Tax rulings: how some countries negotiate tailor-made tax regimes for wealthy expatriates in 2026

When a French billionaire moves to Belgium, Italy, or Portugal, they don't pay the same taxes as everyone else. They negotiate. A phone call to the right person, a specialized law firm, a discreet meeting with the tax authorities—and a few weeks later, a confidential document is signed: a tax ruling. A tailor-made tax agreement that guarantees the wealthy taxpayer preferential tax treatment, validated in advance by the administration, and often inaccessible to ordinary people. Welcome to the world of negotiated tax rulings—the tax optimization of the ultra-rich.

This guide explains what tax rulings are, how they work, which countries offer them, for what type of taxpayer, at what cost, and why Paraguay offers a radically different alternative—a tax advantage that requires no negotiation, no €1,000/hour lawyers, and no preferential treatment. Paraguayan territoriality is a universal 0% tax ruling—for everyone, not just billionaires.

Tax rulings: the tax privilege of the ultra-rich

Definition

A tax ruling (rescrit fiscal, advance ruling, ruling anticipé) is an advance decision from the tax administration that confirms the tax treatment applicable to a specific situation of a taxpayer. In other words: you ask the tax authorities "if I do X, how much tax will I pay?" and the tax authorities respond in writing, in a binding manner.

Tax rulings exist in most developed countries—including France (rescrits, articles L.80 A and L.80 B of the Tax Procedure Book). But in some countries, tax rulings go much further: they don't just confirm the application of the law—they negotiate preferential treatment that goes beyond (or below) what the law normally provides.

The two types of tax rulings

Type	Confirmation ruling	Negotiation ruling
Principle	The administration confirms how existing law applies to your specific situation.	The administration negotiates preferential tax treatment, sometimes derogating from common law.
Who benefits	Any taxpayer can request a confirmation ruling (in France: article L.80 B).	Mainly the ultra-rich, multinationals, and wealthy expatriates who bring "economic benefit" to the host country.
Examples	Ruling on the tax treatment of a real estate transaction, confirmation of the applicable tax exemption scheme.	Swiss lump-sum taxation, Belgian ruling on expatriates, Italian agreement on the €100,000 flat tax.
Transparency	Generally public or accessible (case law on rulings).	Often confidential (except LuxLeaks and scandals that forced transparency via DAC3).
Cost of obtaining	Free (administrative request) or low (a few hundred euros for a lawyer).	High: €10,000-100,000+ in fees for specialized tax lawyers.

It's the negotiation ruling that interests us here—because it's what European countries use to attract wealthy taxpayers, and it's what creates a two-tier tax system: one for the rich (negotiated rate of 5-15%), one for everyone else (standard rate of 30-55%).

Countries that negotiate tax rulings for wealthy expatriates

Country 1: Switzerland—the lump-sum taxation

• The mechanism: "lump-sum taxation" (Besteuerung nach dem Aufwand—taxation by expenditure) allows wealthy foreigners who settle in Switzerland to pay tax not on their actual income but on their living expenses (rent, food, travel, leisure). The lump sum is negotiated with the cantonal administration.
• Who benefits: wealthy foreigners who do not engage in gainful activity in Switzerland. Condition: declared expenses must be at least 7x the annual rent (or a cantonal floor of CHF 250,000-400,000 depending on the canton). In practice: the lump sum is accessible to people who spend CHF 300,000-1,000,000+ per year.
• Result: a billionaire with CHF 50 million in annual income who declares CHF 500,000 in expenses pays tax on CHF 500,000 (not on CHF 50 million). Effective rate: < 1%. This is legal, negotiated, and reserved for the very rich.
• Cost of access: fees for Swiss tax lawyers for negotiating the lump sum: CHF 20,000-100,000. Plus the rent for the Swiss residence (often CHF 5,000-20,000/month in attractive cantons). Plus the lump sum tax itself (CHF 250,000-1,000,000+ per year).
• Trend: several cantons have abolished lump-sum taxation (Zurich, Basel-Stadt, Schaffhausen) following popular votes. Cantons that maintain it (Vaud, Valais, Geneva, Graubünden, Ticino) have tightened conditions. Swiss lump-sum taxation is an eroding advantage.

Country 2: Belgium—the expatriate ruling

• The mechanism: Belgium historically offered a special tax status for "foreign executives" (expatriates sent to Belgium by their international employer). The status allowed a portion of the salary to be considered "employer's own expenses" (non-taxable) and excluded foreign income. Since 2022, the new "special tax regime for impatriate taxpayers and impatriate researchers" (RSII) has replaced the old system.
• RSII (since 2022): 30% exemption from gross salary (capped at €90,000/year exemption) for foreign executives coming to work in Belgium. Conditions: gross salary > €75,000/year, recruitment from abroad, specific skills. Duration: 5 years (renewable 3 years = 8 years max).
• The classic Belgian ruling: beyond the RSII, wealthy taxpayers can request an advance ruling from the Service for Advance Decisions (SDA) to confirm the tax treatment of complex structures (holding, foreign income, capital gains). The SDA publishes advance decisions that provide legal certainty to the taxpayer—but these rulings are not "negotiations" in the Swiss sense of the term. It's a confirmation of the law, not a derogation.
• Cost of access: lawyer's fees for the Belgian ruling: €5,000-30,000. The RSII is accessible via the employer (no direct cost for the employee, but requires an employer who structures the expatriation).

Country 3: Italy—the €100,000 flat tax

• The mechanism: since 2017 (article 24-bis TUIR), Italy has offered a "new residents regime" (regime dei neo-residenti) that allows wealthy foreigners who transfer their residence to Italy to pay a flat tax of €100,000/year on all their foreign income. Italian income remains taxed normally.
• Who benefits: individuals who have not been Italian tax residents for at least 9 of the previous 10 years. No minimum income requirement—but with a flat tax of €100,000/year, the regime is only worthwhile for very high incomes (> €500,000/year at a minimum, ideally > 1 million).
• Family extension: each family member who transfers their residence to Italy can benefit from the regime for an additional €25,000/year per person.
• Duration: maximum 15 years. After 15 years, return to the normal Italian regime (progressive tax scale up to 43% + local surcharges).
• Cost of access: the flat tax itself (€100,000/year) + fees for Italian tax lawyers (€10,000-30,000 for structuring and ruling application) + cost of living in Italy (significantly higher than in Paraguay).

Country 4: Greece—the €100,000 flat tax (inspired by Italy)

• The mechanism: since 2020, Greece has offered a regime similar to Italy for "high net worth individuals" (HNWI) who transfer their residence to Greece: a flat tax of €100,000/year on foreign income (+ €20,000/year per additional family member). Greek income is taxed normally.
• Conditions: not having been a Greek tax resident for 7 of the last 8 years. Investment of at least €500,000 in Greek assets (real estate, business, government bonds).
• Duration: 15 years.
• Alternative for retirees: Greece also offers a specific regime for foreign retirees: a 7% flat tax on foreign pensions for 15 years. More accessible than the HNWI regime.
• Cost of access: flat tax €100,000/year + €500,000 investment + lawyers €10,000-20,000.

Country 5: Portugal—the ex-NHR (dead and buried)

• The historical mechanism: the NHR (Non-Habitual Resident) regime offered a 20% rate on certain Portuguese-sourced income and a total exemption on certain foreign income (pensions, dividends, capital gains) for 10 years. It was THE tax regime that attracted tens of thousands of French, Scandinavian, and British people to Portugal.
• The end of NHR: Portugal abolished the NHR for new applicants from January 1, 2024 (existing beneficiaries retain their rights for the remaining duration of their 10 years). The replacement—a regime for "researchers and scientific professionals"—is much more restrictive.
• Lesson: the NHR illustrates the risk of tailor-made regimes: they can be abolished overnight by political decision. Thousands of expatriates who had structured their lives around the NHR found themselves without a safety net when the regime was abolished.

Country 6: Malta—the non-dom regime

• The mechanism: Malta applies a "remittance basis" system for non-domiciled residents (non-dom). Foreign income not remitted to Malta is not taxed. Remitted income is taxed at the Maltese rates (0-35%). The minimum tax is €5,000/year (the non-dom must pay at least €5,000/year in tax in Malta).
• The Global Residence Programme: a specific status for non-EU nationals that offers a 15% rate on remitted foreign income (minimum €15,000/year in tax). Condition: purchase or rental of real estate in Malta (purchase > €275,000 or rental > €9,600/year).
• Cost of access: minimum tax €5,000-15,000/year + real estate (purchase €275,000+ or rental €10,000+/year) + lawyers €5,000-15,000.

Country 7: United Kingdom—the ex-non-dom (disappearing)

• The historical mechanism: the British non-dom status allowed "non-domiciled" residents (born outside the UK or whose father was not UK domiciled) to pay tax only on income remitted to the UK (remittance basis). Foreign income not remitted was exempt. After 7 years of residency, an annual charge of £30,000 was applied (£60,000 after 12 years).
• The 2025 reform: the British government has announced the gradual abolition of non-dom status from April 2025. Existing non-doms benefit from a transitional regime, but the status is gradually being phased out for new arrivals.
• Lesson: like the Portuguese NHR, the British non-dom illustrates the fragility of negotiated regimes—they are easy political targets ("rich foreigners don't pay their fair share") and can be abolished by a change of government.

The real cost of tax rulings: what no one tells you

The financial cost

Country	Regime	Minimum annual cost	Lawyers/setup	Required real estate	Limited duration
Switzerland	Lump-sum taxation	CHF 250,000-1,000,000+	CHF 20,000-100,000	Yes (primary residence)	No (but cantons are abolishing it)
Italy	Flat tax neo-residenti	€100,000	€10,000-30,000	No (but high cost of living)	15 years max
Greece	Flat tax HNWI	€100,000	€10,000-20,000	Investment €500,000 in Greece	15 years max
Malta	Global Residence Programme	€15,000	€5,000-15,000	Purchase €275,000+ or rental €10,000+/year	No (as long as conditions are met)
Belgium	RSII impatriates	Variable (30% exemption)	€5,000-30,000	No	8 years max
Paraguay	Territoriality (no ruling)	€0 on foreign income	€0 (no negotiation)	No	Unlimited

Swiss lump-sum taxation costs CHF 250,000-1,000,000+ per year. The Italian flat tax costs €100,000 per year. The Greek regime requires an investment of €500,000. Malta requires €275,000 in real estate. Paraguayan territoriality costs €0/year on foreign income—with residency starting at €1,400 (one-time). The differential is staggering.

The hidden cost: political dependence

The most significant cost of tax rulings is not financial—it's political dependence. Every tailor-made regime can be abolished by a parliamentary vote:

• Portugal NHR: abolished in 2024. Thousands of expatriates affected.
• British non-dom: abolished in 2025. Thousands of expatriates affected.
• Swiss lump-sum taxation: abolished in 5 cantons. Under discussion in others.
• Italian flat tax: proposals for abolition or increase (to €200,000) regularly circulate in the Italian Parliament.
• The Greek regime: created in 2020, no guarantee of longevity beyond a few years.

These regimes are political tools—created to attract the rich, and abolished when the political winds change (populist pressure, revenue needs, media scandals). An expatriate who structures their life around a tax ruling is playing political roulette.

Paraguayan territoriality is NOT a tax ruling. It is a constitutional tax system that applies to all residents, enshrined in law (6380/2019), and rooted in the country's political culture for decades. Changing it would require a major legislative reform—not a simple budget vote. The risk of abolition is incomparably lower than that of a special European regime.

The hidden cost: unequal access

Tax rulings create a two-tier tax system:

• The ultra-rich: have access to Swiss lump-sum taxation (minimum CHF 250,000), the Italian flat tax (€100,000/year), the Greek regime (€500,000 investment). They pay an effective rate of 1-5% on millions of income.
• The "normally rich": an entrepreneur earning €200,000/year cannot access Swiss lump-sum taxation (floor too high) or the Italian flat tax (€100,000/year = half of their income). They pay the standard rate: 35-50%.
• The middle class: an employee earning €50,000/year pays 30-40% tax and has no access to any special regime. They finance public services that the ultra-rich with lump-sum taxation do not.

Paraguayan territoriality is universally accessible. Whether you earn €30,000/year or €30 million/year, the treatment is the same: 0% on foreign income. No floor, no minimum investment, no €50,000 lawyer. A freelancer earning €50,000/year benefits from the same 0% as a millionaire earning €5,000,000/year. It's an egalitarian system—ironically more egalitarian than the European systems that claim to be.

LuxLeaks and the forced transparency of tax rulings

The scandal that changed everything

In 2014, the LuxLeaks scandal revealed that Luxembourg had granted ultra-advantageous tax rulings to hundreds of multinationals (Apple, IKEA, Amazon, FedEx, Pepsi)—reducing their effective corporate tax rate to 0.5-3%. These rulings were confidential, negotiated on a case-by-case basis, and often contradicted the spirit of the law.

Consequences of LuxLeaks:

• DAC3 (2015): the EU adopted the automatic exchange of tax rulings between member states. All rulings granted by an EU country are now communicated to the tax administrations of other member states. Confidentiality is over.
• European Commission investigations: The Commission opened investigations into Luxembourgish, Irish, and Dutch tax rulings—classifying some as illegal state aid (violation of competition law). Apple was ordered to repay €13 billion in tax advantages to Ireland (decision annulled then reinstated by the CJEU in 2024).
• Political pressure: The LuxLeaks fueled the "rich don't pay their fair share" narrative and accelerated BEPS reforms, successive DACs, and pressure on preferential tax regimes.

The impact on tax rulings for individuals

The LuxLeaks primarily concerned multinationals, but the shockwave affected tax rulings for individuals:

• Countries are more cautious in granting individual rulings (risk of media scandal).
• Rulings are more standardized and less "negotiated" (the Italian flat tax at €100,000 is a fixed rate, not a case-by-case negotiated amount—unlike the Swiss lump-sum).
• Access conditions are stricter and durations are limited (15 years for Italy and Greece, 8 years for Belgium).
• The trend is towards the abolition of regimes deemed "unfair" (NHR Portugal, non-dom UK, Swiss lump-sum in certain cantons).

The era of tailor-made tax rulings for the ultra-rich is coming to an end in Europe. The regimes that remain are under constant political pressure and could be abolished at any time. This is an environment of uncertainty—the opposite of what a rational investor seeks.

The decisive comparison: European tax ruling vs. Paraguayan territoriality

Criterion	European tax ruling (best case)	Paraguayan territoriality
Rate on foreign income	Fixed lump-sum (€100,000/year Italy/Greece) or negotiated (Switzerland)	0% (pure territoriality, no lump-sum)
Access cost	€10,000-€100,000 in lawyers' fees + €275,000-€500,000 investment	€1,400 (residence) + ~€5,000 (US LLC + setup)
Annual cost	€15,000-€1,000,000/year (lump-sum tax)	~€360/year (DNIT accounting)
Duration	Limited (8-15 years) then return to normal regime	Unlimited (as long as you are a PY resident)
Stability	Fragile (can be abolished by parliamentary vote—NHR, non-dom UK, Swiss lump-sum)	Stable (fundamental law, anti-tax political culture)
Negotiation required	Yes (lawyers, tax authorities, complex file)	No (the law automatically applies to all residents)
Accessibility	Reserved for the ultra-rich (income > €500,000/year for it to be worthwhile)	Universal (freelancer at €30,000 as well as millionaire at €5M)
Cost of living in the country	High (Switzerland: €5,000-€15,000/month, Italy: €2,500-€4,000/month)	Low (US$1,500-US$2,500/month couple in premium neighborhood)
Political risk	High (permanent target of populists and media)	Low (no political debate on territoriality in PY)
Accessible nationality	Variable (Switzerland: 10+ years, Italy: 10 years, Greece: 7 years)	3 years

The European tax ruling is a temporary, costly, and fragile privilege reserved for the ultra-rich. Paraguayan territoriality is a permanent, free, and stable right accessible to all. The choice between the two is not a tax choice—it's a philosophical choice: dependence on the goodwill of a European government vs. personal fiscal sovereignty in a stable country.

Profiles for whom the European tax ruling can make sense (despite everything)

The billionaire who does NOT want to leave Europe

If your wealth exceeds €50 million and you absolutely want to stay in Europe (family, business, lifestyle), the Swiss lump-sum tax or the Italian flat tax can make sense—despite the cost. The Swiss lump-sum of CHF 500,000/year is negligible when your income is CHF 10 million/year (effective rate: 5%). The Italian flat tax of €100,000 is negligible when your foreign income is €5 million/year (effective rate: 2%).

But even for this profile, the question is: why pay €100,000-€500,000/year when Paraguay offers €0/year? The answer is lifestyle: some people want to live in Milan, Geneva, or Athens—not Asunción. And that's a legitimate choice. The tax ruling is the price of that choice.

The European retiree with average pension

The Greek regime for retirees (7% flat tax on foreign pensions) can be attractive for a retiree with a pension of €3,000-€5,000/month who wants to live in Greece (sea, sun, culture). 7% tax on €40,000/year = €2,800/year. That's little—and Greece offers an exceptional Mediterranean lifestyle.

But even there, Paraguay offers 0% on foreign pensions (territoriality = pension is from a foreign source). And the cost of living in Paraguay is ~40% lower than in Greece. The retiree who chooses Greece does so for the Mediterranean lifestyle—not for tax optimization.

The expatriate executive sent by their employer

The Belgian RSII is relevant for an executive sent to Belgium by a multinational: the 30% salary exemption is automatic (via the employer), no choice of country of residence (the employer decides), and Belgium offers a decent family living environment (international schools, proximity to Paris). This is not an optimization choice but an optimization within the framework of imposed mobility.

The case of French expatriates who "combine" tax ruling + Paraguay

The dual-flag scheme

Some sophisticated expatriates use a two-step scheme:

1. Phase 1 (5-15 years): Residence in Italy or Greece with a €100,000 flat tax. Capitalization of foreign income with a tax capped at €100,000/year (effective rate 2-5% on income of €2-5M). Wealth grows rapidly.
2. Phase 2 (after the end of the regime): Transfer of residence to Paraguay. Foreign income at 0%. Wealth accumulated during Phase 1 continues to grow at 0% tax.

This scheme is legal but complex (double change of residence, potential double exit tax, coordination between 3 tax systems). It is only worthwhile for very significant assets (> €5M) and requires an experienced international tax lawyer.

For 95% of French-speaking expatriates, the strategy is much simpler: go directly to Paraguay. Why pay €100,000/year for 15 years in Italy (= €1.5M in cumulative taxes) when you can pay €0 from day 1 in Paraguay? The dual-flag scheme only makes sense if you absolutely want to live in Europe for 10-15 years before moving to South America.

Conclusion

Tax rulings are the mechanism by which European countries attract the ultra-rich with tailor-made tax regimes: Swiss lump-sum tax (CHF 250,000-1,000,000+/year), Italian flat tax (€100,000/year), Greek flat tax (€100,000 + €500,000 investment), Maltese non-dom (€15,000/year minimum). These regimes offer effective rates of 1-5% on foreign income—but at a prohibitive cost, with a limited duration, and under the permanent threat of political abolition (NHR Portugal, non-dom UK).

Paraguay offers the same tax result—0% on foreign income—without any of the disadvantages of European tax rulings:

• No minimum annual cost (€0 vs €15,000-€1,000,000)
• No investment required (€0 vs €275,000-€500,000)
• No limited duration (unlimited vs 8-15 years)
• No negotiation (the law applies automatically)
• No political risk (entrenched system vs fragile regime)
• Accessible to all income levels (not reserved for the ultra-rich)

European tax rulings are band-aids on a sick tax system—exceptions created because normal rates are too high to retain mobile taxpayers. Paraguay doesn't need band-aids: its tax system is healthy from the start. 0% territoriality is not an exception—it's the rule. And the rule applies to everyone, regardless of wealth, without negotiation, and without an expiration date.

The tax ruling is the privilege of millionaires. Paraguayan territoriality is the right of all. And for the first time in tax history, the "right of all" is more advantageous than the "privilege of millionaires."

Do you want a tax advantage without negotiation, without lump sum, and without an expiration date? Contact our team to start your Paraguayan tax residency (from €1,400). US LLC, bank account, accounting (€30/month). No ruling. No lump sum. No time limit. Just the law—and the law says 0%.