Turkey vs UAE vs Italy vs Greece: choosing where to become tax resident in 2026
Four countries come up most often for people deciding where to be tax resident: Turkey, the UAE, Italy and Greece. They solve the same problem in very different ways — a statutory exemption, no income tax at all, or a fixed annual payment. This comparison sets out the figures as of October 2026, the conditions attached, and what each option does not do.
The short version
| Turkey | UAE | Italy | Greece | |
|---|---|---|---|---|
| Foreign income | Exempt from Turkish income tax, up to 20 years | No personal income tax | Flat €300,000 a year covers all foreign income (new residents from 2026) | Flat €100,000 a year covers all foreign income |
| Duration | Up to 20 years | No limit (no tax) | Up to 15 years | Up to 15 years |
| Family | Each person qualifies in their own right if resident | n/a | €50,000 per family member (from 2026) | €20,000 per family member |
| Local income | 15–40% | No personal income tax | Normal Italian rates | Normal Greek rates |
| Entry condition | Become tax resident; no Turkish employment/business in prior 3 years; certificate by deadline | Residence visa; meet a residency test | Not Italian resident in 9 of the previous 10 years | Not Greek resident in 7 of the previous 8 years; €500,000 investment |
| Inheritance / gift | 1% for regime beneficiaries | No inheritance tax | Foreign assets exempt from Italian inheritance and gift tax under the regime | Foreign assets exempt from Greek inheritance and gift tax under the regime |
| Path to citizenship by investment | Yes, $400,000 real estate, 9–12 months | No | No | No (Golden Visa is residence only) |
Figures for Italy, Greece and the UAE were checked against professional and press sources in October 2026; see the caveats in each section. None of this is advice for your situation.
Turkey: an exemption for new residents
Under Law No. 7582 (published 4 June 2026), a new Turkish tax resident pays no Turkish income tax on foreign-source income and gains for up to 20 years, and inheritance and gift tax at 1%. There is no annual lump sum. Conditions: you must actually become tax resident (more than 183 days in a calendar year and centre of life in Turkey), you must not have worked or run a business in Turkey in the previous three years, and you must obtain a certificate from the tax office by 31 December of the year you become resident (end of February for November–December movers), per GIB guide No. 616.
What it does not do: Turkish-source income is taxed at 15–40%; foreign withholding taxes remain. The practice of the tax authority is still young. Turkey is the only one of the four with a direct route to citizenship by investment ($400,000 in real estate).
UAE: no personal income tax
The UAE levies no personal income tax, no capital gains tax on individuals and no inheritance tax. A 9% corporate tax applies to business profits above a threshold since 2023, which matters if your income runs through a UAE company.
Tax residency for individuals is defined by Cabinet Decision No. 85 of 2022 (in force from 1 March 2023). You are resident if you meet any one of three tests:
- your usual or primary place of residence and centre of financial and personal interests is in the UAE; or
- you were physically present for 183 days or more in a consecutive 12-month period; or
- you were physically present for 90 days or more in a consecutive 12-month period, are a UAE or GCC national or hold a valid UAE residence permit, and either have a permanent place of residence in the UAE or are employed or run a business there.
A tax residency certificate is what other countries' tax authorities and banks usually ask for. What the UAE does not give: a citizenship route. Residence visas (including the 10-year Golden Visa, from about AED 2 million in property) are renewable residence permits.
Italy: a flat tax on foreign income — now €300,000
Italy's regime for new residents (article 24-bis of the income tax code) replaces Italian tax on all foreign income with a fixed annual payment, for up to 15 years. The amount has risen twice:
- €100,000 a year when introduced in 2017;
- €200,000 for those moving after 10 August 2024;
- €300,000 a year for those becoming resident from 1 January 2026, under the 2026 Budget Law approved at the end of December 2025. The supplement for each qualifying family member rose from €25,000 to €50,000. Existing beneficiaries keep the amount that applied when they joined.
Conditions: you must not have been Italian tax resident in at least 9 of the previous 10 years. Italian-source income is taxed at normal progressive rates. Foreign assets are outside Italian inheritance and gift tax while the regime applies, and the foreign asset wealth taxes and reporting are not required. A proposal to link access to an investment in Italy was discussed during the budget process and, according to the sources we checked, dropped.
Italy makes sense when foreign income is very large: at €300,000 a year, the break-even against ordinary Italian rates sits well into seven figures of foreign income.
Greece: €100,000 a year, with an investment
Greece's non-dom regime (article 5A of the Income Tax Code, Law 4172/2013) replaces Greek tax on foreign income with a lump sum of €100,000 a year, regardless of the amount, for up to 15 years. Family members can be added for €20,000 each a year. Foreign assets are exempt from Greek inheritance and gift tax.
Conditions: not Greek tax resident in 7 of the previous 8 years, and an investment of at least €500,000 in Greece (real estate, businesses or securities) within three years of applying. Greek-source income is taxed at normal rates. The Golden Visa is a residence permit only and its property thresholds were raised in 2024 to €400,000–800,000 depending on location; it is a separate programme from the 5A tax regime.
A note on Cyprus
Cyprus is often in the same conversation. A tax resident who is not Cyprus-domiciled is exempt from Special Defence Contribution on dividends and interest, for up to 17 of 20 years. Residency can be obtained under a 60-day rule with ties to Cyprus. A 2026 reform changed several elements, including the 60-day test and an option to extend non-dom status for a fee; secondary sources describe the details inconsistently, so check the current text with a Cypriot adviser.
How to choose
- Very large foreign income, EU lifestyle, no passport needed: Italy or Greece, where a fixed payment caps the tax. Compare the €300,000 (Italy) and €100,000 + €500,000 investment (Greece) against your income.
- Absolute zero now, minimal presence, no citizenship goal: the UAE.
- Mainly foreign income, a second passport for the family, 1% on inheritance, willing to live in the country: Turkey — with the caveat that its regime is new and the practice still forming.
- Income arising in the new country itself: none of the foreign-income regimes help; compare ordinary local rates.
Frequently asked questions
How much is Italy's flat tax for new residents in 2026?
€300,000 a year on foreign income for people becoming resident from 1 January 2026, plus €50,000 per family member, for up to 15 years. Earlier entrants keep €100,000 or €200,000.
What does Greece's non-dom regime cost?
€100,000 a year (€20,000 per family member) for up to 15 years, with a €500,000 investment in Greece.
How do you become tax resident in the UAE?
By meeting one of three tests: primary residence and centre of interests in the UAE; 183 days in a 12-month period; or 90 days with a UAE residence permit (or UAE/GCC nationality) plus a permanent home or work/business in the UAE.
Which of these countries offers citizenship by investment?
Only Turkey: $400,000 in real estate, typically 9–12 months.
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This article is general information, not tax, legal or investment advice. Tax consequences depend on your individual circumstances and on the rules of the country where you are currently tax resident. Laws, rates and government programme terms change; figures are current as of the publication date. Take advice from qualified professionals before acting.