The WhereNext Expat Relocation Glossary

Beckham Law

Spain's Beckham Law lets eligible new arrivals elect to be taxed as non-residents for up to six tax years: a flat 24% rate on Spanish-source employment income up to €600,000 (47% on the excess) and only Spanish-source income within the Spanish tax net. Named after David Beckham, who used it after joining Real Madrid in 2003. Reformed in 2023 to include digital nomads, remote workers for foreign employers, and certain entrepreneurs.

Citizenship by Descent

Citizenship by descent (jus sanguinis, "right of blood") is the acquisition of citizenship through ancestry rather than birthplace or naturalisation. Generation depth, paperwork, and timeline vary wildly: Italy historically allowed unlimited generational descent (now restricted by the March 2025 reform); Ireland allows three generations; Germany, Hungary, Poland, Portugal Sephardic, and Spanish Sephardic each have specific routes. Often the fastest non-investment route to a second EU passport.

D7 Visa (Portugal Passive Income Visa)

Portugal's D7 visa is the residency pathway for non-EU citizens with stable passive income — pensions, rental yields, dividends, royalties, or capital-gain distributions sufficient to cover Portuguese living costs. Minimum income in 2026 is the Portuguese minimum wage (€920/month) for the main applicant plus 50% per dependent adult and 30% per child. Issued for 4 months, converted to a 2-year residence permit, renewable for 3 more, with a path to permanent residence at year 5.

D8 Visa (Portugal Digital Nomad Visa)

Portugal's D8 visa is the dedicated remote-worker and digital-nomad route, launched in October 2022. Applicants must show monthly income at least four times the Portuguese minimum wage (€3,680/month gross in 2026) earned remotely from outside Portugal, plus Portuguese health coverage and accommodation. The visa is issued for 4 months, then converted to a 2-year residence permit, renewable for 3 more years, with a path to permanent residence at year 5.

HSP Visa (Spain Highly Qualified Professional)

Spain's Highly Qualified Professional visa is a fast-track work and residence permit for non-EU professionals filling specialised, well-paid roles at Spanish employers — including remote-first innovators under the 2023 Startups Law. Salary thresholds and qualifications gate entry, but processing is materially faster than the standard work-permit route, with permits typically valid for three years and renewable.

IFICI (Incentivo Fiscal à Investigação Científica e Inovação)

IFICI is Portugal's 10-year successor regime to NHR, available to new tax residents who haven't been Portuguese tax residents in the prior five years and who work in qualifying scientific research, innovation, higher education, or specific high-value tech roles. Qualifying Portuguese-source employment income is taxed at a flat 20%, with the same broad foreign-income exemptions as NHR. Approved by Decree-Law 249-A/2024.

Inpatriati Regime

Italy's Inpatriati regime gives qualifying new tax residents a 50% exemption on Italian-source employment, assimilated employment and professional self-employment income — on up to €600,000 of qualifying income per year before the exemption — for five tax years (a three-year extension at 50% exists only for 2024 movers who bought their Italian principal residence by 31 December 2023 and within the twelve months before their registered-residence transfer). Reformed by the 2024 Tax Reform Law, which tightened eligibility and reduced the exemption from the prior 70-90% range.

Italy Digital Nomad Visa

Italy's Digital Nomad Visa launched in April 2024. Open to non-EU "highly qualified" remote workers (university degree or qualifying three-year post-secondary vocational qualification, a recognised regulated-profession qualification, 5+ years of relevant experience, or 3 years within the preceding 7 for ICT managers/specialists — plus six months of prior relevant work in every case) earning about €28,000/year gross (2024 consular figure) from an employer or clients in Italy or abroad; employees must also meet the applicable collective-agreement salary and, in all cases, the ISTAT average gross annual salary floor (Washington posts €33,000). Issued for up to 1 year, renewable. Tax residency triggers Italian worldwide taxation; the Impatriati regime can mitigate it.

MM2H (Malaysia My Second Home)

MM2H is Malaysia's long-stay multiple-entry visa for foreign nationals, launched in 2002 and extensively reformed in 2021 and 2024. The current 2024 framework offers three tiers — Silver (RM 500,000 fixed deposit, 5-year stay), Gold (RM 2 million, 15-year), and Platinum (RM 5 million, 20-year) — plus a separate "Sarawak MM2H" with lower thresholds for residence in Sarawak only. Holders can lease property, hold a Malaysian bank account, and spend any amount of the year in Malaysia.

NHR (Non-Habitual Resident)

Portugal's Non-Habitual Resident regime offered new tax residents a 10-year window of preferential rates: foreign income often tax-exempt and qualifying high-value Portuguese employment income taxed at a flat 20%. Closed to new applicants on 31 December 2023; existing NHR holders retain their decade-long status. Replaced for new arrivals by IFICI (the "NHR 2.0" tax incentive for scientific research and innovation).

Permanent Residence (PR)

Permanent Residence is the immigration status that entitles a non-citizen to live in a country indefinitely without citizenship, with most resident rights including work, study, and access to social services. Acquired through years of continuous legal residence (typically 5 years in the EU, 5 in the US for most green-card categories, 4-5 in Australia/Canada/NZ). Often a stepping stone to citizenship after additional residence years.

Schengen Area

The Schengen Area is a passport-free travel zone of 29 European countries (25 EU members + Iceland, Norway, Switzerland, Liechtenstein), where internal border checks are abolished. Non-EU short-stay visitors can spend up to 90 days within any rolling 180-day period across the entire area. Romania and Bulgaria fully joined for land borders on 1 January 2025, completing the area's expansion.

Spain Digital Nomad Visa

Spain's Digital Nomad Visa, launched in January 2023 under the Startups Law, lets non-EU remote workers live in Spain while working for foreign employers (or as freelancers serving foreign clients with Spanish revenue capped at 20%). The 2026 threshold is €2,442/month gross — 200% of the 2026 SMI. Issued for 1 year initially, renewable up to 5 years total. Pairs with the Beckham Law tax election.

CRS (Common Reporting Standard)

CRS is the OECD's global financial-account reporting standard, in force since 2017 across 120+ jurisdictions. Banks and other financial institutions in participating countries automatically report account-holder information (name, address, tax IDs, balance, interest, dividends) to the holder's country of tax residence. The US is NOT a CRS participant but operates the parallel FATCA programme bilaterally.

Double Taxation

Double taxation occurs when the same income or capital is taxed twice — typically once by the source country (where the income arises) and once by the residence country (where the recipient is tax resident). It's prevented by tax treaties (which allocate taxing rights) and by domestic relief mechanisms like the foreign tax credit and the foreign earned income exclusion. Unrelieved double taxation is rare in modern tax systems but can still occur with non-treaty-partner countries.

Expatriation Tax (US Exit Tax)

The US expatriation tax under § 877A applies a mark-to-market deemed sale of all worldwide assets to "covered expatriates" — individuals who renounce US citizenship or surrender a green card after holding it 8+ of the last 15 years, AND meet one of three triggering tests (net worth ≥$2M, 5-year average tax liability over a threshold, or non-compliance certification failure). Gain above an annual exclusion ($890,000 in 2025, indexed) is taxed at long-term capital-gains rates.

FATCA

FATCA is a 2010 US law requiring foreign financial institutions to report accounts held by US persons to the IRS, and US persons themselves to disclose foreign financial assets above threshold amounts on Form 8938. Thresholds for individuals living abroad start at $200,000 (single) / $400,000 (joint) at year-end. FATCA penalties for non-disclosure are severe: $10,000 minimum per failure, doubling every 30 days up to $50,000.

FBAR

FBAR is the Foreign Bank Account Report (FinCEN Form 114) that US persons file annually if the aggregate value of their foreign financial accounts exceeded $10,000 at any point during the year. Filed electronically with the Treasury Department's FinCEN (not the IRS), separate from Form 1040. Penalties for wilful non-filing can reach 50% of the account balance per year. Due date: 15 April with automatic 6-month extension.

FEIE (Foreign Earned Income Exclusion)

FEIE lets US citizens and resident aliens exclude up to $132,900 (2026) of foreign-earned income from US federal income tax — but not from Social Security/self-employment tax. To qualify, the taxpayer must meet either the Bona Fide Residence Test (full-year tax residence in a foreign country) or the Physical Presence Test (330 full days abroad in any 12-month period). Claimed on IRS Form 2555 attached to Form 1040.

Foreign Tax Credit (FTC)

The Foreign Tax Credit lets US citizens and resident aliens reduce their US tax liability dollar-for-dollar by income taxes already paid to foreign governments on the same income. Claimed on IRS Form 1116, it prevents double taxation on income above the FEIE ceiling and on passive income that FEIE doesn't cover. The credit is per-category, capped at the US tax otherwise due on the foreign-source income, with 10-year carryforward and 1-year carryback for unused credits.

IRS Streamlined Filing Compliance Procedure

The IRS Streamlined Filing Compliance Procedure is the standard remedial pathway for US persons who failed to file FBARs, Form 8938, or income tax returns reporting foreign income — provided their non-compliance was non-wilful. The Streamlined Foreign Offshore Procedure (SFOP), for taxpayers living abroad, requires 3 years of amended/late tax returns + 6 years of FBARs + a non-wilfulness statement. Penalty: zero on SFOP if non-wilfulness is established.

Non-Resident Alien (NRA)

A Non-Resident Alien (NRA) is a non-US-citizen who meets neither the Green Card Test nor the Substantial Presence Test. NRAs are taxed by the US only on US-source income (typically at flat rates, often 30% gross) and on income effectively connected with a US trade or business (at standard graduated rates). Filed on Form 1040-NR. NRAs are NOT subject to worldwide-income taxation, FBAR, FATCA, or full FEIE/FTC.

Resident Alien

A Resident Alien is a non-US-citizen who meets either the Green Card Test or the Substantial Presence Test for US tax purposes. Resident aliens are taxed on worldwide income on the same terms as US citizens — including FEIE/FTC eligibility, FBAR/FATCA obligations, and standard Form 1040 filing. Distinct from immigration "resident alien" status (the green-card-holder term) — the IRS definition is purely fiscal.

Self-Employment Tax (US Expats)

US self-employment tax is the 15.3% combined Social Security (12.4%) and Medicare (2.9%) tax that US-citizen and resident-alien self-employed individuals owe on net earnings — including foreign-source self-employment income. Critically, FEIE does NOT exclude SE tax. The only relief is a Totalization Agreement (Bilateral Social Security Agreement) with a foreign country, which lets the expat pay foreign social-security tax instead of US SE tax.

Substantial Presence Test (SPT)

The Substantial Presence Test is the IRS's primary test for determining whether a non-US citizen is a US tax resident. It applies a weighted formula: count all days physically present in the US in the current year + 1/3 of days in the prior year + 1/6 of days two years prior. If the total reaches 183, you are a US tax resident — subject to certain exemptions and the closer-connection exception.

Tax Haven

A tax haven is a jurisdiction with very low or zero corporate or individual income tax, typically combined with banking secrecy, weak transparency requirements, and political or fiscal independence. The OECD, EU, and FATF maintain blacklists and greylists of non-cooperative jurisdictions. Common 2026 examples: Cayman Islands, BVI, Bermuda, Bahamas, UAE (with caveats), Andorra, Monaco. Tax-haven use by individuals is now severely constrained by FATCA, CRS, and beneficial-ownership registries.

Tax Residency

Tax residency determines which country has primary right to tax your worldwide income. Each country sets its own tests — typically based on physical presence (often 183+ days/year), domicile, primary economic interests, or family ties. Holding a residence permit does not automatically establish tax residency, and tax residency does not require a residence permit. Dual tax residency is resolved by tax-treaty tie-breaker rules.

Tax Treaty

A tax treaty is a bilateral agreement between two countries that allocates taxing rights over cross-border income, prevents double taxation, and provides mechanisms to resolve disputes. Treaties typically follow the OECD or UN Model Convention. The US has tax treaties with about 70 countries; the UK with about 130. Treaty benefits often require formal claim on a tax return (e.g., IRS Form 8833 for treaty-based positions on a US return).

Territorial Taxation

Territorial taxation is a system in which a country taxes only income earned within its own borders (or with a domestic source), exempting foreign-source income for residents. Notable adopters in 2026 include Singapore, Hong Kong, Malaysia, Panama, Costa Rica, Georgia, Paraguay, and Thailand. The opposite of worldwide taxation. Most territorial systems still tax foreign income that's remitted to the country, with various carve-outs.

Worldwide Taxation

Worldwide taxation is a system in which a country taxes its tax residents (and, in the US case, citizens) on income from all sources globally — domestic and foreign. Tax-treaty allocation and foreign tax credits prevent most double taxation. Adopted by the US, UK, Germany, France, Spain, Italy, Australia, Canada, and most OECD countries. Eritrea is the only other country besides the US that taxes citizens regardless of residence.

Citizenship by Investment (CBI)

Citizenship by investment programmes grant a passport in exchange for a qualifying investment — typically a non-refundable government donation, real-estate purchase, or business investment. Active 2026 programmes include St. Kitts and Nevis ($250,000+), Dominica ($200,000+), Antigua and Barbuda, Grenada, St. Lucia, Vanuatu, Türkiye ($400,000+ real estate), and Egypt. EU CBI programmes (Cyprus, Malta) have been closed or restricted following European Commission and ECJ pressure.

EB-5 Visa (US Investor Visa)

EB-5 is the US employment-based fifth-preference immigrant visa: a green card for foreign nationals who invest in a US commercial enterprise that creates at least 10 full-time US jobs. The 2022 RIA reform set investment minimums at $800,000 (Targeted Employment Areas) or $1,050,000 (non-TEA), introduced concurrent filing for applicants already in the US, and reserved set-asides for rural and high-unemployment areas. Process timelines run 4-7+ years from filing to permanent residence.

Golden Visa

A Golden Visa is residency-by-investment: non-EU/non-domestic applicants gain residence rights by investing in qualifying assets (property, funds, government bonds, or job-creating business) above a country-set threshold. Programmes vary widely in cost, physical-presence requirements, and whether they lead to citizenship. Portugal closed its real-estate route in October 2023; Spain ended its programme entirely in April 2025; Greece, Malta, and the Caribbean states remain open with different conditions.

Greece Golden Visa

Greece's Golden Visa is the most-applied-to active European RBI in 2026. Property-investment thresholds were raised in 2024: €800,000 across the Attica region, the Thessaloniki regional unit, the Mykonos and Thira (Santorini) regional units and islands above 3,100 inhabitants; €400,000 elsewhere; €250,000 for conversion-to-residential or listed-building restoration projects. No physical-presence requirement. 5-year renewable residence permit; permanent residence at year 5; Greek citizenship typically at year 7+.

Portugal Golden Visa

Portugal's Golden Visa (Autorização de Residência para Investimento, ARI) provides residency-by-investment to non-EU/EEA/Swiss nationals. The real-estate route closed in October 2023 (Lei 56/2023). Active routes in 2026: investment in venture-capital or private-equity funds (€500,000 minimum), R&D investment (€500,000), cultural-heritage support (€250,000), or business creation/maintenance (10+ jobs). Path to permanent residence at year 5 and Portuguese citizenship at year 10 (7 for CPLP/EU nationals) since 19 May 2026.

IBAN (International Bank Account Number)

IBAN is an internationally agreed system for identifying bank accounts across borders. The format encodes country, check digits, bank identifier, and account number in a standardised string of up to 34 characters. Required for all SEPA transfers and most international wires to/from EU banks. 80+ countries use IBAN in 2026 including the UK, all EU states, Switzerland, Türkiye, Saudi Arabia, UAE, and Brazil. The US does NOT use IBAN domestically.

Multi-Currency Account

A multi-currency account holds balances in two or more currencies under a single account and lets the holder receive, hold, convert, and pay out in any of them. Modern fintech versions (Revolut, Currencycloud, HSBC Global Money) provide local-equivalent receiving details (US ACH, EU IBAN, UK Sort Code) and mid-market conversion at low margins. Distinct from foreign-currency-deposit accounts at traditional banks, which typically convert at retail spreads.

SEPA

SEPA (Single Euro Payments Area) is the EU framework that lets cross-border euro payments work like domestic ones — same speed, same cost, same fields. Covers 36 countries (27 EU + EEA + UK + Switzerland + Andorra + Monaco + San Marino + Vatican). SEPA Credit Transfer (SCT) settles same-day; SCT Inst is instant (10 seconds, 24/7) and became universal in 2025-2026 under EU Regulation 2024/886.

EHIC / GHIC Card

The European Health Insurance Card (EHIC, EU/EEA/Swiss residents) and UK Global Health Insurance Card (GHIC, UK residents post-Brexit) entitle holders to access state healthcare in another EU/EEA country (and Switzerland, for EHIC) on the same terms as residents — typically free or with the locally applicable co-payment. Covers necessary care during temporary stays only; not a substitute for travel or international health insurance.

International Health Insurance

International Private Medical Insurance (IPMI) is health coverage designed for individuals living abroad. It covers in-patient and out-patient care across multiple countries, typically with worldwide options excluding or including the US. Major providers: Cigna Global, Allianz Care, Bupa Global, GeoBlue, William Russell, IMG Global. Annual premiums for a healthy 40-year-old expat range $2,500-$8,000+ depending on coverage scope, deductible, and US inclusion.

Mutuelle (France)

A mutuelle is private complementary health insurance in France that covers the portion of medical costs not reimbursed by the state Assurance Maladie (typically 30-40% of standard tariffs, plus most dental and optical care). Since 2016 (Loi ANI), employers must offer a group mutuelle to all employees and pay at least 50% of premium. For self-employed, retirees, and unemployed expats, individual policies cost €40-€200/month.

SNS (Serviço Nacional de Saúde Portugal)

The Serviço Nacional de Saúde is Portugal's universal public health service, established by the 1979 Health System Law. SNS provides primary care, specialist care, hospitalisation, and emergency services. Most services are free at the point of use or carry small co-payments (€4-€20 per consultation, capped). Legal residents — including holders of D7, D8, and Golden Visa permits — are entitled to register and use SNS on the same terms as Portuguese citizens.

Apostille

An apostille is a standardised certification that authenticates a public document for use in another country that's a party to the 1961 Hague Apostille Convention. It eliminates the need for further consular legalisation. Used for birth certificates, marriage certificates, education credentials, court documents, and notarised documents. 126 countries are parties as of 2026 (China and Indonesia joined in 2023; Pakistan and Rwanda in 2024-2025).

EES (EU Entry/Exit System)

EES is the EU's automated biometric entry/exit registration system for non-EU nationals crossing Schengen external borders, operational since 12 October 2025. It replaces manual passport stamping with fingerprint and facial-image capture, automatically tracks the 90/180-day quota, and detects overstays. Each entry typically adds 1-3 minutes to border processing for the first registration; subsequent crossings are faster.

ETIAS

ETIAS is the EU's pre-travel electronic authorisation for visa-exempt non-EU nationals visiting the Schengen Area, analogous to the US ESTA. Required for citizens of about 60 visa-exempt countries (including the US, Canada, UK, Australia, Brazil, Japan), it costs €20 (raised from the originally legislated €7 by a July 2025 Commission decision), is valid for 3 years or until passport expiry (whichever is sooner), and is checked at carrier check-in and at the Schengen external border. Originally scheduled for 2024, the launch is currently slated for late 2026 / early 2027.

Hague Conventions

The Hague Conventions are a series of multilateral treaties developed by the Hague Conference on Private International Law (HCCH) governing cross-border legal matters: child abduction, adoption, civil-procedure cooperation, document authentication (Apostille), and international child support. The most-cited expat-relevant ones are the 1961 Apostille Convention, the 1980 Child Abduction Convention, and the 1993 Adoption Convention.

Notarization

Notarization is the formal certification of a document or signature by a notary public, granting it official evidentiary weight. The civil-law notary system (most of Europe, Latin America, Japan) uses highly trained legal professionals who draft documents and verify identities; the common-law notary system (US, UK common-law) uses notaries who simply witness signatures with limited authentication scope. Notarized documents typically need apostille for cross-border use.

Power of Attorney (POA)

A Power of Attorney is a legal instrument in which one person (the principal) authorises another (the attorney-in-fact or agent) to act on their behalf. Scope ranges from limited (a single transaction) to general (broad financial and legal authority). For cross-border use, a POA usually must be notarized in the issuing country and apostilled or legalised for the receiving country. Civil-law jurisdictions often require the POA to be drafted in detailed civil-law form to be recognised.

Visa-Free Travel

Visa-free travel refers to the right to enter a country without a pre-arranged visa, typically for short-stay tourism or business of up to 30, 60, or 90 days. The Henley Passport Index, Arton Capital Passport Index, and Nomad Capitalist rankings track visa-free destination counts as a proxy for passport strength. Visa-free is distinct from visa-on-arrival (issued at the border), eVisa (issued electronically pre-trip), and ETIAS-style pre-authorisation.