); a spouse who is one of several heirs and acquires more than the greater of ¥160,000,000 and her statutory share is under-taxed — the only under-tax this pack carries
• Minor-heir, disability, successive-inheritance, gift-in-contemplation credits not modelled; small-scale residential land 80% reduction not modelled (特定居住用宅地等 330㎡ at 80%, 特定事業用/特定同族会社事業用 400㎡ at 80%, 貸付事業用 200㎡ at 50% — 措法69の4)
• Taxpayer scope (相法1の3) is not modelled — every Japanese death is charged on the WORLDWIDE estate here (estateTaxAtDeath inScope). Japan actually splits acquirers into unlimited and limited taxpayers: a foreign national resident in Japan on a Table-1 status of residence whose Japanese addresses over the previous 15 years total 10 years or less is a 一時居住者 and, where the decedent is an 外国人被相続人 or 非居住被相続人, is chargeable on JAPAN-SITUS assets only — so the working expat in Japan is OVER-taxed here, by the whole foreign-asset base. Situs itself follows 相法10 (deposits by the branch that took them, securities by the issuer's head office, insurance proceeds by the insurer's head office, retirement allowances by the payer's head office, residual assets by the decedent's address) and is not modelled either. In the other direction, a Japanese national who emigrates remains chargeable on worldwide assets for ten years after leaving (相法1の3①二イ), so relocation does not clear the charge — also not modelled.
• Death-benefit exclusions are not modelled: life-insurance proceeds received by an heir are excluded up to ¥5,000,000 × the number of statutory heirs (相法12①六), and death retirement allowances — including death-in-service and post-retirement lump sums confirmed within three years of death (相法3①二) — carry a separate ¥5,000,000 × heirs exclusion (相法12①七). Both enter the estate at full value here, so a Japanese death benefit is over-taxed by up to ¥10,000,000 for a single heir.
• Unilateral foreign-tax relief is not modelled: 相法20の2 credits inheritance tax (or its equivalent) actually imposed by another jurisdiction on assets situated there against the Japanese charge, limited proportionally to the Japanese tax × foreign assets ÷ assets in the taxable base. The engine's only credit is estateSitusRelief, which relieves the situs legs Ember itself computes, so foreign death duties Ember does not charge produce no Japanese relief and a cross-border Japanese estate is over-taxed here.
• No basis step-up at death: 所法60①一 carries the decedent's acquisition cost AND acquisition date over to the heir, so a later sale is taxed on the whole latent gain (and the long/short-term test runs from the decedent's purchase). 措法39 adds part of the inheritance tax paid on the asset to its acquisition cost where it is sold within about three years and ten months of death, capped at the gain. Neither is modelled — this pack charges only the death transfer, so the total cost of dying with appreciated Japanese assets is understated.
• Gift tax (贈与税) is not modelled at all, and lifetime gifting is Japan's principal estate-planning lever. 暦年課税 gives a ¥1,100,000 annual basic deduction then an eight-bracket 10–55% schedule, in a lower 特例税率 version for gifts from a lineal ascendant to a donee aged 18 or over and a 一般税率 version otherwise (相法21の5、21の7、措法70の2の5). 相続時精算課税 is an alternative regime with its own ¥1,100,000 annual deduction for gifts made from 1 January 2024. Gifts are added back to the estate over an 加算対象期間 that steps up over time (相法19、令5改正法附則19): 3 years before death for deaths up to 31 December 2026; everything back to 1 January 2024 for deaths from 1 January 2027 to 31 December 2030; the full 7 years for deaths from 1 January 2031, with a ¥1,000,000 aggregate deduction on the portion beyond three years. Gift tax paid on added-back property is credited against the inheritance tax.

Source: 相続税法 (Act No. 73 of 1950) arts. 12, 15, 16, 18, 19, 19-2, 20-2 via e-Gov https://laws.e-gov.go.jp/law/325AC0000000073 ; National Tax Agency タックスアンサー No.4152 相続税の計算 https://www.nta.go.jp/taxes/shiraberu/taxanswer/sozoku/4152.htm , No.4155 相続税の税率 (速算表), No.4157 相続税額の2割加算, No.4158 配偶者の税額の軽減, No.4161 贈与財産の加算と税額控除 (加算対象期間), No.4102 相続税がかかる場合, No.4138 相続人が外国に居住しているとき, No.4124 小規模宅地等の特例 — all [令和7年4月1日現在法令等], re-derived 2026-08-07. Top rate 55% over ¥600M (相法16). Heir order and statutory shares behind the parent class: 民法 (Act No. 89 of 1896) arts. 887, 889, 900 via e-Gov https://laws.e-gov.go.jp/law/129AC0000000089 — 直系尊属 inherit only where the decedent left no 直系卑属 (art. 889①一) and surviving parents share equally (art. 900④).

• Gifts to other than spouse/lineal relatives are exempt only up to 3x annual UMA = MXN 128,384 (2026); the excess is taxed to the recipient as 'ingresos por adquisición de bienes' (LISR Título IV Cap. V, Art. 130 frac. I), valued at avalúo, with a 20% provisional payment within 15 days (Art. 132) ahead of the annual Art. 152 tariff — a gift-side income-tax rule, not a death tax, and not modelled (sibling gifts are not exempt; a gift from a descendant to an ascendant loses the exemption if the ascendant then alienates or re-gifts it to another lineal descendant, 'sin limitación de grado'). The UMA is re-set each 1 February while frac. XXIII c) tests a calendar year, so the applicable multiple straddles two UMA values.
• Disclosure obligations, not modelled and not taxes. (a) LISR Art. 150, third paragraph: a Mexican-resident individual whose TOTAL income for the year — taxable, exempt and definitively-taxed combined — exceeds MXN 500,000 must declare all of it in the annual return, expressly including income exempt under Art. 93 fracs. XVII (viáticos), XIX inciso a) (principal residence) and XXII (herencia o legado). The threshold is on total annual income, not on the size of the inheritance. Art. 150 does not itself forfeit the exemption for non-reporting; the exposure is SAT assessment practice and discrepancia fiscal. (b) LISR Art. 90, second paragraph: a separate informative duty in the annual return for loans, GIFTS and prizes exceeding MXN 600,000 individually or in aggregate.
• Watch item, uncited and NOT verified in the 2026-08-07 sweep: recurring Mexican legislative proposals to introduce an inheritance/gift tax and a net-wealth tax (the reported April 2026 Senate initiative is understood to pitch an inheritance/gift charge above roughly MXN 14m at 10-18% and a wealth tax above MXN 100m at 2-6%; no Gaceta del Senado record was retrievable when this pack was reviewed). Nothing of the kind is in force — the federal statute inventory contains no inheritance, estate, gift or wealth tax law — so the model stays 'none' under current law. Re-check at the next review before relying on the figures.
• 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
• LOCAL REAL-ESTATE TRANSFER TAX AT DEATH — REAL, NOT MODELLED, AND THE LARGEST MEXICAN DEATH CHARGE FOR A PROPERTY-OWNING ESTATE: the Impuesto sobre Adquisición de Inmuebles is levied by the states and Mexico City on the ACQUIRER of real property, and acquisition by reason of death is expressly inside the charge (Código Fiscal de la Ciudad de México Art. 112; Art. 115 frac. I: 'Todo acto por el que se transmita la propiedad, incluyendo la donación, la que ocurra por causa de muerte'). CDMX applies a progressive tariff (Art. 113) whose marginal factor runs from about 1.5% to 7.551%. A 0% rate applies to an inheritance ONLY where three conditions hold together (Art. 115): the property's value does not exceed 27,185 times the daily UMA (about MXN 3.19m at the 2026 UMA of MXN 117.31); the adjudication deed is granted, signed and lodged for registration within five years of the death; and the heir is the spouse, concubine or a first-degree descendant. Outside that box the full tariff is due — a MXN 10m CDMX property is on the order of MXN 0.5m of ISAI. Ceding an heir's or legatee's rights, and repudiating an inheritance after accepting it, are separately taxable acquisitions (Art. 115 frac. IX). The other 31 states levy their own ISAI or impuesto sobre traslación de dominio on the same event at their own rates, not verified here. Ember computes no probate or transfer duty in any jurisdiction, so this charge is disclosed, never modelled; tariff amounts are re-indexed annually and the figures above are indicative.
• NO BASIS STEP-UP AT DEATH, NOT MODELLED: the price of the uncapped Art. 93 XXII exemption is that the latent gain is deferred, not forgiven. LISR Art. 124 gives the heir the deceased's own cost of acquisition and the deceased's acquisition date ('el que haya pagado el autor de la sucesión ... y como fecha de adquisición, la que hubiere correspondido a estos últimos'), and the rule chains back through earlier gratuitous transfers. The inherited acquisition date does drive the inflation indexation and the 3%-per-year construction write-down in Art. 124, so a long-held asset carries a substantially uplifted indexed basis; and a gift on which ISR was actually paid does take an avalúo step-up. On a later sale by a NON-RESIDENT heir, LISR Art. 160 charges 25% of gross proceeds with no deduction, or by election through a qualifying Mexican representative the top Art. 152 marginal rate (35%) on the gain computed on that carryover basis. Ember's estate layer is basis-independent and has no death step-up primitive, so none of this is computed here; the MX row in cgtByCountry.ts carries entryStepUp: false, which is the residency-arrival concept and unrelated.
• spouseExempt: true is a required field on EstateTaxPack and is inert here: Mexico levies no death-transfer tax, so no spousal exemption exists to model, and estateTaxAtDeath puts every component out of scope before any spousal branch is reached. It is set true only so the field carries the truthful sense that a surviving spouse owes no Mexican death tax.
• SOURCE-QUALITY DISCLOSURE (2026-08-07 sweep): model 'none' is verified FEDERALLY — SEGOB's Orden Jurídico Nacional inventory of 437 federal laws in force contains no inheritance, estate, succession, gift or wealth tax statute, and the only federal tax-imposing laws are LISR, LIVA, LIEPS, the Ley Federal del Impuesto sobre Automóviles Nuevos and the Ley de los Impuestos Generales de Importación y de Exportación. Sub-nationally only Mexico City's Código Fiscal was checked, and it does charge ISAI on death transfers of real property (see the ISAI gap). No Mexican state is believed to levy an inheritance or estate tax, but the fiscal codes of the other 31 states were NOT examined, so that absence is unverified rather than confirmed.

Source: Mexico levies no federal estate, inheritance or gift tax. Verified 2026-08-07 against (1) the official consolidated Ley del Impuesto sobre la Renta published by SEGOB's Orden Jurídico Nacional — http://www.ordenjuridico.gob.mx/Documentos/Federal/wo25.doc — Art. 93 frac. XXII ('Los que se reciban por herencia o legado.'), Art. 93 frac. XXIII (gift exemptions), Art. 124 (carryover basis on inherited or gifted property), Art. 130 (taxable acquisitions — herencia and legado absent), Art. 150 third paragraph (MXN 500,000 total-income reporting threshold), Art. 90 second paragraph (MXN 600,000 gift/loan/prize informative duty), Art. 153 and Art. 160 (non-resident source rules); (2) the SEGOB federal-law inventory at http://www.ordenjuridico.gob.mx/leyes.php, which contains no inheritance, estate, gift or wealth tax statute among the 437 federal laws in force; (3) INEGI's UMA press release 1/26 of 8 Jan 2026 — https://www.inegi.org.mx/contenidos/saladeprensa/boletines/2026/uma/uma2026.pdf — UMA from 1 Feb 2026: MXN 117.31 daily / 3,566.22 monthly / 42,794.64 annual, so 3x annual = MXN 128,383.92; (4) the Código Fiscal de la Ciudad de México, Impuesto sobre Adquisición de Inmuebles chapter (Arts. 112-115), as published by the CDMX Secretaría de Administración y Finanzas — https://transparencia.finanzas.cdmx.gob.mx/repositorio/public/upload/repositorio/Tesoreria/123/b/Criterio_9/123_XV_Impuesto_sobre_adquisicion_de_inmuebles_2024.pdf. Secondary cross-check only: PwC Worldwide Tax Summaries — Mexico, Individual/Other taxes (last reviewed 06 Aug 2026), 'There is no specific inheritance, estate, or gift tax in Mexico.' — note PwC does not cover ISAI.

• 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
• Lifetime GIFTS of Portuguese real estate are not modelled, and they are the one place the exempt family ring still pays: TGIS verba 1.1 charges 0.8% on 'aquisição onerosa ou por doação' of immovables, and the Art. 6(1)(e) exemption is expressly limited to transfers 'sujeitas à verba 1.2', so a spouse, descendant or ascendant receiving a gifted PT property pays 0.8% of the VPT (€2,400 on a €300,000 VPT home) even though the 10% is exempt; a non-exempt donee pays 0.8% + 10% (CIS Art. 22(4) disapplies the no-accumulation rule for these two verbas). NOTE this does NOT apply on death — verba 1.1 reaches only onerous acquisitions and doações, so an inheritance of PT real estate bears no 0.8% and an exempt heir pays nothing at all.
• GRANDPARENTS and remoter ascendants are still over-taxed. CIS Art. 6(1)(e) exempts 'descendentes e ascendentes' with no degree limit, but Ember's 'parent' relationship class is first-degree only (a deliberate cross-pack choice — other jurisdictions do distinguish, e.g. Japan surcharges a grandparent and Ireland gives one only Group B — so grandparents fall to 'other'). An inheritance passing up to a grandparent is therefore charged the flat 10% here against a statutory zero: €25,000 on a €250,000 legacy. Parents themselves ARE now modelled correctly as exempt.
• life-insurance proceeds, social-security death benefits, and PPR / fundos de pensões / fundos de poupança-reforma / pan-European personal pension products are outside the charge altogether — a NON-incidence rule, not an exemption, so it protects non-family beneficiaries too (CIS Art. 1(5)(a)-(b), the PEPP limb added by Lei 31/2024). Ember folds DC pots into the terminal investable pot, so a Portuguese PPR left to a sibling is taxed here at 10% against a statutory zero.
• Portuguese real estate is valued for this duty at the VPT (valor patrimonial tributário) on the matriz at the date of transfer — NOT at market value and not at the greater of the two (CIS Art. 13(1); the 'whichever is greater' rule applies to movables under Art. 14(1) and to residual rights under Art. 13(2)). Ember values property at market equity, and the VPT is usually well below market, so a taxable PT property is over-taxed here — a €500,000 house with a €250,000 VPT left to a sibling is modelled at €50,000 against a statutory €25,000. Usufruct / bare-ownership splits and the CIMT partial-rights valuation rules (Art. 13(4), 13(6)) are likewise not modelled.
• Heir relationship is not modelled in the terminal estate: the overlay values a Portuguese death as passing to a single descendant, who is exempt, so estate tax at a PT death is always shown as zero. That is right when descendants inherit, but a childless estate passing to a sibling, a nephew or an unqualified partner bears the full 10% on its Portuguese-situs assets with no allowance — €40,000 on a €400,000 PT estate, modelled here as €0. The relationship-scaled 0%/10% split is applied only on the inheritance-RECEIVED path, not to your own estate.
• Goods of personal or household use are outside the charge entirely (CIS Art. 1(5)(f); the 2004 reform also abolished the old presumption that an estate contained them), as are transfers to IRC taxpayers (Art. 1(5)(e)) and small lifetime gifts — €500 of customary donativos (Art. 1(5)(d)) and €5,000 between spouse/unido de facto, descendants and ascendants (Art. 1(5)(g), Lei 82/2023). Ember has no chattels asset kind, so household or personal items entered as PT-situs assets are taxed here at 10% for a non-exempt heir against a statutory zero.

Source: Código do Imposto do Selo arts. 1.º, 2.º, 3.º, 4.º, 5.º, 6.º n.º 1 al. e), 13.º, 14.º, 22.º + Tabela Geral verbas 1.1/1.2 (info.portaldasfinancas.gov.pt, retrieved 2026-08-07); CIS preâmbulo (DL 287/2003 property-tax reform); CIRS art. 45.º for the death-basis rule; PT rental pack slice 2026-07-24.

• 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 (IRC §2001(c)) collapsed to flat 40% on the US-domiciled leg only, where it is EXACT rather than an approximation — the $15,000,000 exclusion sits above the $1,000,000 point at which the 40% bracket begins, so tax is exactly 40% of the excess. The non-resident-alien US-situs leg runs the full §2001(c) schedule less the §2102(b)(1) $13,000 credit
• Lifetime gift-tax unification ($15M is a combined gift+estate exclusion) not separately modelled; the separate annual per-donee exclusion ($19,000 for 2026) and the $194,000 annual exclusion for gifts to a non-citizen spouse (§2523(i)(2)) do not consume the unified amount and are not 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
• Basis step-up at death (IRC §1014) not modelled: heirs take fair market value at the date of death, so unrealised capital gains escape income tax entirely — Ember charges no CGT at death for any jurisdiction, so this is disclosure only, not a divergence. The exception matters: IRC §1014(c) denies the step-up for income in respect of a decedent, so traditional IRA / 401(k) balances pass with the decedent's basis and heirs pay ordinary income tax on withdrawals ON TOP of estate tax; community-property halves get a double step-up under §1014(b)(6).
• US-situs scope for non-resident aliens is taken from each asset's country tag and is not re-derived from IRC §2104/§2105. Shares in US-incorporated companies are US-situs even when held through a non-US broker (§2104(a); IRS Form 706-NA guidance), as is US real estate and tangible property; but US bank deposits and portfolio-interest debt (§2105(b)), life insurance on an NRA's life (§2105(a)) and art on loan (§2105(c)) are NOT. A non-US-domiciled fund holding US equities (e.g. an Irish UCITS ETF) is not US-situs. Tag assets accordingly — only $60,000 is sheltered, and the rate above it is 40%.
• Generation-skipping transfer tax (IRC ch. 13) not modelled: transfers to grandchildren or to trusts for them can bear a further flat 40% (§2641 — the maximum §2001 rate × the inclusion ratio) on top of estate tax. The GST exemption is a SEPARATE $15,000,000 allocation for 2026 (§2631(c), Rev. Proc. 2025-32 §.14) and, unlike the estate exclusion, is not portable to a surviving spouse.
• Chapter-11 deductions other than the marital and charitable deductions are not modelled: funeral and administration expenses, claims against the estate and certain indebtedness (IRC §2053) and administration-period casualty losses (§2054) all reduce the taxable estate in practice. Only unsecured debt outstanding at death is deducted here, so the taxable base — and the tax — is slightly overstated.
• One recipient-side US transfer tax exists and is not modelled: a US citizen or resident receiving a gift or bequest from a COVERED EXPATRIATE pays 40% of it themselves (IRC §2801, Form 708), above a §2503(b) annual floor ($19,000 for 2026). Relevant only where the deceased had expatriated as a covered expatriate.

Source: IRC §2001(c) rate schedule; §2010(c)(3) basic exclusion $15,000,000 as amended by OBBBA (P.L. 119-21) §70106, confirmed by Rev. Proc. 2025-32 §.14 (https://www.irs.gov/pub/irs-drop/rp-25-32.pdf); IRS Estate Tax filing thresholds (https://www.irs.gov/businesses/small-businesses-self-employed/estate-tax); IRC §2102(b)(1) $13,000 NRA credit = $60,000 exclusion-equivalent, IRS Form 706-NA guidance; §2056/§2056A marital deduction and QDOT; §2055 charitable deduction; §1014 basis. Re-verified 2026-08-07 (estate sweep wave 2).

• asset-class scope NOT modelled — Law 109/2025/QH15 Điều 3.9 makes taxable ONLY an inheritance or gift of chứng khoán (securities), phần vốn trong các tổ chức kinh tế / cơ sở kinh doanh (capital in economic organisations and business establishments), bất động sản (real estate), and các tài sản phải đăng ký sở hữu hoặc đăng ký sử dụng (assets requiring ownership or use registration). CASH, BANK DEPOSITS, GOLD BULLION AND UNREGISTERED CHATTELS ARE OUTSIDE THE CHARGE ENTIRELY. This pack applies the flat 10% to the whole inherited value, so an estate holding cash or deposits is over-taxed by 10% of that portion above VND 20m.
• real-estate close-family exemption NOT modelled — Điều 4.1 exempts income from the transfer, inheritance or gift of REAL ESTATE (bất động sản only) between spouses; natural parents and natural children; adoptive parents and adopted children; parents-in-law and daughter-in-law; parents-in-law and son-in-law; paternal grandparents and paternal grandchildren; maternal grandparents and maternal grandchildren; and full siblings. It is asset-class-conditioned, so it cannot be encoded as a relationship-keyed allowance or a 0% class band, and spouseExempt is deliberately false to avoid wrongly zero-rating a spouse inheriting securities or a business stake. The pairing is bidirectional in the statute ("giữa … cha đẻ, mẹ đẻ với con đẻ"), so the C2 `parent` class sits inside this exempt list on exactly the same real-estate-only terms as `child` — and is left non-exempt here for exactly the same reason.
• death-path interaction: the terminal estate overlay models a VN estate as passing to a single CHILD-class heir (estateTaxAtDeath, v1), and a natural child is inside the Điều 4.1 exempt list for real estate — so the real-estate component of a modelled VN estate is charged the flat 10% where the statute charges nothing. Exempting it needs an asset-class-aware death path, not a relationship change; the exemption must NOT be applied to an 'other'-class heir who falls outside the Điều 4.1 list (an unrelated legatee, a cousin, a nephew), for whom the 10% is correctly due.
• C2 relationship-class scope vs Điều 4.1: the `parent` class added 2026-08-09 is first-degree only (heir = cha đẻ / mẹ đẻ of the deceased), while Điều 4.1's real-estate exempt list is wider — cha nuôi, mẹ nuôi (adoptive parents), cha chồng, mẹ chồng and cha vợ, mẹ vợ (parents-in-law) and ông nội, bà nội / ông ngoại, bà ngoại (both grandparent lines) all sit inside it but map to `other` here. This moves NO number today, because Điều 18 has no relationship axis and all five classes carry the identical VND 20m per-occurrence threshold and flat 10%; it becomes material the moment the asset-class-aware Điều 4.1 exemption above is modelled, at which point the class taxonomy alone will not identify every exempt pairing.
• 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 (Điều 29.1 — inheritance/gift is outside the Điều 29.2 carve-out that gives resident business and employment income a whole-2026 start, so 1 Jul 2026 is the correct commencement for this head; Điều 29.3 repeals Law 04/2007/QH12 and its eight amending laws from that date) — immaterial to forward FIRE projections
• Điều 18.4 delegates the detail of this Điều to a Government decree which has not yet published — the valuation basis for an inherited unlisted business stake and the exact boundary of 'tài sản phải đăng ký sở hữu hoặc đăng ký sử dụng' are unresolved; re-check on publication rather than waiting for nextReviewDue.
• territorial reach: Law 109/2025/QH15 Điều 2.1 charges a VN TAX RESIDENT on taxable income arising both inside and outside Vietnam, so a resident (including an expat resident) receiving a foreign inheritance of securities, business capital, real estate or registrable assets is inside the Điều 18 flat 10% on the worldwide value; Điều 26 charges a NON-RESIDENT 10% only on value received 'tại Việt Nam'. The engine reproduces both legs (recipient-residence leg on the full value, situs leg where situs differs, higher of the two), but two approximations remain: the situs tag is applied to the whole estate rather than per component, and taking the higher of the two legs stands in for a foreign-tax credit that this head of the Law does not itself provide.
• basis at death is not a Vietnamese concept for the assets an heir usually sells: Điều 13.2 taxes securities transfers at 0.1% of the transfer PRICE and Điều 14.1 taxes real-estate transfers at 2% of the transfer PRICE, both without reference to acquisition cost, so there is no latent gains charge on an inherited unrealised gain and no step-up to model. The one open case is Điều 13.1 (non-securities capital transfers, 20% of price less giá mua and costs, or 2% of price where those cannot be determined) — whether an heir's giá mua is the inherited value or nil is left to the unpublished Điều 13.4 decree.

Source: Luật Thuế thu nhập cá nhân số 109/2025/QH15 (Quốc hội khoá XV, kỳ họp thứ 10, thông qua 10/12/2025) — Công báo số 37, 22/01/2026: Điều 3.9 (taxable inheritance/gift asset classes), Điều 4.1 (real-estate close-family exemption), Điều 18.1-18.2 (resident: flat 10% on value above VND 20m per occurrence), Điều 26 (non-resident: 10% on VN-situs value above VND 20m), Điều 29.1 (in force 1 Jul 2026). C2 `parent` derivation (2026-08-09): Điều 18 verbatim — "Thu nhập tính thuế từ nhận thừa kế, quà tặng là phần giá trị tài sản thừa kế, quà tặng vượt trên 20 triệu đồng mà người nộp thuế nhận được theo từng lần phát sinh" … "được xác định bằng thu nhập tính thuế nhân (x) với thuế suất 10%" — no relationship term anywhere in the charge, so an ascendant heir is taxed identically to a descendant (Chính phủ policy portal reproduction: https://xaydungchinhsach.chinhphu.vn/quy-dinh-thue-thu-nhap-ca-nhan-doi-voi-thu-nhap-tu-nhan-thua-ke-qua-tang-119260327152356109.htm). The only place relationship appears in this head is the asset-class-conditioned Điều 4.1 exemption, verbatim: "Thu nhập từ chuyển nhượng, nhận thừa kế, quà tặng là bất động sản giữa vợ với chồng; cha đẻ, mẹ đẻ với con đẻ; cha nuôi, mẹ nuôi với con nuôi; cha chồng, mẹ chồng với con dâu; cha vợ, mẹ vợ với con rể; ông nội, bà nội với cháu nội; ông ngoại, bà ngoại với cháu ngoại; anh, chị, em ruột với nhau" — bidirectional ("giữa … với …"), so it reaches a parent inheriting from a natural child, but only for bất động sản. Gazette: https://congbao.chinhphu.vn/van-ban/luat-so-109-2025-qh15-468671.htm — official signed PDF: https://congbaocdn.chinhphu.vn/180507251028987904/2026/1/24/109signed-17692403594311667615452.pdf (the thuvienphapluat.vn English translation previously cited here returns HTTP 403 and is retained only as an unofficial reading aid).

• 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 tax where the asset sits (UK IHT on UK-situs assets; US estate tax on US-situs assets above the USD 60,000 non-resident-alien threshold). Ember DOES model these: it charges each estate-model situs jurisdiction from its own pack and applies a proportional credit.
• NOT MODELLED — a former home jurisdiction's WORLDWIDE reach. UK inheritance tax now turns on long-term residence rather than domicile: under IHTA 1984 s.6A (inserted 6 April 2025 by Finance Act 2025 Sch. 13) someone UK-resident for at least 10 of the previous 20 tax years stays a long-term UK resident for a further 3 to 10 non-resident tax years, and throughout that tail their WORLDWIDE estate — not merely UK-situs assets — stays chargeable to UK IHT at 40% above the nil-rate band. Ember applies that test only when the modelled death jurisdiction is the UK, so a UAE-resident former UK resident inside the tail is shown zero estate tax here.
• NOT MODELLED — citizenship-based reach. A US citizen is chargeable to US estate tax on the entire gross estate 'wherever situated' (26 U.S.C. s.2031(a)) whatever their residence, so a US-citizen UAE resident's non-US assets fall outside the US-situs leg Ember does model.
• No UAE estate or inheritance tax treaty exists. The UK has ten inheritance-tax double taxation conventions (France, India, Ireland, Italy, Netherlands, Pakistan, South Africa, Sweden, Switzerland, USA) and the UAE is not among them, so a UAE resident's UK IHT exposure attracts only unilateral relief under IHTA 1984 s.159. Ember's proportional situs credit is a modelling approximation, not treaty relief.
• Property registration fees are not modelled and are not a tax: Dubai Land Department charges heirs a FLAT AED 1,000 per property on an inheritance title transfer (plus ~AED 250 title deed, map fees and a AED 130 + VAT service-partner fee), with no percentage of value — whereas a LIFETIME gift of the same property to a first-degree relative costs 0.125% of the DLD valuation, minimum AED 2,000, plus a AED 2,000-4,000 + VAT service-partner fee, and an ordinary third-party sale carries the 4% Dubai land registration fee. Other emirates set their own fees.

Source: UAE Federal Tax Authority — Taxes (primary, accessed 2026-08-07): the FTA administers exactly three taxes — VAT, Excise Tax and Corporate Tax; no death-transfer tax exists. https://tax.gov.ae/en/taxes.aspx · UAE Government official platform (u.ae) — Taxation: 'The UAE does not levy income tax on individuals.' https://u.ae/en/information-and-services/finance-and-investment/taxation · Corroborating secondary: PwC Worldwide Tax Summaries — UAE, Individual Other taxes (last reviewed 12 March 2026): 'There are currently no inheritance, estate, or gift taxes imposed on individuals in the United Arab Emirates.'

• CGT event K3 (ITAA 1997 s 104-215) is not modelled: where a CGT asset of an Australian-resident deceased passes to a FOREIGN-RESIDENT beneficiary and is not taxable Australian property — or passes to an exempt entity or the trustee of a complying superannuation entity — a capital gain equal to market value at the date of death less cost base arises just before death and is assessed in the deceased's date-of-death return (disregarded for assets acquired before 20 September 1985). This is the one genuine at-death tax charge in Australia, it is uncapped, and it is triggered by exactly the cross-border family shape this product models.
• Superannuation death benefits to non-dependants are not modelled here (they are a super/income-tax matter, not an estate pack): ITAA 1997 s 302-145 caps the rate at 15% on the element taxed in the fund and 30% on the element untaxed in the fund, plus the 2% Medicare levy where the benefit is paid directly to an individual (no levy where it is paid to the deceased estate and assessed to the trustee under s 302-10). The tax-free component is never assessable (s 302-140). 'Dependant' is narrow — s 302-195 covers a spouse or former spouse, a child aged under 18, an interdependency relationship or an actual dependant, so financially independent adult children are NON-dependants.
• Deemed cost-base inheritance / deferred CGT and the main-residence window are CGT-layer concerns, not modelled here: ITAA 1997 s 118-195 disregards the gain where the interest ends within 2 years of death (or a longer period allowed by the Commissioner), but ONLY if the deceased was not an 'excluded foreign resident' just before death — a foreign resident for a continuous period of more than 6 years who does not meet the life-events test (ss 118-195(1)(c), 118-110(3)-(5)). The same condition switches off the s 128-15 item 3 market-value cost base, so a long-term expat's former family home passes at its original cost base with no main-residence relief.
• State stamp/transfer duty on some transfers not modelled (state variation)
• Inheritances received from a FOREIGN estate are modelled as tax-free, which is right for an Australian estate and can be wrong for an overseas one: ITAA 1936 s 99B includes in an Australian-resident beneficiary's assessable income any amount of trust-estate property paid to, or applied for the benefit of, that beneficiary, reduced only so far as it represents corpus or amounts that would not have been assessable to a resident (s 99B(2)); s 99C reads 'applied for the benefit of' widely. A deceased estate is a trust estate for this purpose.

Source: Income Tax Assessment Act 1997 (Cth), Compilation No. 266 (compilation date 01/07/2026): s 128-10 and s 128-15 (effect of death; cost-base table), s 104-215 (CGT event K3), ss 118-110 and 118-195 (main residence; excluded foreign resident), ss 302-10, 302-140, 302-145 and 302-195 (superannuation death benefits). Income Tax Assessment Act 1936 (Cth), Compilation No. 192 (compilation date 01/07/2026): s 99B and s 99C (distributions from a foreign trust estate). Federal Register of Legislation: Estate Duty Assessment Act 1914 and Gift Duty Assessment Act 1941, both repealed / no longer in force. Australian Treasury, 'A brief history of Australia's tax system' (Economic Roundup, Winter 2006) for the 1977-1982 abolition sequence.

• Provincial probate / estate-administration fees (e.g. Ontario EAT ~1.5% over CAD 50,000) not modelled — administrative levies, vary by province
• NOT MODELLED ANYWHERE IN EMBER: the ITA s.70(5) deemed disposition at death (each capital property deemed sold at fair market value immediately before death, one-half of the gain included in the deceased's terminal return at marginal rates under s.38(a)). This is Canada's real death tax. Ember's CGT layer is triggered by plan disposals and by ceasing residence, not by death, and the estate assembly carries no cost base, so the charge cannot be computed here — the estate figure is gross of it
• Spousal/common-law rollover (ITA s.70(6)) is conditional and its conditions are not modelled: the DECEASED must have been resident in Canada immediately before death — a Canadian who emigrates and dies non-resident gets no rollover — the spouse/common-law partner or qualifying testamentary spousal trust must be Canadian-resident, and the property must vest indefeasibly within 36 months of death (extendable on written application to the Minister). The legal representative may also elect OUT of the rollover property-by-property under s.70(6.2). Only the headline deferral is recorded here
• spouseExempt=true is recorded for schema consistency but is a CGT-deferral rollover, not an estate-tax exemption (Canada has no death-transfer tax)
• NOT MODELLED ANYWHERE IN EMBER, and usually the largest Canadian death charge for a retiree: registered plans are deemed received in FULL at death, not taxed at the 50% capital-gains inclusion. ITA s.146(8.8) deems the RRSP annuitant to have received, immediately before death, a benefit equal to the fair market value of all the property of the plan; ITA s.146.3(6) does the same for the full fair market value of a RRIF. Relief is narrow and conditional — a s.146(8.1) refund-of-premiums designation to a surviving spouse or common-law partner or to a financially dependent child or grandchild, plus the s.146(8.9) deduction. A registered wrapper is not a capital property, so this is separate from the s.70(5) deemed disposition and would not be covered by modelling that alone
• TERRITORIAL SCOPE, NOT MODELLED: because Canada levies no death-transfer tax there is no situs or domicile scope to encode here, but Canada still reaches a NON-RESIDENT at death. ITA s.70(5) deems a disposition of each capital property at fair market value with no residence precondition, and ITA s.2(3)/s.115(1)(b) bring a non-resident's taxable capital gains on taxable Canadian property — which includes Canadian real or immovable property — into Canadian taxable income. A non-resident dying with a Canadian property is therefore taxed on one-half of the accrued gain, and no s.70(6) spousal rollover is available to them. Ember shows zero Canadian charge in that case
• NO GIFT TAX, BUT GIFTS ARE NOT FREE AND ARE NOT MODELLED: Canada levies no gift tax, yet ITA s.69(1)(b) deems a taxpayer who disposes of anything by way of gift, or to a non-arm's-length person for less than fair market value, to have received proceeds equal to fair market value — so giving appreciated property to a child crystallises the gain immediately at the 50% inclusion rate, and s.69(1)(c) gives the recipient a fair-market-value cost base. An inter vivos transfer to a spouse or common-law partner rolls over at cost under s.73(1) unless elected out. Ember models no lifetime gifting event, so none of this appears in a projection
• SOURCE-QUALITY DISCLOSURE: the absence of a federal death-transfer tax is established structurally from the Justice Laws consolidated-Acts index (accessed 2026-08-07), but the PROVINCIAL succession duties were not re-read from provincial statute books in that pass — Quebec's Légis Québec and Ontario's e-Laws both refuse automated retrieval. The historical record is that Ontario repealed its succession duty by The Succession Duty Repeal Act, 1979 (S.O. 1979, c. 20) and Quebec's Succession Duty Act (c. D-13.2) ceased to apply to successions opening after 23 April 1985, with full repeal for successions opening after 27 May 1986; no province or territory levies a death-transfer tax today. Provincial probate/estate-administration charges (above) are the surviving death-time levies

Source: Canada levies no estate, inheritance or gift tax. Verified structurally against the Justice Laws consolidated-Acts index (accessed 2026-08-07: https://laws-lois.justice.gc.ca/eng/acts/E.html, /S.html, /G.html, /I.html, /D.html), which carries no estate, inheritance or gift tax statute — the only death-transfer title, the Dominion Succession Duty Act (R.S.C. 1952, c. 89), resolves to 'This Act is not included in the database of consolidated federal legislation' (https://laws-lois.justice.gc.ca/eng/acts/Z-0.98/FullText.html). What death does trigger is income tax on the deceased: ITA s.70(5) deemed disposition at fair market value and s.70(5)(b) step-up (https://laws-lois.justice.gc.ca/eng/acts/I-3.3/section-70.html), one-half inclusion under ITA s.38(a) (https://laws-lois.justice.gc.ca/eng/acts/I-3.3/section-38.html, consolidation current to 2026-06-17), the s.70(6) spousal rollover, and full deemed receipt of RRSP/RRIF value under ITA s.146(8.8) and s.146.3(6). The proposed two-thirds inclusion rate was cancelled on 21 March 2025 (Prime Minister of Canada news release, https://www.pm.gc.ca/en/news/news-releases/2025/03/21/prime-minister-mark-carney-cancels-proposed-capital-gains-tax-increase) and never entered the statute — s.38(a) still reads '½'. Provincial probate charges survive, e.g. Ontario Estate Administration Tax at $15 per $1,000 of estate value above $50,000 since 1 January 2020 (Estate Administration Tax Act, 1998; https://www.ontario.ca/page/estate-administration-tax).

• Lifetime gifts are a separate track outside this death-transfer model and are not modelled here: §10(3)(c)(1)-(2) ZDP exempts gratuitous income WITHOUT LIMIT from a relative in the direct line and, in the collateral line, from a sibling, uncle, aunt, nephew, niece, spouse, child's spouse, spouse's child, spouse's parents or parents' spouse, and from anyone the taxpayer shared a jointly-managed household with for at least the year before the gift; §10(3)(c)(5) exempts other gifts where the aggregate FROM THE SAME DONOR in the tax period does not exceed CZK 50,000 (raised from CZK 15,000 by zákon č. 349/2023 Sb. with effect from 1 January 2024). Anything above that is ordinary 'other income' on the §16 scale — 15% up to 36× the average wage, 23% above it.
• What the heir does NEXT is not modelled, and Czech law splits the answer: on a later sale the deductible cost of a gratuitously acquired asset is its valuation-law price at the date of acquisition (§10(5) ZDP), so death-date value is effectively stepped up; but the §4(1) exemption time tests (10 years for immovable property, 3 years for securities and crypto-assets, 5 years for a stake in a company) do NOT restart — they are shortened by the period the DECEASED held the asset, and only where the deceased was a relative in the direct line or a spouse. Inherit from a sibling, a more distant relative or an unrelated testator and the clock starts again at zero, so a sale soon after death can be fully taxable on the §16 15%/23% scale even though the inheritance itself was exempt.
• §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 (zákon č. 586/1992 Sb., ZDP), consolidated text in force 1 Aug 2026: §4a písm. a)-b) (unconditional exemption of income from inheritance or bequest, and of a trust beneficiary under a mortis-causa settlement), §10(3)(c) (lifetime-gift exemptions; bod 5 CZK 50,000 per donor per tax period), §10(5) (valuation-law cost basis for gratuitously acquired assets), §16(1) (15% / 23% above 36× average wage), §38v-§38w (CZK 5m notification of exempt income and its 0.1/10/15% penalty ladder): https://www.zakonyprolidi.cz/cs/1992-586 | Inheritance, gift and real-estate-transfer tax Act (zákon č. 357/1992 Sb.) REPEALED with effect 1 Jan 2014 by zákonné opatření Senátu č. 340/2013 Sb.: https://www.zakonyprolidi.cz/cs/1992-357 | gift threshold raised CZK 15,000 → 50,000 by zákon č. 349/2023 Sb. (konsolidační balíček) from 1 Jan 2024: https://www.zakonyprolidi.cz/cs/2023-349 | Finanční správa — Daň z příjmů fyzických osob, Ostatní (oznámení o osvobozených příjmech): https://financnisprava.gov.cz/cs/dane/dane/dan-z-prijmu/fyzicke-osoby/ostatni | PwC Worldwide Tax Summaries — Czech Republic, Individual, Other taxes (last reviewed 27 July 2026): https://taxsummaries.pwc.com/czech-republic/individual/other-taxes | ARROWS: https://arws.cz/news-at-arrows/tax-aspects-of-large-inheritances-2026

• Versorgungsfreibetrag (§17) not modelled: +€256,000 spouse, €52,000 down to €10,300 for a child by age at death — but §17 reduces it by the capital value of non-taxable survivor pensions, so a spouse with a widow's/widower's pension may get little or none of it
• Familienheim exemption (§13(1) Nr.4b/4c) not modelled: unlimited for a surviving spouse, but capped at 200 m² Wohnfläche for a child, and both require the deceased's own occupation until death plus the heir's continued self-use for ten years or the relief is clawed back
• Business/agricultural reliefs (§§13a/13b, 85–100%) not modelled
• Grandchild allowance €200,000/€400,000 collapsed into child class
• Parents inheriting ON DEATH are now modelled as their own class — Steuerklasse I bands with the §16(1) Nr.4 €100,000 allowance (§15(1) StKl I Nr.4), so €500,000 to a surviving mother is the statutory €60,000, not the €144,000 the old 'other' routing charged. Two residual scope defects remain: (a) GRANDPARENTS and remoter ascendants (Voreltern) are in exactly the same §15(1) StKl I Nr.4 / §16(1) Nr.4 position on death, but the relationship class covers first-degree ascendants only, so a grandparent heir still routes to 'other' (€20,000 allowance and Steuerklasse III rates) and is over-taxed by a factor, not a margin — conservative; (b) the class is death-only by construction, and this pack scores no gift events at all, so it cannot express the Steuerklasse II treatment (€20,000, 15–43%) the same parent would get on a lifetime gift
• ErbStG §13(1) Nr. 10 (steuerfreier Rückfall) is not modelled: assets a parent or other Vorelternteil had gifted to the now-deceased descendant revert to them tax-free on that descendant's death, to the extent the reverting assets can still be identified in the estate — precisely the scenario the `parent` class scores. This pack charges the full Steuerklasse I tax on such a reversion instead of exempting it, a conservative over-tax, not modelled.
• Scope (§2) not modelled — worldwide reach: unbeschränkte Steuerpflicht attaches if EITHER the deceased OR the recipient is an Inländer (§2(1) Nr.1), so a German-resident heir is taxable on a wholly foreign estate
• EXPAT REACH not modelled (largest scope gap for this product): a German national remains an Inländer, taxable on the WORLDWIDE estate, for five years after giving up German residence (§2(1) Nr.1b ErbStG); and for up to ten years after emigrating to a low-tax country §4 AStG extends the charge beyond German Inlandsvermögen to everything that would not be ausländische Einkünfte under §34d EStG, with an escape only where a foreign death tax of at least 30% of the German tax is actually payable (§4(2) AStG) — which a move to a no-estate-tax jurisdiction such as the UAE does not provide. The engine scores the death against the destination country's pack, so this can under-state the whole liability
• Limited liability (§2(1) Nr.3) not modelled: a non-Inländer decedent is taxable on German Inlandsvermögen (§121 BewG) with an allowance prorated under §16(2); the engine adds no German leg for DE-situs assets on the own-death path because estateSitusRelief only levies estate-model situs jurisdictions (the received-inheritance path does charge DE situs)
• §19(3) Härteausgleich IS applied (the jump on crossing a Wertgrenze is levied only from half the excess at rates up to 30%, three quarters above); §19(2) treaty-exempt-asset rate preservation is not
• §10(1) S.6 base rounding not applied: the steuerpflichtiger Erwerb is rounded DOWN to full €100 before the §19 tariff. Under the Vollmengenstaffeltarif that rounding is RATE-relevant, not just base-relevant — it can pull an acquisition back below a Wertgrenze and so change the rate applied to the WHOLE acquisition — so this model can charge the next rate up on an acquisition the statute would keep in the lower one. The §19(3) Härteausgleich bounds the residual to the tax on at most €99 of excess (≤ €74), so the euro impact is negligible; disclosed because an unmodelled base rule on a slab tariff is a rate rule in disguise
• Lifetime gifting not modelled at all: the ErbStG is a combined inheritance AND gift tax, and the §16 allowances refresh every ten years per donor/recipient pair (§14 aggregates earlier acquisitions from the same person inside that window) — so serial gifting is Germany's dominant death-tax planning lever and this pack scores a single death event only. The January 2026 SPD concept would replace the ten-year refresh with one lifetime allowance
• Pending reform risk: BVerfG ruling + Jan-2026 SPD concept open — re-review before nextReviewDue
• Valuation not modelled: Erbschaftsteuer is a single federal tax with no Land variation in allowances or rates, but the taxable base is the Bewertungsgesetz value determined by the local Finanzamt — for real estate the Grundbesitzwert (Ertragswert-/Sachwertverfahren), not the market value this model carries — and a lower value may be proved under §198 BewG
• §13d 10% valuation relief not modelled: residential property let to tenants is brought in at 90% of its value automatically (no occupancy test, no holding period, no election), unless it is §13a-privileged business or agricultural property; third-country property qualifies only where information exchange is assured. Every let residential property in a German estate is therefore over-taxed here by the tax on 10% of its value
• no step-up in basis on death — the heir is treated as having made the deceased's own acquisition (§23(1) S.3 EStG for private assets, §11d EStDV for depreciable ones), so a later SALE of an inherited asset is taxed on the gain from the DECEASED's original cost and acquisition date, after Erbschaftsteuer has already been charged on the death-date value; the partial income-tax relief for that double charge (§35b EStG) is also not modelled (a CGT-side effect, not modelled in this pack)

Source: ErbStG §15 Steuerklassen (https://www.gesetze-im-internet.de/erbstg_1974/__15.html) — StKl I Nr.4 'die Eltern und Voreltern bei Erwerben von Todes wegen', StKl II Nr.1 the same persons outside death acquisitions — §16 Freibeträge (https://www.gesetze-im-internet.de/erbstg_1974/__16.html), incl. Nr.4 'der übrigen Personen der Steuerklasse I in Höhe von 100 000 Euro', and §19 Steuersätze incl. §19(2) 'ganzer Erwerb' and the §19(3) Härteausgleich (https://www.gesetze-im-internet.de/erbstg_1974/__19.html); scope §2 (https://www.gesetze-im-internet.de/erbstg_1974/__2.html) and §4 AStG; base/rounding §10(1); reliefs §13(1) Nr.4b/4c, §§13a/13b, §13d, §17. Both §16 and §19 stand in their 23.06.2017 StUmgBG version (in force 25.06.2017) — no change for 2026. The ErbStG was last amended by Art. 10 of the Gesetz vom 22.06.2026 (BGBl. 2026 I Nr. 192, notarial-digitalisation act), which touches no allowance or rate. Corroborated against PwC WWTS Germany 2026. Verified 2026-08-07.

• 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 runs on long-term residence, not domicile: UK resident for at least 10 of the previous 20 tax years (IHTA 1984 s6A, inserted by Finance Act 2025 s44). That 10-of-20 test IS modelled and decides whether the estate is charged worldwide or on UK-situs assets only. NOT modelled: the 3-to-10-year 'tail' that keeps a departing long-term resident in worldwide scope after leaving (so a recent leaver is understated); the test runs on whole projection years at the death age rather than on UK tax years; and Schedule A1 (UK residential property held through offshore structures, in scope regardless of residence) relies on situs tagging alone.
• Business Property Relief and Agricultural Property Relief are not modelled at all. From 6 Apr 2026 (Finance Act 2026 s65/Sch 12) the 100% rate is capped at a £2,500,000 combined allowance per estate — transferable between spouses/civil partners, so up to £5,000,000 for a couple, on top of the NRB and RNRB — with 50% relief (an effective 20% rate) above it, and 50% relief in all circumstances for shares not listed on a recognised exchange (e.g. AIM), which do not use up the allowance. Any qualifying business or agricultural property in this model is charged at the full 40%.
• Unused pension funds and death benefits enter the IHT estate for deaths on or after 6 Apr 2027 (Finance Act 2026 ss66-70). Remaining DC pots are ALREADY inside the modelled estate (they are carried as investable assets), so this pack matches the post-Apr-2027 law; only a death before 6 Apr 2027 is overstated, and the pre-2027 exclusion is not modelled because the pension remnant cannot be attributed out of the blended terminal pot. Death-in-service benefits, and death benefits passing to a long-term-resident spouse/civil partner or to charity, stay outside IHT and are not separately modelled.
• 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
• Charity reduced rate (36%, IHTA Sch 1A) is carried as data but never auto-applied — the engine always charges flatRatePct; the Sch 1A per-component 10%-of-baseline test and the merger election are not modelled.
• Charitable and other exempt legacies (IHTA s23-s27) are not deducted from the estate at all.
• RNRB is applied to every GB estate unconditionally. In law it needs a qualifying residential interest in the estate that is closely inherited by direct descendants, and it is capped at the value of the home actually left to them (IHTA 1984 s8E-s8M). A user with no property, no direct descendants, or a home worth less than the band therefore has their IHT understated — by up to £70,000 single, £140,000 for a couple with both bands brought forward.
• Settled property is not modelled: the relevant-property regime's ten-yearly principal charges and exit charges (IHTA 1984 Part III Ch III) are ignored, as is the interaction of the reformed APR/BPR allowance with property settled into trust.
• Gifts with reservation of benefit (FA 1986 s102) and pre-owned assets are not modelled — an asset given away but still enjoyed remains in the death estate in law, and this model would treat it as gone.

Source: IHTA 1984 Sch 1 (40% above the £325,000 nil-rate portion), Sch 1A (36% lower rate, 10% of the baseline amount), s6A (long-term UK residence, 10 of 20 tax years — inserted by Finance Act 2025 s44), s8A/s8G (transferable NRB and brought-forward RNRB), s18(1)/(2)/(2A) (spousal exemption, capped at the nil-rate band for a non-long-term-resident spouse); NRB £325,000, RNRB £175,000 and the £2,000,000 RNRB taper threshold frozen to 5 Apr 2031 by Finance Act 2026 c.11 s72; GOV.UK, Rates and allowances: Inheritance Tax thresholds and interest rates.

• 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
• Class collapse (over-taxes, narrowed by the 'parent' class): (a) CATEGORY A also covers second-degree blood descendants (GRANDCHILDREN) — Art. 78 s.1(d) L.5219/2025 — and no RelationshipClass reaches them, so a grandchild heir falls to 'other' and is charged the Cat C scale (EUR 6,000 free, then 20/30/40%) instead of Cat A (EUR 150,000 free, then 1/5/10%) — on a EUR 300,000 share that is EUR 84,900 instead of EUR 1,500. The first-degree blood ascendant limb (PARENTS, Art. 78 s.1(e)) is now modelled: the 'parent' class carries the Cat A allowance and scale, so that leg of the old collapse is FIXED. Ascendant scope is first-degree ONLY — ascendants of the second and further degrees (grandparents, great-grandparents) are Category B by statute (s.1(b)), not Category A, and remain in 'other' under limb (b); (b) CATEGORY B non-sibling relatives (great-grandchildren, grandparents, uncles/aunts, nephews/nieces, step-parents, step-children, sons/daughters-in-law, parents-in-law — Art. 78 s.1 Cat B (a),(b),(f)-(j)) are likewise mapped to 'other' at Cat C 20-40% instead of their legal Cat B 5-20%.
• Territorial scope not modelled, and the engine's default over-taxes: Art. 55 s.1 L.5219/2025 reaches (a) all property situated in Greece, whoever owns it, and (b) foreign-situated MOVABLE property of a Greek national wherever domiciled and of a foreigner domiciled in Greece — foreign IMMOVABLE property is outside scope entirely, and Art. 75 s.2(c) further exempts the foreign movables of a Greek national settled abroad for at least ten consecutive years (except civil servants, military and employees of Greece-based companies posted abroad). estateTaxAtDeath applies the Greek scale to the WORLDWIDE net estate for any non-GB/non-US death jurisdiction, so a Greece-resident foreigner holding foreign real estate is over-taxed by up to 10% of that property's value (conservative direction).
• Gift/parental-grant interaction not modelled: donations and parental grants to Category A persons (and cash gifts to them made through a financial institution) are taxed under Art. 98 s.1 L.5219/2025 at a flat 10% after a ONE-OFF EUR 800,000 tax-free amount, and those same acquisitions are expressly NOT aggregated with the later inheritance between the same persons ('δεν συνυπολογίζονται στην αιτία θανάτου κτήση περιουσίας μεταξύ των ίδιων προσώπων'). Cash gifts outside that route are taxed autonomously at 10% (Cat A) / 20% (Cat B) / 40% (Cat C) under Art. 98 s.2. Aggregation with the death scale (Arts. 57, 82, 91) survives only for gifts outside the Art. 98 s.1 regime. None of this is modelled: the engine has no lifetime-gift rail at all.
• Reliefs not modelled: (a) the first-residence exemption of Art. 76 L.5219/2025 for a spouse/civil partner/child heir — a dwelling exempt up to EUR 200,000 (minor or unmarried heir) or EUR 250,000 (married/partnered/divorced/widowed/single parent with custody), plus EUR 25,000 for each of the first two children and EUR 30,000 for the third and each subsequent, and a building plot to EUR 50,000 / EUR 100,000 with EUR 10,000 / EUR 15,000 child uplifts, all conditional on the heir having no other adequate housing, on a five-year retention undertaking, and on the heir being a Greek or EU/EEA citizen (Art. 76 Section C) — so a non-EEA heir, including a British one, does NOT qualify; (b) a flat 10% reduction of the computed tax where the heir has a disability of at least 67% (Art. 79 s.2); (c) full exemption where the deceased was a serviceman who died in and because of the execution of duty (Art. 75 s.2(f)). NOTE: the Code carries NO agricultural/farm exemption on the inheritance side — its special agricultural exemption (Arts. 46-48) belongs to the real-estate transfer tax.
• 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
• Joint accounts not modelled: Art. 75 s.2(b) L.5219/2025 exempts joint cash deposits and joint accounts in other financial products, held in Greece or abroad and irrespective of the co-holders' residence, on the death of any co-holder — the balance passes automatically to the surviving co-holders and the exemption repeats down to the last of them (excluded only for accounts in non-cooperative jurisdictions or states with no administrative-assistance/CRS arrangement with Greece). The engine charges the whole assembled estate, so a household holding joint deposits or joint brokerage accounts is over-taxed at the first death.
• Insurance and pension death benefits not modelled: Greece does not run them through the inheritance scale. Lump sums or pensions paid on the death of the insured by an insurer, insurance fund or organisation are deemed GIFTS (Art. 88 s.2(b)-(d) L.5219/2025) and are then EXEMPT where they go to the surviving spouse or civil partner, the children, the parents or unmarried sisters of the deceased (Art. 97 Section B(b)); a life policy enters the inheritance base only where the policy names no beneficiary (Art. 54 s.1(c)). The engine assembles pension and wrapper balances into the estate base and charges them on the Cat A child scale, so an estate that is mostly a pension pot passing to a spouse or children is over-taxed — potentially by the whole 10% top-band charge on it.
• Foreign-tax credit approximated: Art. 83 L.5219/2025 gives a unilateral credit for death tax determined, assessed or paid abroad on property Greece also taxes, apportioned between the Greek and each foreign part of the estate and floored at the tax attributable to the Greek-situs assets alone (federal-state sub-taxes count; FX at the official rate). The engine applies its generic proportional situs credit (estateSitusRelief), which is not per-state apportioned and does not implement the Greek-situs floor.

Source: Government Gazette text of L.5219/2025 (Kodikas Forologias Periousias), FEK A' 130/18.07.2025 — Art. 55 (scope), Art. 75 (general exemptions incl. the EUR 400,000 spouse/minor-child exemption at s.2(e) and its bracket-collapse rule), Art. 76 (first residence), Art. 77 (taxable share), Art. 78 (categories — s.1(c) children, s.1(d) grandchildren and s.1(e) «οι ανιόντες εξ αίματος πρώτου βαθμού» (first-degree blood ascendants, i.e. PARENTS) are all Category A, which is what binds the 'parent' class to the Cat A allowance and scale; Cat B (b) puts ascendants of the second and further degrees in Category B, so grandparents are outside that class), Art. 79 (scales; s.2 disability reduction), Art. 83 (foreign credit), Arts. 88/97/98 (gift and parental-grant regime). Scale figures cross-checked against the Hellenic Ministry of Economy and Finance capital-taxation guide and PwC Worldwide Tax Summaries (Greece, reviewed 16 Feb 2026), which reproduce the Ministry cumulative-tax figures exactly. Not amended in substance by L.5264/2025, L.5301/2026 or L.5313/2026. Band boundaries cross-checked against Greek practitioner guides (KPAG, efm.gr, Taxheaven) — the Ministry's cumulative check figures reproduce exactly under this encoding.

• 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
• Five relationship classes (spouse/child/sibling/parent/other) still cannot express Ireland's three CAT groups exactly: only a brother or sister genuinely maps to 'sibling' €40,000 (Group B), and Group C (uncles, aunts, grandnephews/nieces, cousins, in-laws, friends, cohabitants) maps to 'other' €20,000 — but the inheritance dialog labels the child option 'Child / lineal descendant', so a GRANDCHILD entered as a child is given the €400,000 Group A threshold instead of the statutory €40,000 Group B one (CATCA 2003 Sch 2 Pt 1 para 1(b); Revenue: a lineal descendant such as a grandchild is Group B), under-charging by up to €118,800 on a €400,000 benefit. The mirror-image hazard now exists on the ascendant side: a GRANDPARENT is statutorily a Group B lineal ancestor with the same €40,000 threshold (CATCA 2003 Sch 2 Pt 1 para 1(b)), but resolveRelationshipClass offers no grandparent option and 'parent' is first-degree only, so the product routes a grandparent heir to 'other' at the €20,000 Group C threshold — an over-charge of exactly €6,600 (33% of the €20,000 allowance shortfall) on any benefit of €40,000 or more.
• Statutory re-classifications that promote a beneficiary to child treatment are not modelled: Favourite Nephew or Niece Relief (CATCA 2003 Sch 2 Pt 1 para 7), Foster Child Relief (para 9) and Surviving Spouse Relief (para 6, under which the surviving spouse of a nearer relative of the disponer takes that relative's group). All three raise the threshold, so the affected beneficiaries are over-charged.
• CAT's connecting factors are not modelled: CATCA 2003 s.11(2) charges an inheritance where EITHER the disponer is resident or ordinarily resident in the State at the date of the disposition, OR the successor is resident or ordinarily resident at the date of the inheritance, OR the property is situate in the State — and s.11(4) treats a person NOT domiciled in the State as neither resident nor ordinarily resident until they have been resident for the 5 consecutive years of assessment immediately preceding. The engine taxes the whole worldwide estate of anyone dying in Ireland from day one, so a foreign-domiciled recent arrival is over-charged on all non-Irish property for their first five years — potentially the entire liability.
• Irish-situs property of a non-Irish decedent is not charged: CATCA 2003 s.11(2)(c) taxes property situate in the State regardless of either party's residence, but the engine's situs legs apply only to estate-model jurisdictions, so an Irish house or Irish-registered shares left by someone dying elsewhere to non-Irish heirs attracts no CAT in this model — an under-charge of 33% of the Irish-situs value above the beneficiary's group threshold.
• Spouse allowance €1bn is a synthetic sentinel — the exemption is genuinely uncapped
• The 'parent' class models ONLY the para 1(a)(ii) case — an ABSOLUTE interest taken on the death of the child — which is the only case this pack can be reached on. Two statutory qualifications on that class remain unmodelled, in opposite directions: (a) a parent taking a GIFT, or taking a LIMITED interest (e.g. a life interest) on the death, is Group B €40,000 (Revenue groups page; thresholds Example 3 — a mother's life interest falls to Group B), and this pack would apply Group A to it, under-charging by up to €118,800 on a €400,000 benefit; (b) CATCA 2003 s.79 exempts the parent's inheritance ENTIRELY where the child took a non-exempt gift or inheritance from either parent in the 5 years before death, so an s.79 case is over-charged by the full Group A liability.
• CAT thresholds are per beneficiary, but the death-jurisdiction leg models the whole estate as one child's benefit (estateTaxAtDeath v1): Revenue's own worked example gives each of two children their own €400,000 Group A threshold on a €900,000 estate. An estate split between N children is over-charged by roughly (N−1) × €400,000 × 33% = €132,000 per additional child heir. The spousal exemption is likewise not applied on this path — an estate left wholly to a surviving spouse (exempt under CATCA 2003 s.71) is still modelled as passing to a child.

Source: Revenue.ie — Capital Acquisitions Tax (CAT) thresholds, rates & aggregation (2026); Budget 2026 left thresholds and the 33% rate unchanged. Primary: CATCA 2003 Sch 2 Pt 1 (group thresholds, incl. para 1(a)(ii) parent-on-death Group A) and Pt 2 (Table), s.71 (spouse exemption), s.79 (parent's inheritance exempt where the child took a non-exempt benefit from a parent within the prior 5 years — unmodelled), ss.6/11 (territorial scope); Revenue.ie cat-thresholds.aspx / cat-rates.aspx / cat-groups.aspx (verified 2026-08-07).

• death itself is not a taxable event (Income-tax Act 2025 s.70(1)(b) — a transfer of a capital asset by an individual or HUF under a will is outside the capital-gains charge), but there is no full step-up in basis: the heir takes the previous owner's cost (s.73(1) Table Sl. No. 1) and the previous owner's holding period (s.2(101)(c)(B)(I)), so a later SALE triggers ordinary CGT on the whole accrued gain. One partial step-up exists and is not modelled: where the asset became the previous owner's property before 1 April 2001 the heir may elect fair market value on 1 April 2001 instead of historic cost (s.90(9)(b)), capped for land or buildings at the 1 April 2001 stamp-duty value (s.90(10)). All of this is a CGT-layer effect, not an estate-pack effect.
• 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
• LIFETIME GIFTS ARE TAXED, and Ember models death transfers only: the standalone Gift-tax Act 1958 charge ceased for gifts made on or after 1 October 1998 (s.3(3)), but the recipient is charged income tax at ordinary slab rates under Income-tax Act 2025 s.92(2)(m) on money received without consideration where the total exceeds Rs 50,000, on immovable property whose stamp-duty value exceeds Rs 50,000 (and on under-consideration transfers where the shortfall exceeds the higher of Rs 50,000 or 10% of consideration), and on other property by aggregate fair market value on the same Rs 50,000 test — unless an s.92(3) exclusion applies (from a relative, on the occasion of marriage, under a will or by way of inheritance, in contemplation of death, from a local authority or registered non-profit, or a s.70(1) non-transfer). A lifetime gifting plan therefore shows zero Indian tax in this model and may carry a real one.
• CROSS-BORDER GIFTS from India are deemed Indian-source: Income-tax Act 2025 s.9(8) (successor to s.9(1)(viii) of the 1961 Act, from 5 July 2019) deems a s.92(2)(m) receipt arising outside India and paid by a person resident in India to a non-resident or to a not-ordinarily-resident person to accrue or arise in India. It fixes situs only — chargeability still runs through s.92, so the s.92(3)(c) will/inheritance exclusion survives and an INHERITANCE passing from India to a non-resident heir stays untaxed; a lifetime GIFT from an India-resident donor to a non-resident recipient does not.
• Deaths BEFORE 16 March 1985 remain within the old estate-duty regime (agricultural land came out earlier — Estate Duty Act 1953 s.5B, with the 1982 amendments applying from 1 March 1981 in the listed States) — historical edge case, not modelled.
• spouseExempt=true is recorded for schema consistency only — India levies no death-transfer tax, so there is no Indian spousal exemption to apply, and the engine ignores the flag for model "none" packs.

Source: PRIMARY: Estate Duty Act 1953 s.5C — 'this Act shall cease to apply to the levy of estate duty in respect of any property (other than agricultural land) which passes on the death of any person on or after the 16th day of March, 1985' (India Code, Repealed Acts: https://www.indiacode.nic.in/repealedfileopen?rfilename=A1953-34.pdf; text: http://www.liiofindia.org/in/legis/cen/num_act/eda1953151/). Income-tax Act, 2025 (No. 30 of 2025) s.92(3)(c) — receipts 'under a will or by way of inheritance' excluded from the gift charge; s.1(3) — in force 1 April 2026 (Gazette of India Extraordinary Pt II s.1 No. 35, 21 August 2025: https://egazette.gov.in/WriteReadData/2025/265620.pdf). Gift-tax Act 1958 s.3(3) — Act 'shall cease to apply and shall have no effect whatsoever in respect of any gift made on or after the 1st day of October, 1998' (https://www.indiacode.nic.in/bitstream/123456789/2483/1/a1958-18.pdf). Wealth-tax Act 1957 s.3(2) as amended by Finance Act 2015 (Act 20 of 2015) s.81 — charge ends before 1 April 2016 (https://www.indiacode.nic.in/bitstream/123456789/3123/1/a1957-27.pdf). SECONDARY: PwC Worldwide Tax Summaries — India, Individual Other taxes: https://taxsummaries.pwc.com/india/individual/other-taxes

• SOURCE-QUALITY DISCLOSURE: the abolition date (deaths on or after 1 Nov 1991) and the repealing instrument (Finance Act 1992 [Act 476]) are corroborated across independent Malaysian practitioner sources but the repealing SECTION was not retrieved from the gazette — lom.agc.gov.my exposes its pre-1998 principal-Acts corpus only through a POST search form. This is the one place the MY pack falls short of the SG pack's verbatim-statute bar. The 'no estate/inheritance/gift tax in 2026' conclusion does NOT depend on it: that is established structurally from LHDN's Acts index and Finance Act 2025 [Act 874] s.2
• Deaths BEFORE 1 Nov 1991 remain within the repealed estate-duty regime — historical edge case, not modelled
• FORCED HEIRSHIP IS NOT MODELLED. For a Muslim decedent, faraid (Islamic law of inheritance, administered by the Syariah Courts, Perintah Faraid) fixes the heirs' shares and a will (wasiat) may dispose of at most one third of the estate to persons outside the faraid heirs. Ember distributes the estate per the user's own inputs and will over-state a testator's freedom for Muslim users
• Non-Muslim intestacy follows the Distribution Act 1958 [Act 300] statutory shares (spouse/issue/parents), not the user's stated intentions — same caveat, no tax consequence
• Lifetime gifts of Malaysian real property are NOT tax-free: Stamp Act 1949 First Schedule item 32(a) ad valorem duty applies to a gift as it does to a sale. P.U.(A) 178/2023 exempts the first RM1,000,000 for parent<->child and grandparent<->grandchild transfers (50% remission on the balance) but only where the TRANSFEREE is a Malaysian citizen — a foreign heir gets the full scale. Modelled in propertyFees, not here
• Foreign-situs assets of a Malaysian 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
• Periodic Malaysian commentary proposing an inheritance tax (most recently around Budget 2025/2026) is opinion, not law — no bill was tabled as at 2026-08-07, and Finance Act 2025 [Act 874] contains no death-transfer chapter

Source: Malaysia levies no estate, inheritance or gift tax. Estate duty (Estate Duty Enactment 1941 [F.M.S. No. 7 of 1941], extended by the Estate Duty (Transitional Provisions) (No. 2) Ordinance 1946, plus the Sabah and Sarawak estate-duty ordinances) was abolished for deaths on or after 1 November 1991 and the enactment was repealed by the Finance Act 1992 [Act 476]. Confirmed structurally against LHDN's own Acts index (accessed 2026-08-07), which carries no estate-duty statute: https://www.hasil.gov.my/en/perundangan/akta/ — and against Finance Act 2025 [Act 874] s.2, which amends only the Income Tax Act 1967, RPGT Act 1976, Stamp Act 1949, Labuan Business Activity Tax Act 1990 and Petroleum (Income Tax) Act 1967.

• Grandchildren and further descendants are not modelled — RelationshipClass has no grandchild slot. Successiewet art. 24 lid 1 note 1 charges descendants in the second or further degree the group-I tax plus 80% of it (so 18%/36% at the 2026 group-I rates), while art. 32 lid 1 sub 4 d gives the €26,230 exemption to grandchildren ONLY — a great-grandchild gets 18%/36% with the €2,769 residual exemption.
• Successiewet art. 32 lid 1 sub 4 e gives a parent recipient a €62,110 exemption, and art. 24 lid 1 confines the 10%/20% column to a partner and descendants in the direct line, so a parent is taxed at 30%/40% like any other acquirer — differing from 'other' by that allowance alone. Two limits remain. The exemption is confined to 'ouders': a grandparent or further ascendant gets no parent exemption, so leaving them in the 'other' class (€2,769 at 30%/40%) is exactly what the statute charges here, not an approximation. And art. 19 lid 1 sub b equates aanverwanten (relatives by marriage) with bloedverwanten for SW purposes — ending only if the marriage or partnership that created the aanverwantschap was dissolved other than by death — while sub c–f extend the same equivalence through the pleegouder, joint-gezag, voogdij and genetic-parent routes. Such a person IS statutorily an 'ouder' and takes the €62,110 exemption, but the selector has no option for them, so they route to 'other' and are over-taxed by up to €23,736.40 (40% of the €59,341 allowance shortfall, at the top of the NL_OTHER scale).
• Disabled-child exemption (€78,671) not modelled
• Partner status for unmarried couples is not modelled and must be chosen by hand. Successiewet art. 1a treats two unmarried adults as partners for erfbelasting if, for the six months before death, they were registered at the same address (BRP or an equivalent foreign register) with a mutual care obligation under a notarial cohabitation contract, are not lineal blood relatives and have no other partner — and art. 1a lid 3 drops the notarial-contract requirement entirely after five unbroken years at the same registered address. A qualifying cohabitant therefore takes the €828,035 partner exemption and the 10%/20% rates; record such a person as 'spouse', not 'other'.
• Business-succession relief (BOR) is not modelled: Successiewet art. 35b exempts 100% of qualifying business assets up to €1,543,500 and 75% of the excess. Nor is the successive-death relief of art. 53 lid 4, which on request reduces erfbelasting to NIL where the recipient dies within thirty days of the acquisition and the same assets are taxed again.
• Box-3 (Wet IB 2001) is a separate regime and out of scope. Gift tax (schenkbelasting) is levied by this same Act (Successiewet art. 1 lid 1 sub 2°) on the same relationship classes with its own exemptions (art. 33), and is not modelled — note that art. 12 lid 1 deems anything gifted within 180 days before death to have been acquired by inheritance instead, so lifetime gifting close to death is pulled back into this base.
• Pension imputation against the partner exemption is NOT modelled: Successiewet art. 32 lid 2 exempts survivor pension rights, annuities and periodic death benefits from erfbelasting but deducts HALF their value from the partner's €828,035 exemption, with a floor of €213,915 (AOW and Anw entitlements are excluded from the imputation). A surviving partner with substantial pension provision can therefore lose up to €614,120 of exemption — up to about €122,824 of tax at the 20% rate — that this pack still grants in full.
• Territorial reach is only partly modelled. Erfbelasting is charged on the WORLDWIDE estate of anyone who was resident in the Netherlands at death (Successiewet art. 1 lid 1 sub 1°), which the engine reproduces, but the deemed-residence tail is not modelled: art. 3 lid 1 treats a DUTCH NATIONAL who has left the Netherlands as still resident for ten years after departure, so emigrating from the Netherlands does not end the charge for a Dutch national and this model understates it for up to ten years. Conversely, and also not surfaced, the Netherlands levies no death tax at all on Dutch-situs assets of a non-resident deceased — the recht van overgang was repealed with effect from 1 January 2010.
• Partner aggregation is not modelled: Successiewet art. 25 treats inheritances taken by two partners from the same estate as a single acquisition by one of them (at the closer relationship), so they share one exemption and one run through the 10%/30% band. Each inheritance recorded here is scored on its own, which understates the charge where a couple both inherit from one estate.

Source: Successiewet 1956 (consolidated 2026-01-01, wetten.overheid.nl) arts. 1, 1a, 3, 12, 24, 25, 32, 35a, 35b, 53; Belastingdienst — Tarieven erfbelasting 2026 and Vrijstellingen erfbelasting 2026 (both re-verified 2026-08-07).

• The income-tax consequences of death are not modelled here (they are the deceased's own income-tax items, not a death tax): subpart FC of the Income Tax Act 2007 treats transfers on death as disposals and acquisitions at market value (s FC 2), subject to rollovers at tax book value for a spouse, civil union partner, de facto partner, close relatives, charities and forestry (ss FC 3-FC 6) and at the deceased's cost for residential land (s FC 9). That can produce income in the deceased's final return on revenue-account property, including FIF interests and financial arrangements. Inherited residential land is expressly outside the bright-line test in the beneficiary's hands (s CB 6A(3)), though the ordinary land-sale rules can still apply and the beneficiary inherits the deceased's purpose in acquiring the property.
• 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
• Inheritances RECEIVED by a New Zealand resident from overseas are modelled as tax-free, which is right for a New Zealand estate and can be wrong for a foreign one: Inland Revenue's IS 25/18 (7 August 2025) states that where a foreign trust arises out of the administration of a deceased estate offshore, amounts distributed to New Zealand-resident beneficiaries may be beneficiary income or taxable distributions, taxed at the beneficiary's marginal rate — 45% for a non-complying trust. Only beneficiary income, corpus, certain capital gains, foreign superannuation withdrawals and pensions are outside the taxable-distribution definition (s HC 15(4)); the s HC 16 ordering rules treat income as distributed first and corpus last regardless of the trust's own records; and if the components cannot be established from those records the ENTIRE distribution is treated as taxable, with the onus on the beneficiary. Disclosure is on form IR307.
• The Green Party's proposed 'Capital Acquisitions Tax' is party policy, not law — a 33% tax on inheritances AND gifts received above NZD 1 million, payable by the RECIPIENT rather than the estate, with small gifts, the family home, family farms, Te Ture Whenua Māori Act land transfers and Post-Settlement Governance Entity transfers exempt (Green Party, 'A tax system for all of us', 2026). If it were ever enacted this pack would become an inheritance-model pack, not an estate-model one. Watch item only: New Zealand's next general election is Saturday 7 November 2026 — re-check after it.

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

• Group 0 full exemption is conditional on notifying the tax office (SD-Z2) within 6 months — for an inheritance the clock runs from the day the court's succession order becomes final, or from registration of the notarial certificate of inheritance / issue of the European Certificate of Succession (art. 4a ust. 1 pkt 1 and ust. 1a), with a fresh 6 months for an heir who learned of the acquisition late (ust. 2), and no notification required at all where the cumulated value is at most 36,120 zł or the acquisition is by notarial deed (ust. 4). The pack assumes the exemption is secured; failing it drops the heir to Group I ordinary rates (allowance 36,120 zł, 3/5/7%), not modelled (art. 4a ust. 3).
• 'other' is the engine's catch-all class and overstates several distinct cohorts by defaulting to the Group III (unrelated) scale: Group I in-laws (allowance 36,120 zł, 3/5/7%) and Group II heirs (allowance 27,090 zł, 7/9/12%) per the record's DE-mirroring conservative default — and, more sharply, the Group 0 relations the RelationshipClass axis still cannot express: grandparents and remoter wstępni, step-parents (ojczym/macocha), step-children (pasierb) and the art. 14 ust. 4/4a adoptive and foster relations that map to neither `parent` nor `child` (an adoptive parent entered as `parent` already gets the correct 0 zł, since art. 14 ust. 4 makes przysposabiający — adoptive parents — rodzice, i.e. wstępni; it is the remaining adoptive/foster relations, such as an adoptive sibling, that still land here) are FULLY EXEMPT under art. 4a ust. 1 but are charged 12/16/20% above 5,733 zł. The commonest of those cases — a parent inheriting from a child — is now modelled exactly by the 'parent' class (art. 4a ust. 1 wstępnych, 0 zł liability); for the rest treat the modelled figure as an upper bound and read 0 where art. 4a applies.
• the 'parent' class is first-degree only (mother/father), while art. 4a ust. 1 exempts every wstępny — a grandparent or remoter ascendant inheriting from a Polish estate owes nothing under the Act but is charged the Group III 12/16/20% scale here as 'other'. The narrow class is deliberate and cross-jurisdictional (other packs' statutes charge grandparents worse than parents, so a broad 'ascendant' class would under-tax there); in Poland it is a pure over-charge on the grandparent case, disclosed rather than modelled.
• A legislative proposal to extend the art. 4a Group 0 exemption to registered/informal partners has been reported in the 2026 session but is NOT in the consolidated text as at 2026-06-18 (t.j. Dz. U. z 2026 r. poz. 478, 775) — deliberately not encoded; confirm against Dziennik Ustaw, not press or Sejm-stage reporting, at next review
• the gazetted scale states cumulative flat amounts rounded UP to whole ten-groszy (art. 17 ust. 3), while the marginal-band encoding recomputes them exactly, so the modelled Group III charge sits up to 12 grosze (PLN 0.12) below the statutory figure — 1,420.00 zł vs 1,419.96 zł at 11,833 zł and 3,313.20 zł vs 3,313.08 zł at 23,665 zł. Immaterial, and deliberately not compensated: fixed-flat encoding is not expressible in EstateBand.
• territorial scope is not modelled and does not key on the deceased: art. 2 taxes assets located abroad only when the ACQUIRER was a Polish citizen or permanently resident in Poland at the moment of death, so a Polish-citizen heir living outside Poland is in scope of Polish tax on a wholly foreign estate (the engine has no citizenship axis and charges the Polish leg only on the recipient's residence — an under-charge), while art. 3 pkt 1 exempts MOVABLE assets situated in Poland where neither the heir nor the deceased was a Polish citizen or permanently resident/seated in Poland, so a foreign heir taking a Polish bank or brokerage account from a foreign deceased owes nothing yet is charged the Group III scale here (an over-charge). Only Polish immovables are reached unconditionally by art. 1 ust. 1.
• the Act provides no credit or deduction for inheritance/estate tax paid abroad (art. 7's deductible debts and charges do not include foreign tax), so where art. 2 reaches a foreign estate the Polish charge can stack on the foreign one; the engine's recipient-side model instead takes max(residence tax, situs tax), a full-credit method, so cross-border double charge is understated. A handful of pre-war bilateral estate conventions exist and are not modelled.
• conditional reliefs on the taxed ('other') path are not modelled — art. 16 ulga mieszkaniowa excludes the net value of up to 110 m² of an inherited dwelling from the base (Group I on inheritance or gift, Group II on inheritance, Group III only for a carer under a notarially-certified written agreement of at least two years, and in every case only for an heir who owns no other dwelling), and art. 4b exempts an inherited sole-trader enterprise for any heir who notifies within 6 months and carries the business on for at least two years. Both are over-stated (conservative) here.
• the allowance and scale run per transferor and are cumulative: art. 9 ust. 2 adds the net value of everything acquired from the same person in the year of the last acquisition and the 5 preceding years, with credit for tax already paid, so lifetime gifts consume the 5,733 zł allowance and shift the death transfer up the scale. Each inheritance is modelled in isolation, so prior gifts are ignored (under-tax).

Source: Ustawa z dnia 28 lipca 1983 r. o podatku od spadków i darowizn, consolidated text t.j. Dz. U. z 2026 r. poz. 478, 775 (ISAP, text as at 2026-06-18) — art. 1-3 territorial scope, art. 4a Group 0 exemption, art. 9 ust. 1 kwoty wolne (36,120 / 27,090 / 5,733 zł), art. 14 group definitions, art. 15-17: https://isap.sejm.gov.pl/isap.nsf/download.xsp/WDU19830450207/U/D19830207Lj.pdf | Rozporządzenie Ministra Finansów z dnia 28 czerwca 2023 r. (Dz. U. 2023 poz. 1226), issued under art. 17 ust. 4 — §2 is the OPERATIVE tax scale (11,833 / 23,665 zł cutoffs; Group III 12/16/20%), superseding the pre-2023 table still printed in art. 15 ust. 1; note its §1 pkt 2 kwoty wolne are themselves superseded by art. 9 ust. 1 of the Act: https://isap.sejm.gov.pl/isap.nsf/download.xsp/WDU20230001226/O/D20231226.pdf | cross-checked against podatki.gov.pl 'Stawki i limity' (https://www.podatki.gov.pl/podatki-osobiste/sd/stawki-i-limity), which carries a typo in the Group I second-band flat ('355 zł 5 gr' vs the gazette's '355 zł')

• No step-up in basis on death: under IL 44 kap. 21 § the heir 'inträder i den tidigare ägarens skattemässiga situation' and takes over the deceased's acquisition cost, so death is not a realisation event but the accrued gain survives into the heir's hands and is taxed on their later sale at 30% (IL 65 kap. 7 §; 22/30 of the gain is quoted in for a private residence, IL 45 kap. 33 § — an effective 22%). Ember charges nothing at death, which is correct, but the amount shown as passing to heirs is gross of that deferred charge — a CGT-layer effect, not modelled in this pack. Assets held in Swedish schablon-taxed wrappers (ISK, kapitalförsäkring) are separately taxed and do not carry a realisation gain.
• Foreign death taxes on a Swedish resident's foreign-situs assets can still apply (e.g. UK IHT on UK situs, US estate tax on US situs) — charged by those countries' packs, not here. Sweden's own charge is nil in every case.
• Estate-tax treaty relief is not modelled anywhere in Ember, and Sweden's death-tax treaty network is uneven: the Sweden–UK convention on estate, inheritance and gift taxes (Lag (1988:593)) remains in force and allocates taxing rights over a Sweden-domiciled decedent's UK-situs property, whereas the Sweden–US convention (Lag (1983:914)) was repealed by SFS 2007:1257 from the end of 2007 and the Nordic convention (Lag (1989:899)) was repealed from 1 September 2007. Ember applies the situs jurisdiction's domestic rules with no treaty override in either direction.
• Lifetime gifts are untaxed (no gåvoskatt since the 2004:1341 repeal), but a gift of Swedish real property is recharacterised as a purchase and pays 1.5% stamp duty where the recipient assumes debt or pays consideration of at least 85% of the property's value (stämpelskattelagen (1984:404) 5 § and 8 § — 15 kr per full 1,000 kr for a natural person). Death transfers are outside the duty entirely (4 § lists only purchase, exchange, corporate contribution, expropriation and company division). No lifetime-gift track is modelled.
• Sweden holds an ordinary general election on 13 September 2026 (Vallagen (2005:837) 1 kap. 3 § — valdag is the second Sunday in September; four-year cycle per RF 3 kap. 3 §). Reintroducing arvsskatt is a recurring Swedish political proposal but is not law and no bill is pending — watch item only; re-check after the election, not at the nominal review date.
• spouseExempt=true is recorded for schema consistency with the other model-'none' packs; Sweden has no death-transfer tax, so there is no spousal exemption to apply and the flag is never read (the engine consults it only for model 'estate').

Source: Lag (1941:416) om arvsskatt och gåvoskatt — repealed: SFS register 'Upphävd 2005-01-01 / Författningen har upphävts genom SFS 2004:1341', repeal text 'skall upphöra att gälla vid utgången av år 2004' (Riksdagen, Källa: Fulltext (Regeringskansliet)): https://data.riksdagen.se/dokument/sfs-1941-416.html; Lag (2005:194) om undantag från arvsskatt och gåvoskatt (no tax where liability arose 17–31 Dec 2004): https://data.riksdagen.se/dokument/sfs-2005-194.html; Inkomstskattelag (1999:1229) 8 kap. 2 § (arv/testamente/gåva/bodelning receipts income-tax-free), 44 kap. 21 § (heir steps into the previous owner's tax position — no basis uplift), 65 kap. 7 § (30% state tax on capital income): https://data.riksdagen.se/dokument/sfs-1999-1229.html; Lag (1984:404) om stämpelskatt vid inskrivningsmyndigheter 4–5, 8 §§ (death transfers not dutiable; 'gift' with consideration ≥85% of value dutiable at 1.5%): https://data.riksdagen.se/dokument/sfs-1984-404.html; PwC Worldwide Tax Summaries — Sweden, Individual, Other taxes (secondary, corroborative only): https://taxsummaries.pwc.com/sweden/individual/other-taxes

• 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. What this pack can stand behind, checked 2026-08-07: nothing substantive has amended the Estate Duty Act 1929 since abolition — s.2A is unamended since [13/2008], and every post-2008 entry in the SSO legislative history is a revised-edition or publication-mechanics change (the most recent, Act 5 of 2025, is the Electronic Gazette and Legislation Act) — and SSO carries the Act as current as at 2026-08-07. Whether any BILL is pending was NOT swept, so read the absence of a pending measure as unverified rather than confirmed
• Stamp duty on a redirected estate distribution is not modelled: IRAS charges ad valorem stamp duty (BSD, and ABSD where applicable) on a 'distribution from the estate of a deceased that is not in accordance with the Will, Intestate Succession Act or Muslim Law of Inheritance', and on a deed of disclaimer made in favour of a specific person rather than back to the estate. A distribution that follows the will or the intestacy rules is not dutiable (a Will is a non-dutiable document). BSD on residential property is 1-6% of the higher of price or market value; ABSD can stack on top. Ember models no stamp duty in any jurisdiction.
• Inheriting Singapore residential property is untaxed at the point of transfer but is not consequence-free, and this is not modelled: IRAS counts property 'acquired or transferred by way of gift, inheritance, release, settlement, declaration of trust ... and exchange' in the ABSD property count, so an inherited home raises the heir's Additional Buyer's Stamp Duty rate on every later Singapore residential purchase (rates on or after 27 Apr 2023: Singapore Citizen 20% on a second property and 30% on a third or subsequent; Singapore PR 30% and 35%; foreigners 60%; entities 65%). Ember models no stamp duty.
• Lifetime transfers are not modelled and Singapore's answer differs sharply from its death answer: there is no gift tax, but a gift of Singapore property (including a voluntary declaration of trust or settlement) attracts ad valorem stamp duty on market value, and transferring residential property into a living trust attracts ABSD (Trust) at 65% from 27 Apr 2023 (35% from 9 May 2022), payable upfront and remittable to the beneficial owner's own ABSD rate only where the beneficiaries are identifiable individuals and a refund is claimed within six months of execution. Ember models no stamp duty and no lifetime-gifting strategy.

Source: Estate Duty (Abolition) Act 2008 (Act 13 of 2008), Acts Supplement 16 Sep 2008, s.2 — inserted s.2A into the Estate Duty Act 1929: 'This Act shall apply only in relation to persons dying before 15 February 2008' (effect retrospective to 15 Feb 2008; annotation [13/2008]). The Estate Duty Act 1929 was NOT repealed and remains a current Act (SSO status 'Current version as at 07 Aug 2026'), merely disapplied to later deaths. https://sso.agc.gov.sg/Act/EDA1929 · Corroborated by IRAS — Estate Duty: 'Estate Duty has been removed for deaths occurring on and after 15 Feb 2008.' https://www.iras.gov.sg/taxes/other-taxes/estate-duty (accessed 2026-08-07)

• Scope is not modelled and the engine taxes the whole worldwide estate, which overstates Thai tax for every cohort. The Act reaches only five statutory asset classes (immovable property; securities under the securities law; deposits and equivalent monies; registered vehicles; and financial assets to be prescribed by Royal Decree — no such decree has issued), so cash, bullion, jewellery, art, unregistered chattels and business goodwill are outside the base entirely. Reach then depends on the RECIPIENT: a Thai national, or a non-Thai national with a domicile in Thailand under the immigration law, is taxed on those asset classes wherever situated, in Thailand or abroad (s.14 para 2); any other non-Thai recipient is taxed only on Thai-situs assets, which the situs regulation defines as Thai immovable property, securities issued by a juristic person registered or established in Thailand, deposits in Thailand, and vehicles registered in Thailand. The pack has no recipient-nationality or situs axis, so it cannot express either boundary.
• the 5% ascendant group in s.16 (บุพการี) is wider than the engine's 'parent' class, which means mother or father only: a parent inheriting from a child now routes to its own entry at the statutory 5% with the full THB 100,000,000 allowance, but a grandparent or more remote ascendant still falls into the 10% 'other' class and is over-taxed by 5 percentage points — no workaround is modelled, because the relationship field also drives any other jurisdiction's leg of the same event (e.g. entering 'child' to fix Thailand would wrongly promote a foreign leg such as Ireland's to Group A instead of Group B)
• lifetime gifts are a separate, un-modelled base taxed through the Revenue Code, not this Act, and its allowances are ANNUAL rather than lifetime: s.42(27) exempts maintenance or gifts from an ascendant, descendant or spouse up to THB 20,000,000 in each tax year, s.42(28) exempts customary-occasion or moral-obligation gifts from anyone else up to THB 10,000,000 in each tax year, and s.42(26) exempts a gratuitous transfer of immovable property to a legitimate child (adopted children excluded) up to THB 20,000,000 per child in each tax year. The recipient may elect a separate 5% charge on the excess instead of aggregating it into the progressive income-tax scale (s.48(4/1), (6), (7)). Because the allowances renew annually and the immovable-property limb is per child, a staged lifetime giving programme can move materially more than this pack's THB 100,000,000 death allowance implies.
• filing/valuation mechanics (return within 150 days of receipt, official appraised values) not modelled
• Section 13 scope exclusions are not modelled: the THB 100,000,000 threshold rule does not apply at all to an heir the deceased intended to use the inheritance for religious, educational or public-benefit purposes, to state agencies and religious/educational/public-benefit juristic persons, or to persons and international organisations covered by Thailand's UN and reciprocal commitments (types and names set by ministerial regulation). A charitable bequest is taxed in full here.
• the THB 100,000,000 threshold is not fixed for the long run: s.12 para 3 requires it to be reviewed every five years against the Ministry of Commerce consumer price index, with any revision made by Royal Decree. No revision has issued as at this review, so the figure is live, but a projection decades out should not be read as a guaranteed nominal allowance.
• no basis step-up at death is modelled because Thailand has none: there is no capital gains tax as such, and on a later sale of immovable property acquired by inheritance or gift the Revenue Code (s.48(4)(a)) instead allows a flat 50% expense deduction, divides the balance by the years held (capped at ten), taxes that at the personal scale and multiplies back. Heirs do not receive a market-value cost base.
• juristic-person heirs are outside the relationship-class model: s.11 para 2 deems a company Thai — and therefore taxable on assets inside AND outside Thailand — where it is registered or established in Thailand, or Thai nationals hold more than 50% of paid-up capital, or more than half of those with managerial power are Thai. Assets left to a holding company are not modelled.

Source: Inheritance Tax Act B.E. 2558 (2015), Gazette Vol. 132 Part 72a, 5 Aug 2015 — s.3(2) spouse outside the Act, s.11 + s.14 para 2 taxpayer classes and worldwide/Thai-situs reach, s.12 THB 100,000,000 per decedent net of inherited liabilities, s.16 rates 5% ascendant/descendant, 10% otherwise. Thai Revenue Department law hub (Thai, authoritative): https://www.rd.go.th/61303.html; English texts (Act + Royal Decree + Ministerial Regulations): https://www.rd.go.th/english/27739.html; situs regulation: https://www.rd.go.th/fileadmin/user_upload/kormor/eng/ITA_Ministerial_Regulation_Subject_to_Inheritance_Tax.pdf

• 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% on the cumulative value donated since 1 March 2018 up to R30m and 25% above, with a R150,000 annual exemption per natural person (s56(2)(b)) effective 1 March 2026, raised from R100,000. It binds SA residents only — non-residents are not liable — and donations to a spouse are wholly exempt (s56(1)), the lifetime mirror of the s4(q) death exemption.
• 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
• Serial-marriage abatement apportionment (s4A(3)) not modelled: where the survivor was one of several spouses of a previously deceased person, the transferred abatement is shared and apportioned between them, whereas this model carries a single prior spouse. The unused-abatement mechanic of s4A(2) itself IS modelled — the second-death abatement is R7m less the amount effectively deducted at the first death, clamped so the reduction never exceeds R3.5m.
• Capital gains tax at death is not modelled: a person dying on or after 1 March 2016 is deemed by s9HA of the Income Tax Act to have disposed of their assets at market value on the date of death, so a ZA death triggers CGT (40% inclusion at marginal rates, max effective 18%) after an annual exclusion increased to R440,000 in the year of death — a charge that lands BEFORE estate duty and is itself deductible as a liability in arriving at the net value of the estate (s4(b)). Assets accruing to a surviving spouse who is a South African resident roll over at base cost instead (s9HA(2)). The heir/estate acquires at that market value, so there is a step-up in base cost. This model charges the 20% duty only, so total tax at death is understated and net to heirs overstated for anyone dying with unrealised gains.
• Deemed property (s3(3)) not modelled: SARS levies estate duty on 'the worldwide property AND DEEMED PROPERTY' of the deceased, which brings into the dutiable estate assets the deceased did not own at death — principally the proceeds of domestic life-insurance policies on the deceased's life (SARS notes the duty on a policy paid directly to a beneficiary is payable by that beneficiary), accrual claims of the estate, and property donated under a donatio mortis causa. This model's estate is assembled from investables, assets and property equity only and holds no life-cover component, so a deceased with South African life cover has a dutiable estate larger than the one modelled and the duty is understated.

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/, effective 25 Feb 2026); s4A/s4(q)/s3(2) text per the consolidated Estate Duty Act 45 of 1955; donations tax per https://www.sars.gov.za/types-of-tax/donations-tax/; CGT at death per SARS IT-GEN-06-G01 'Guide to the Individual ITR12 Return for Deceased and Insolvent Estates' (s9HA deemed disposal, spouse roll-over, R440,000 year-of-death exclusion) and https://www.sars.gov.za/tax-rates/income-tax/capital-gains-tax-cgt/; verified 2026-08-07

• documented in the dossier; not yet coded into an estate pack

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

• 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

• 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/

• 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/

• 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

• 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/

• 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

• 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/

• 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/

• 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/

• 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/

• 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

• 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/

• 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

• 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/

• 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

• 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/

• 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

• 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/

• 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/

• 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

• 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/

• 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

• 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/

• 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

• 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

• 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

• 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

• 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/

• 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

• 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

• 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/

• 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/

• 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

• 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

• 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/

• 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/

• 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/

• 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

• 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/

• 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/

• 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

• 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

• 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

• 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/

• 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/

• 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/

• 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/

• 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/

• 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

• 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/

• 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/

• subnational rates span 2–3.5% — the representative rate is wired

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

• 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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Source: Eurostat price-level index (illustrative)

Source: OECD/World Bank PPP (illustrative)

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

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

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

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

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

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

Source: World Bank PPP conversion factor / official exchange rate, 2024 (MY 0.3058 vs GB 0.8489 = 0.36 raw), adjusted to an expat-retiree basket on the TH/AE precedent (illustrative)

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

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

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

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

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

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

Source: World Bank PPP (illustrative)

Source: OECD PPP (illustrative)

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

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

• 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)

• 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

• 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

• 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

• 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)

• 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

• 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

• 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

• 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)

• 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

• 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)

• 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)

• 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)

• 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')

• 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)

• 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

• 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)

• 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)

• 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

• 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)

• 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

• 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

• 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

• 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)

• 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)

• 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 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)

• THE FSI EXEMPTION, AND ITS CLIFF: P.U.(A) 234/2022 exempts an individual's foreign-source income received in Malaysia, and P.U.(A) 451/2024 (made 11 Dec 2024, gazetted 24 Dec 2024, in operation 1 Jan 2027) substitutes '31 December 2036' for '31 December 2026' — so the exemption now runs 1 Jan 2022 to 31 Dec 2036. From YA2037, on the current law, remitted foreign pensions, dividends and rents become taxable at the resident progressive scale. Ember's MY pack has no territoriality axis and therefore charges the full scale on foreign-source income for EVERY year, including the exempt ones — a disclosed OVER-tax for a Malaysia-resident user living on foreign income (see the pack's knownUnsupportedRules).
• s.7(1)(d) can make a departing long-term resident RESIDENT for a year in which he sets foot in Malaysia not at all, if he was resident for the three preceding years and is resident again the following year — a returner's trap with no equivalent in the ES/PT rows.
• No exit tax, no emigration charge and no deemed disposal on ceasing Malaysian residence. The only departure-adjacent charge is RPGT on an actual disposal, and a non-citizen non-PR disposer sits in Schedule 5 Part III (30% for the first five years, 10% from the sixth) regardless of residence.
• MM2H is an IMMIGRATION status, not a tax status: it neither creates nor prevents s.7 residence and carries no special tax regime. Terms since the 2023/2024 MOTAC restructure: Silver (USD 150,000 fixed deposit, RM600,000 property purchase, 5-year pass), Gold (USD 500,000, RM1,000,000, 15 years), Platinum (USD 1,000,000, RM2,000,000, 20 years); property held ~10 years; up to 50% of the deposit releasable after year one against approved categories. Programme terms change often and were taken from converging immigration/press sources rather than the MOTAC portal — verify before relying on them.
• Foreign buyers of Malaysian residential property pay a FLAT 8% stamp duty on transfer from 1 January 2026 (Stamp Act 1949 First Schedule item 32(ab), inserted by Finance Act 2025 [Act 874] s.29), up from 4%, and face state-level minimum-purchase-price thresholds. Modelled in propertyFees.

Source: LHDN — Residence Status (ITA 1967 s.7(1)(A)-(D)), last updated 2026-06-18; Income Tax Act 1967 [Act 53], consolidated text (LHDN) — ss.3, 7, 21, 46(1), Schedule 1 Part I para 1A; Malaysia–UAE DTA, P.U.(A) 127/1996, Art. 4 (Resident) and Art. 18 (Pension and Annuities); P.U.(A) 451/2024 — Income Tax (Exemption) (No. 5) Order 2022 (Amendment) Order 2024, extending the individual foreign-source-income exemption to 31 Dec 2036

• 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)

• 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 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

• 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

• 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 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)

• 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)

• 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)

• 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)

• 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)

• 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

• 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 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)

• 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

• 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)

• 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

• 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

• 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)

• 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

• 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

• 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)

• 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)

• 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 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

• 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

• The full-window 2.1%/yr conceals a sharp deceleration: 1.61%/yr real over 2015Q1-2026Q1 and 0.90%/yr over 2020Q1-2026Q1, with NAPIC's own 2025 print at +2.6% NOMINAL (~+0.6-1.1% real) and Q4 2025P at +1.47% y/y. Most of the long-window growth is the 2009-2014 boom (2010Q1-2026Q1 measures 3.63%/yr). The 1997-98 Asian crisis cut the real index ~19% (106.37 -> 86.06) and it took until ~2007 to recover. A forward default anchored on the last decade would be ~1.5; 2.1 is the file's clamp formula applied to the whole series and is the OPTIMISTIC end of the defensible range for Malaysia.

Source: BIS Data Portal — Malaysia, Selected residential property prices, Real, Index 2010 = 100 (Q.MY.R.628); BIS SDMX API — full series CSV (Q.MY.R.628, 1988Q1-2026Q1); NAPIC/JPPH — Indeks Harga Rumah Malaysia / Malaysian House Price Index 2025P (MHPI 233.1, +2.6% y/y; average transacted price RM502,922)

• 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

• 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

• 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 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)

• 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

• 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)

• 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)

• 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

• 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 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

• 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)

• 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)

• 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

• 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

• 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)

• 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

• 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

• 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)

• 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

• 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

• 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

• 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

• 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)

• 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

• 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)

• 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)

• 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)

• Contributory earnings-related benefit. Post-70 deferral adds nothing.

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

• 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

• 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

• 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)

• 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

• 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

• 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)

• 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)

• 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

• 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)

• 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

• 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

• 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

• 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

• 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

• 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

• 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

• 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

• 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

• 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