Territorial vs Worldwide Taxation: 45 Countries Compared

Territorial taxation means a country taxes its residents only on income from local sources, while worldwide taxation reaches everything a resident earns, wherever it arises. Most countries tax worldwide income, the US taxes its citizens wherever they live, and many countries mix the rules. If you are choosing where to live, the system decides what happens to your foreign investment income, and the local rate decides what you pay on work you do there.

Quick summary

  • Of the 45 countries in the Nomad Tax Index, 24 tax residents on worldwide income, 7 are territorial, 5 have no personal income tax, 4 use a remittance basis and 5 mix systems.
  • Territorial countries such as Georgia, Paraguay, Panama and Hong Kong leave foreign dividends, interest and gains untaxed, but they tax work done on their soil even when every client is abroad.
  • On $100,000 of remote-work revenue, the Index puts the effective rate in territorial countries anywhere from 0% in Costa Rica and 1.18% in Georgia to 19.86% in Malaysia and 29.3% in Panama.
  • Worldwide taxation follows residence and ends when residence ends, but the US taxes its citizens wherever they live, and Spain keeps taxing nationals who move to a tax haven for 4 more years.
  • For companies, Hong Kong, Panama and Seychelles tax only local profits, but a company in a multinational group keeps foreign dividends and interest untaxed only if it meets local conditions, mainly substance.

Territorial vs worldwide taxation: the difference

Worldwide taxation is the default. A resident is taxed on income from every source, at home and abroad, and relief for tax paid elsewhere comes through credits or treaties. It follows residence, so it ends when you stop being resident, except in a country that also taxes by citizenship.

Territorial taxation taxes by source. A resident pays tax on income that arises in the country and nothing on foreign income, whether it stays abroad or comes home. Between them sit remittance systems, which tax foreign income only when it is brought in, and at the far end are countries with no personal income tax at all.

The tax systems a resident can live under

SystemWhat a resident is taxed onForeign incomeExamples
WorldwideIncome from every sourceTaxed, with credit for foreign taxPortugal, Spain, Italy, United Kingdom, Cyprus
TerritorialIncome from local sources onlyNot taxed, even if brought inGeorgia, Paraguay, Panama, Hong Kong, Singapore
RemittanceLocal income, plus foreign income brought inTaxed only when brought inMalta, Thailand, Mauritius, Barbados
No personal income taxNo tax on personal incomeNot taxedUAE, Monaco, Cayman Islands, The Bahamas
Citizenship-basedCitizens on all income, wherever they liveTaxed, with exclusions and creditsUnited States
HybridA mix, by income type, nationality or domicileDepends on the ruleIreland, Uruguay, Philippines, Dominican Republic

Which countries use territorial or worldwide taxation

The Index records each country's system for the person it scores, a self-employed remote worker who has just moved in. Worldwide taxation is still the norm: 24 of the 45 countries use it, against 7 territorial countries.

The 45 Index countries by tax system

SystemCountCountries
Worldwide24Albania, Andorra, Argentina, Armenia, Brazil, Bulgaria, Colombia, Croatia, Cyprus, Czechia, Estonia, Greece, Hungary, Indonesia, Italy, Mexico, Montenegro, Portugal, Puerto Rico, Romania, Serbia, Spain, Switzerland, United Kingdom
Territorial7Costa Rica, Georgia, Hong Kong, Malaysia, Panama, Paraguay, Singapore
No personal income tax5The Bahamas, Cayman Islands, Monaco, St Kitts and Nevis, United Arab Emirates
Hybrid5Antigua and Barbuda, Dominican Republic, Ireland, Philippines, Uruguay
Remittance4Barbados, Malta, Mauritius, Thailand

Territorial taxation: what goes untaxed and what does not

In most of the territorial tax countries in the Index, a resident's foreign dividends, interest and gains go untaxed: Panama has individuals subtract foreign-source income on their return, Paraguay's income tax reaches only Paraguayan-source income, and Hong Kong does not tax profits arising abroad even when they are brought into Hong Kong.

Work done on the country's soil is still taxed: the source of pay for services is generally where the work is done, not where the client sits, so Georgia, Paraguay, Singapore, Malaysia and Hong Kong all tax remote work done there. Georgia's Tax Code treats services rendered in Georgia as Georgian-source income, and also services a Georgian resident supplies to a client abroad unless a permanent establishment elsewhere performs them, which is why a freelancer resident in Georgia is taxed there on every invoice.

How Georgia's territorial system taxes a resident
Foreign dividends, interest and gainsIncome without a Georgian source is exempt0%
Work done in Georgia, standard ratePersonal income tax on Georgian-source income20%
Work done in Georgia, small business statusIndividual entrepreneurs in eligible activities, up to GEL 500,000 (about $192,000) a year1% of turnover
From the month turnover passes GEL 500,000 (about $192,000)Status revoked from the next January after 2 calendar years each above that limit3% of turnover to year end

Small business rates and the loss of status from articles 88 to 90 of the Tax Code of Georgia (article 90(2) for the 3% rate, article 89(2)(a) and 89(3) for the revocation), checked October 12, 2026; the foreign income exemption and the 20% standard rate from the Nomad Tax Index data, checked September 29, 2026.

Costa Rica is the exception. Remote workers on its Law 10008 permit pay no Costa Rican income tax on pay from abroad for up to 2 years and are never treated as habitual residents, which gives Costa Rica a 0% rate in the Index. A bill the government presented in September 2026, file 25.796, would tax residents' foreign dividends, interest, royalties, rents and capital gains while leaving other income territorial, Delfino.cr reported on September 23, 2026; it is not law.

For a remote worker, the territorial countries differ by the rate they charge on work done there.

Tax on $100,000 of remote-work revenue in the territorial countriesEffective rate on profit, tax plus social contributions, for a self-employed person working for foreign clients, on the structure and cost assumption the Index scores in each country (Costa Rica: the Law 10008 remote-worker permit, whose holders are not tax resident)
  1. Costa Rica0%
  2. Georgia1.2%
  3. Singapore6.1%
  4. Paraguay9.6%
  5. Hong Kong10.2%
  6. Malaysia19.9%
  7. Panama29.3%

Source: Nomad Tax Index country data (effective rate at $100,000)

Show the numbers
Effective rate
Costa Rica0%
Georgia1.2%
Singapore6.1%
Paraguay9.6%
Hong Kong10.2%
Malaysia19.9%
Panama29.3%

Panama's 29.3% assumes remote work done in Panama is Panamanian-source income, a point Panama's rules leave open, while Georgia's 1.18% comes from its small business regime rather than from the territorial system itself.

Foreign clients do not make income foreign

In a territorial country the question is where you sat while you did the work, not where the client is or which account the money lands in. A designer living in Asunción who bills only US clients has Paraguayan-source income, and keeping the fees in a US account changes nothing.

Worldwide taxation: tied to where you live

In the 24 worldwide countries in the Index, a resident is taxed on income from every country until residence ends, and leaving does not end it by itself: digital nomads who never settle anywhere often stay tax resident, and taxed on everything, in the country they left.

Several worldwide countries soften the rule for newcomers. The UK exempts foreign income and gains for the first 4 tax years after 10 years abroad under its FIG regime, Italy and Greece offer a fixed lump sum tax in place of tax on foreign income, and other special tax regimes for new residents cut the rate on work for a set number of years.

Cyprus is worldwide on paper, but residents with non-dom status pay no Special Defence Contribution on dividends and interest until they have been resident 17 of the last 20 years, a limit they can now extend by up to 2 periods of 5 years for €250,000 (about $284,000) each, KPMG Cyprus explains.

Some worldwide countries also keep a hold on their own nationals after they leave. Spain keeps taxing Spanish nationals who move their tax residence to a tax haven for the year of the move and the 4 years after it, under article 8.2 of its income tax law.

Citizenship-based taxation: the US case

The US taxes by citizenship as well as residence: citizens and resident aliens are taxed on worldwide income wherever they live, the IRS states. Moving to a territorial or zero-tax country lowers the US bill through the foreign earned income exclusion, up to $132,900 of earned income per person for 2026, according to the IRS, the foreign housing exclusion or deduction, and credits for foreign tax, which a zero-tax country never produces.

That makes the new country's system a secondary question for Americans living abroad: a territorial country leaves their foreign dividends untaxed locally, but the US still taxes them.

Remittance systems: taxed only when brought in

A remittance system sits between territorial and worldwide taxation. Foreign income is taxed only when it reaches the country, so income left abroad stays untaxed there, but it is taxed the moment it comes in. Malta applies the remittance basis to residents who are not domiciled there, Thailand to foreign income its residents earn from 2024, and Mauritius to all residents.

Malaysia is territorial in practice but no longer in law: foreign income received in Malaysia is now taxable, but resident individuals can bring it in tax free until December 31, 2036, subject to conditions, PwC reports.

Hybrid tax systems: 5 countries that mix the rules

These countries do not fit a single label, because they tax by income type, by nationality or by domicile:

  • Philippines. Foreigners, resident or not, are taxed only on Philippine-source income, while Filipino citizens living there are taxed on worldwide income; work done in the Philippines is local income either way.
  • Uruguay. Work done in Uruguay is taxed at rates up to 36%, foreign dividends and interest at 12%, and from 2026 gains on foreign assets too, under Uruguay's personal income tax law, but newcomers who meet the conditions of Uruguay's newcomer regime can keep foreign capital income out of tax for the year of arrival and 10 more years.
  • Dominican Republic. Foreign investment income is untaxed for a newcomer's first 2 tax years, while work done in the Dominican Republic is taxed from the start.
  • Ireland. Residents domiciled in Ireland are taxed on worldwide income, and residents who are not domiciled there pay tax on foreign investment income only when they bring it in.
  • Antigua and Barbuda. Wages carry no personal income tax, but self-employed residents of Antigua and Barbuda pay the Unincorporated Business Tax of up to 25% on net business income, the Inland Revenue Department states.

Territorial taxation for companies

The same split exists for companies. A worldwide system taxes a company on profits from everywhere; a territorial one taxes only local profits, or exempts dividends a company receives from foreign subsidiaries. In the Index, Hong Kong companies, Panama companies and Seychelles companies are taxed only on profits from local sources, but a company that belongs to a multinational group, such as one sitting beside another company its owner holds abroad, must meet conditions in all 3, mainly local substance, to keep foreign passive income such as dividends and interest untaxed.

Hong Kong has applied a substance or participation test to such income since January 1, 2023 under its foreign-sourced income exemption rules, Panama taxes it at 15% unless the company has qualified staff, premises and decision-making in Panama, and Seychelles has applied an economic substance test to passive income from non-residents since September 16, 2021. None of this binds the owner's own country, which can tax the company's profit under CFC rules.

US corporate tax has a territorial feature of its own: a US corporation that holds at least 10% of a foreign corporation for more than 365 days around the dividend date can deduct the foreign-source portion of most dividends it receives from it, under section 245A of the Internal Revenue Code and the holding period in section 246(c)(5). US individuals get no such deduction.

Which tax system suits you

The right system depends on the kind of income you have and where you do the work:

  • Investment income you do not need to spend. A territorial country, a remittance country or one with no income tax leaves it untaxed while it stays abroad.
  • Freelance or remote work. Work done in a territorial country is taxed there, so what cuts the tax on fees legally is a country with no income tax, a low local rate on work or a newcomer regime.
  • A large foreign income and a move to Europe. A worldwide country with a newcomer regime can beat a territorial one.
  • US citizenship. Every system leaves the US claim in place.

Choosing a country by its tax system

Works

You live on foreign dividends and want them untaxed. You become resident in Paraguay with a tax certificate and keep the portfolio abroad; the dividends are outside Paraguayan income tax because the capital is not placed in Paraguay.

Fails

You become resident in Paraguay the same way but keep your home in Madrid and spend 200 days a year there. Spain still treats you as resident under article 9 of its income tax law and taxes the dividends on its worldwide basis, and Paraguay's territorial rule saves you nothing.

Checking a country's tax system before you move

  • Find out how it taxes residents: worldwide, territorial, remittance, no income tax, or a mix.
  • Find its source rule for services: in most countries, work done there is local income.
  • Check how foreign dividends, interest and gains are taxed, and whether that changes after a set number of years.
  • Check the residence test and the certificate, since the system helps only once you are resident.
  • Check what your old country does when you leave: exit taxes, rules for nationals like Spain's, or citizenship-based tax.
  • Compare the effective rate on your real income, not the label.

David's note

I treat a territorial exemption as today's law, not a promise. Malaysia now taxes foreign income received there and exempts resident individuals only until 2036, and Costa Rica has a bill to tax residents' foreign investment income, so before a long move I want a plan that still works if the exemption goes.

Sources

  1. IRS: U.S. citizens and resident aliens abroadirs.gov, checked
  2. IRS: Figuring the foreign earned income exclusion ($132,900 for 2026)irs.gov, checked
  3. IRS: Foreign housing exclusion or deductionirs.gov, checked
  4. Spain, Ley 35/2006 del IRPF, article 8.2 (nationals resident in a tax haven) and article 9.1(a) (more than 183 days)boe.es, checked
  5. HMRC helpsheet HS266: Foreign income and gains (FIG) regime (2026)gov.uk, checked
  6. KPMG Cyprus: Cyprus Tax Residency and Non-Dom rules, April 2026 (page 6, including the extension of non-dom status)assets.kpmg.com, checked
  7. Tax Code of Georgia, articles 88 to 90 (small business status, the 3% rate and revocation)matsne.gov.ge, checked
  8. Delfino.cr: bills 25.796 and 25.797 on foreign income and exemptions (September 23, 2026)delfino.cr, checked
  9. PwC Worldwide Tax Summaries: Malaysia, income determination (last reviewed June 16, 2026)taxsummaries.pwc.com, checked
  10. Uruguay, Texto Ordenado 2023, Title 7 (IRPF): article 6(2) as replaced by Law 20.446, articles 24-Bis, 37 and 48impo.com.uy, checked
  11. PwC Worldwide Tax Summaries: Uruguay, income determination (foreign capital gains from January 1, 2026; last reviewed September 2, 2026)taxsummaries.pwc.com, checked
  12. Dominican Republic, Tax Code (Law 11-92), article 271 (foreign income of new residents from the 3rd tax year)dgii.gov.do, checked
  13. Antigua and Barbuda Inland Revenue Department: Unincorporated Business Tax FAQ (rates 0%, 8% and 25%)ird.gov.ag, checked
  14. Hong Kong Inland Revenue Department: Foreign-sourced income exemptionird.gov.hk, checked
  15. PwC Worldwide Tax Summaries: Panama, taxes on corporate income (last reviewed August 4, 2026)taxsummaries.pwc.com, checked
  16. Seychelles Revenue Commission: Seychelles tax system (economic substance test from September 16, 2021)src.gov.sc, checked
  17. 26 U.S. Code section 245A: Deduction for foreign source-portion of dividendslaw.cornell.edu, checked
  18. 26 U.S. Code section 246(c)(5): Holding period for the section 245A deductionlaw.cornell.edu, checked

Frequently asked questions

What is territorial taxation?

A system in which a country taxes residents only on income from local sources. Foreign income goes untaxed whether it stays abroad or is brought home, but work done inside the country counts as local income.

Which countries use territorial taxation?

In the Nomad Tax Index, 7 countries do: Costa Rica, Georgia, Hong Kong, Malaysia, Panama, Paraguay and Singapore. Malaysia technically taxes foreign income brought in but exempts resident individuals until December 31, 2036, subject to conditions.

What is worldwide taxation?

A system in which residents are taxed on income from every country. It is the most common system: 24 of the 45 countries in the Nomad Tax Index use it, and it usually ends when you stop being resident.

Does the US use territorial or worldwide taxation?

For individuals, worldwide and based on citizenship: citizens are taxed on worldwide income wherever they live. For corporations, the US has a territorial element, a deduction for the foreign-source part of dividends from foreign companies they hold at least 10% of for more than 365 days around the dividend date, under section 245A and the holding period rule in section 246(c)(5).

Is income from foreign clients foreign income in a territorial country?

Usually not. The source of pay for services is generally where the work is done, so fees for work you do while living in Georgia, Paraguay, Singapore, Malaysia or Hong Kong are local income there, whoever pays them.

What is the difference between territorial and remittance taxation?

A territorial country does not tax foreign income even if you bring it in; a remittance country taxes foreign income when you bring it in and leaves it alone only while it stays abroad. Hong Kong is territorial; Malta and Thailand use a remittance basis.

David Sisvadze

CEO at Nomad Tax Map

David brings 13+ years of experience, including 6 years with the Revenue Service of Georgia and 7 years managing private-sector import operations. He has a strong background in customs, imports, exports, and cross-border logistics.