Countries that tax worldwide income
36 destinations in ExpatLedger tax residents on worldwide income — income is in scope wherever it arises, with double-tax treaties giving credit or exemption for foreign tax already paid. This group includes most of Western Europe (Germany, France, Spain, the Nordics) plus Canada, Australia and Brazil. Several still offer a special regime that shelters foreign income for qualifying new arrivals for a few years. Sorted by top rate. Headline rules, 2026; not tax advice.
Source: PwC Worldwide Tax Summaries. Data as of June 2026.
Worldwide-tax destinations (36), highest top rate first
| Country | Top income tax | Special regime | Foreign pension |
|---|---|---|---|
| Denmark | 55.9% | Researcher / key-employee scheme | Taxed as personal income at progressive rates (up to ~52% before labour-market contribution); foreign pensions reportable with treaty relief |
| Austria | 55% | Zuzugsbeguenstigung (researchers/experts) | Foreign/private pension of a resident is generally taxed as ordinary income at progressive rates up to 55% (treaties may reduce/exempt) |
| Sweden | 52% | Expert tax relief (expertskatt) | Taxed as ordinary income at municipal (~32%) + state (20% above SEK 643,000) progressive rates; treaty may reallocate taxing rights |
| Finland | 52% | Foreign key-employee source tax | Earned-income pensions taxed at progressive national + municipal rates; foreign pensions reportable with treaty relief |
| Belgium | 50% | Inbound taxpayers regime (STRIT) | Foreign/private pension of a resident is in principle taxable (often at progressive rates; treaties and pension type can shift or reduce this) |
| Netherlands | 49.5% | 30% ruling (moving to 27%) | Foreign/private pension of a resident is generally taxed as Box 1 income at progressive rates up to 49.5% (treaty may reassign taxing rights) |
| Portugal | 48% | IFICI (NHR successor) | Taxed at ordinary progressive IRS rates (up to 48% + solidarity surcharge) — the old NHR 10% pension rate is gone for new arrivals; even under IFICI, foreign pensions are NOT exempt |
| Norway | 47.4% | PAYE scheme for foreign workers | Taxed as ordinary/personal income (22% general + progressive bracket tax); foreign pensions reportable with treaty relief |
| Spain | 47% | Beckham Law (regimen de impatriados) | Ordinary residents: foreign pensions taxed at general progressive rates (up to ~47%, varies by autonomous community). Under Beckham: a foreign private pension is generally outside Spanish tax (only Spanish-source income taxed) |
| Israel | 47% | New immigrant (Oleh) 10-year exemption | Taxable; immigrants/returning residents may elect relief (lower of a 35% exemption or tax capped at source-country liability) |
| France | 45% | Regime des impatries (Art. 155 B CGI) | Generally taxable in France as resident income, but treaty-dependent — under the France-US treaty US-source pensions (incl. IRA/401k) are declared in France but effectively credited so no double tax |
| Germany | 45% | None | Treaty-dependent — typically exempt-with-progression under the applicable double-tax treaty, or taxed in Germany with a foreign-tax credit where the treaty so allows |
| Australia | 45% | Temporary resident exemption | Generally assessable as income; no flat exemption, but the undeducted purchase price portion is deductible |
| Greece | 44% | 7% pensioner flat tax / non-dom EUR 100k | Normally taxed on the 9%-44% progressive scale; under the pensioner regime a flat 7% on all foreign-source income (incl. pension) for up to 15 years |
| Italy | 43% | Lump-sum flat tax + impatriate regime | Ordinary residents: foreign pensions at progressive IRPEF (top 43% + regional/municipal surcharges). A separate 7% flat regime exists for foreign pensioners moving to small towns in southern Italy. |
| Turkey | 40% | Law No. 7582 foreign-income exemption | Part of the worldwide tax base, but typically taxable only in Turkey under treaty pension articles; exemption is treaty-conditional |
| Colombia | 39% | None | Taxable as ordinary income at progressive rates up to 39%; a partial exemption applies to pension income up to 1,000 UVT/year |
| New Zealand | 39% | Transitional resident exemption | Regular foreign pensions/annuities are fully taxable; foreign superannuation withdrawals/transfers taxed under the foreign super regime |
| United States | 37% | FEIE / FTC for citizens abroad | Taxable as ordinary income (treaty may reallocate; foreign tax credit available) |
| Ecuador | 37% | 5-year new-resident territorial election | Taxable as part of worldwide income at progressive rates up to 37%, with a foreign tax credit capped at the Ecuadorian tax on that income |
| Cyprus | 35% | Non-dom (17 years) + expat exemptions | Foreign pensions taxed either at a flat 5% over EUR 3,420/yr or under the normal scale (taxpayer's annual election) |
| Mexico | 35% | None | Taxable as income in the annual return (treaty/FTC relief may apply) |
| Argentina | 35% | None | Taxable as part of worldwide income at progressive rates up to 35%, with a foreign tax credit for foreign tax paid |
| Vietnam | 35% | None | Foreign pension of a resident is taxable worldwide income; taxed at progressive rates (5-35%) |
| Latvia | 33% | None | Taxed as ordinary income at 25.5%; pensioners get a raised allowance (about EUR 12,000/yr) so only the excess is taxed |
| Croatia | 33% | Returning-emigrant 5-year exemption | Foreign pensions of residents are taxed like Croatian pensions, but a 50% reduction on the calculated pension tax gives low effective rates (~10-15%) |
| Canada | 33% | None | Taxable as income; treaty/FTC relief, foreign-pension exemptions and pension-splitting may apply |
| Puerto Rico | 33% | Act 60 (formerly Acts 20/22) | Taxed as ordinary income under the PR Internal Revenue Code (regular brackets, top 33%), unless covered by an incentive decree |
| Poland | 32% | Ulga na powrot + lump-sum option | Taxed as ordinary income on the progressive 12% / 32% scale where the treaty assigns the taxing right to Poland |
| Brazil | 27.5% | None | Taxable as ordinary income at progressive rates up to 27.5%, declared/paid monthly via carne-leao |
| Czech Republic | 23% | None | Taxed as ordinary income at 15% / 23%, but only where the applicable treaty gives Czechia the taxing right |
| Estonia | 22% | None | Included in worldwide income and taxed at the flat 22% |
| Switzerland | 11.5% | Lump-sum taxation (forfait fiscal) | Foreign private/occupational pension of a resident is taxable as ordinary income (worldwide), at combined federal+cantonal+communal rates |
| Andorra | 10% | Passive (non-lucrative) residency | Included in worldwide income, taxed on the IRPF scale (0% up to EUR 24,000, 5% to 40,000, 10% above EUR 40,000) |
| Bulgaria | 10% | None | Taxed at the standard 10% flat rate (no dedicated pension regime); most treaties assign pension taxing rights to Bulgaria as residence country |
| Romania | 10% | None | Pension income (Romanian and foreign) taxed at 10% on the amount exceeding a non-taxable monthly threshold (RON 3,000) |
Source: PwC Worldwide Tax Summaries. Data as of June 2026.
How treaties soften worldwide taxation
Worldwide taxation does not mean double taxation. A double-tax treaty assigns the taxing right between your new home and the source country, and you usually get a credit for foreign tax already paid or an exemption with progression. The real bite is on income from a no-tax source (e.g. a tax-free capital gain abroad), which a worldwide-tax country can still tax in full. Read territorial vs worldwide taxation for the mechanics.
Frequently asked questions
Which countries tax worldwide income?
Most developed economies tax residents on worldwide income — among the 36 in our dataset are Germany, France, Spain, Portugal, Sweden, Denmark, the Netherlands, Canada, Australia, Norway and Brazil. A resident is taxed on income wherever it arises, with double-tax treaties giving credit or exemption for foreign tax already paid.
Can I avoid worldwide taxation with a special regime?
Sometimes. Several worldwide-tax countries layer a special regime on top — Spain's Beckham Law, Portugal's IFICI, Italy's lump-sum flat tax, Greece's pensioner regime — that effectively exempts much foreign income for qualifying new arrivals, for a limited number of years. After the regime ends, full worldwide taxation resumes.
Is the United States the only country that taxes by citizenship?
Essentially yes. The US taxes its citizens on worldwide income no matter where they live (Eritrea is the only other notable example). Everywhere else, worldwide taxation applies only while you are tax resident — leave and become non-resident, and the country generally stops taxing your foreign income (subject to exit taxes).
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Last updated: 2026-06-21