A sunlit wooden desk by an open window over terracotta rooftops and the sea, with a closed laptop, two folders side by side, a coffee cup and a bowl of oranges

IFICI vs Beckham Law: Portugal’s 20% or Spain’s 24%, and who each one fits

On 1 January 2023 Spain opened its flat-rate regime for newcomers to remote employees, and to company directors whatever their stake in a trading company. A year later, Portugal swapped NHR for IFICI. So if you’re deciding between the two countries, you’re now looking at a 20% rate in Portugal or 24% in Spain.

At first glance they look like the same deal. Both tax your work income at a flat rate, both leave most of your foreign investment income alone, and both shut you out if you lived in the country in the last five years.

Look closer, though, and they’re built for different people, with very different deadlines. If you became a Portuguese tax resident in 2026, your IFICI request is due by 15 January 2027. In Spain, the clock starts when you register with Social Security, even if you’re not tax resident yet.

Below, we put the two side by side: who gets in, what each one taxes, how long it lasts, and the dates you can’t miss.

A versão curta

  • IFICI taxes qualifying work income at 20% for 10 years. The Beckham Law taxes your salary at 24%, up to €600,000, for 6 tax years.
  • Both leave most foreign investment income outside local tax, and both shut you out if you were resident in that country in any of the last five years.
  • If you work remotely for a company abroad, Spain’s regime names you in the law. IFICI’s routes need a job or a board seat in a company that passes its activity test.
  • If you freelance on your own invoices, neither fits as things stand. Forming a company and becoming its paid director is what changes the answer, in both countries.
  • The deadlines work differently. IFICI: by 15 January after your first resident year, and a late request still works for the years left. Beckham: within six months of your Social Security start date, with no late route.

Want the Portuguese regime on its own first? Our guia do IFICI explains who qualifies and how to apply. This post is the comparison.

Neste guia10 sections
  1. What do we mean by IFICI and the Beckham Law?
  2. How do IFICI and the Beckham Law compare side by side?
  3. Who qualifies for IFICI, and who qualifies for the Beckham Law?
  4. What rate do you pay on your salary under each?
  5. What happens to your foreign income, pensions and dividends?
  6. How long does each regime last?
  7. What are the deadlines for IFICI and the Beckham Law?
  8. Can a founder with their own company use IFICI or the Beckham Law?
  9. Do remote workers and freelancers qualify?
  10. Which regime suits whom?

What do we mean by IFICI and the Beckham Law?

IFICI is the tax break Portugal has offered new residents since 2024, after NHR closed. Officially it’s an incentive for scientific research and innovation. It gives you a 20% rate on work income from a qualifying activity and exempts most of your foreign income.[1]

The “Beckham Law” is the nickname for Spain’s special regime for workers, professionals, entrepreneurs and investors moving to Spain. Once you’re tax resident in Spain, you pay income tax as if you were a non-resident, with a flat 24% on your salary.[9]

Two things about the Spanish regime catch people out:

  • There’s no investor route. Despite the word “investors” in the title, the law lists no route for buying property or investing.
  • Professional sportspeople are out. If you’re employed under Spain’s special rules for professional sport, you can’t use the employment route.

How do IFICI and the Beckham Law compare side by side?

IFICI gives you 20% for ten years on income from a qualifying activity. The Beckham Law gives you 24% for six tax years on your salary, wherever it’s paid. The rest of the table is where they really differ.

Portugal: IFICISpain: Beckham Law
Rate on your work income20% on net income from the qualifying activity24% on gross employment income up to €600,000, 47% above
How long it runs10 consecutive years from your residence yearYour residence year and the five after
Not resident beforeIn any of the previous 5 yearsIn any of the previous 5 tax years
Remote employee of a company abroadDoesn’t fit the routes as writtenQualifies, with or without the digital nomad visa
Freelancer on your own invoicesDoesn’t fit the routesExcluded by the business-base rule
Founder with your own companyPaid gerente, main activity code on IAPMEI’s listDirector, company in place before the move
Foreign investment incomeExempt, but counted to set your rateOutside Spanish tax
Foreign pensionTaxed on the normal scaleNo route in on a pension
Your spouse and childrenEach person qualifies on their ownCan opt in with you, on conditions
How you joinRequest on Portal das Finanças by 15 January after your residence yearModelo 149 within 6 months of your Social Security start date
If you’re lateBenefit runs from the year you fileNo late route

Sources: Portugal’s tax benefits statute and IFICI regulation; Spain’s income tax law and regulation, and the Spanish tax agency’s guidance. Footnotes below give each source.

Who qualifies for IFICI, and who qualifies for the Beckham Law?

IFICI asks what you do in Portugal. The Beckham Law asks why you moved to Spain. That one difference settles most cases.

Portugal: IFICI

You need a qualifying activity

A job or a board seat that passes one of seven routes.

  • You become a Portuguese tax resident
  • You weren’t resident in Portugal in any of the last five years
  • Your job or board seat passes a route’s activity test
  • You can’t have had NHR or opted into Programa Regressar
  • You can’t use it a second time
Spain: Beckham Law

You need a reason to move

A job, a posting, remote work, a directorship, or one of the innovation routes.

  • You become a Spanish tax resident because of the move
  • You weren’t resident in Spain in any of the last five tax years
  • You move because of the job, the posting, the remote work or the appointment
  • You can’t earn through a business base in Spain, outside the entrepreneur, startup and research routes
Under both

Where you stand everywhere

On the law as written in each country.

  • You can’t get in on a pension alone
  • You can’t get in on investment income alone
  • You can’t get in as a freelancer invoicing your own clients
  • You can get in as the paid director of your own company, on each country’s conditions

Illustrative diagram. Sources: Portugal’s tax benefits statute; Spain’s income tax law and regulation.

Who gets into IFICI?

You qualify for IFICI if four things are true:[1]

  • You become a Portuguese tax resident.
  • You weren’t resident in Portugal in any of the previous five years.
  • You’ve never had NHR and never opted into Programa Regressar, the scheme for returning former residents.
  • You carry out an activity on one of seven routes, such as research and teaching, a qualified job or board seat in a company whose activity IAPMEI or AICEP recognises, a highly qualified job at an exporting company, or a job at a certified startup.

You can only use IFICI once in your lifetime. The agency in charge of your route checks your work, and the tax authority checks the rest.[3]

Who gets into the Beckham Law?

You qualify for the Beckham Law if three things are true:[9]

  • You weren’t resident in Spain in any of the five tax years before your move.
  • You move because of one of the listed situations, in your first regime year or the year before.
  • You don’t earn income through a business base in Spain, except on the entrepreneur, startup and research routes.

The listed situations are:

  • An employment contract: a new job with an employer in Spain, a posting from your employer, or remote work for any employer done by computer and telecoms.
  • Becoming a company director, with any stake, unless the company is an asset-holding company, where your stake has to stay below 25%.
  • An entrepreneurial activity that ENISA, Spain’s state innovation company, reports on favourably before you move.
  • Highly qualified work for a certified startup, or in training, research, development and innovation.

Spain’s startup law loosened all this from 1 January 2023. It cut the no-residence period from ten years to five, opened the regime to remote workers and to directors with bigger stakes, and let your family join you.[11]

What rate do you pay on your salary under each?

20% under IFICI and 24% under the Beckham Law, up to €600,000 of salary a year. Above €600,000, Spain’s rate is 47%.[1][9]

The flat rate on your pay

IFICI, your qualifying pay20%
Beckham, up to €600,00024%
Beckham, above €600,00047%

Gold: Portugal’s IFICI, on your net qualifying income. Navy: Spain’s Beckham Law, on your gross employment income.

Dividends from your own company in that country

Portugal, resident rate28%
Spain, savings scale19% to 30%

Neither flat rate reaches these dividends. In Spain the scale runs from 19% on the first €6,000 to 30% above €300,000.

The two rates aren’t charged on the same amount:

  • IFICI’s 20% applies to your net qualifying income. If the normal scale works out cheaper in a given year, you can choose it instead.[1]
  • The Beckham Law’s 24% applies to your gross pay. You get no personal or family allowances, because the non-resident rules tax the full amount.[12]
  • Your employer starts withholding at the flat rate once you show them proof. In Portugal that’s proof of your filed request.[4] In Spain it’s the tax agency’s confirmation, which the rules say should arrive within ten working days of an accepted filing.[10]

Does the flat rate always save you money?

Não. In Portugal, the normal scale does about as well as IFICI up to roughly €32,500 of salary a year, on our calculadora de IRS para Portugal for an employee in 2026. The more you earn above that, the more you save.

In Spain, you’re comparing 24% of your gross salary with the ordinary scale on your net income after allowances. Where you come out ahead depends on your region and your family, so get a Spanish adviser to run your numbers.

Once you leave the Beckham Law, you can’t come back. You can only opt out in November or December, it takes effect the following year, and you can’t rejoin later.[10]

What happens to your foreign income, pensions and dividends?

Under IFICI, most foreign income is exempt, though it still counts when Portugal sets the rate on your other income. Under the Beckham Law, Spain doesn’t tax your foreign investment income at all.[2][9]

Portugal: IFICI

Exempt, but it sets your rate

Foreign-source income in five categories.

  • Your foreign employment and business income is exempt
  • Your foreign dividends, interest, rent and gains are exempt
  • It still counts when your rate on other income is set
  • Your foreign pension is taxed on the normal scale
  • You pay 35% on income from a blacklisted jurisdiction
Spain: Beckham Law

Outside Spanish tax

You’re taxed on Spanish-source income, plus all your salary.

  • Your foreign dividends, interest, rent and gains aren’t taxed in Spain
  • You pay wealth tax on your Spanish assets only
  • You don’t file the foreign-assets return (Modelo 720)
  • All your salary is taxed in Spain, wherever you’re paid
  • You can’t claim treaty residence as a Spanish resident
Under both

Local income is taxed

Investment income from inside the country.

  • Your local dividends, interest and gains are taxed either way
  • A pension alone gets you into neither regime
  • A large foreign portfolio can matter more to you than the rate

Illustrative diagram. Sources: Portugal’s income tax code; Spain’s income tax law and the tax agency’s guidance.

Foreign investment income

  • Under IFICI, your foreign employment, business, investment, rental and capital-gains income is exempt. It’s still added in when Portugal sets the rate on your other income.[2]
  • Under IFICI, you pay 35% on income from a blacklisted jurisdiction, such as dividends from a company in the United Arab Emirates in the tax authority’s own example.[4]
  • Under the Beckham Law, Spain only taxes your Spanish income, plus your salary wherever it’s paid, so your foreign dividends, interest, rent and gains aren’t taxed there.[9]

Pensões estrangeiras

Neither regime is built for retirees. IFICI taxes a foreign pension on Portugal’s normal scale,[4] and the Beckham Law has no route in for someone moving on a pension.

Dividends from your own company

Neither flat rate covers dividends from a company in the same country. In Portugal they’re taxed at the 28% resident rate.[8] In Spain they go on the savings scale, 19% to 30%.[9]

Wealth and treaties

Two more things only apply under the Beckham Law:

  • Wealth tax and the solidarity tax reach only your Spanish assets, and you don’t file Modelo 720, Spain’s return on foreign assets.[9][14]
  • You can’t claim tax treaty benefits as a Spanish resident. For treaty purposes, the tax agency doesn’t treat you as resident,[15] so foreign payers keep withholding their own tax on your dividends and interest.

How long does each regime last?

IFICI lasts ten consecutive years, counted from the year you become resident. The Beckham Law lasts six tax years: the year you become resident and the five after.[1][10]

The clocks, side by side
10 anos
IFICI, consecutive, from your residence year
6 tax years
Beckham, your residence year and the five after
5 years
you can’t have been resident before, in either country
Once
IFICI is once in a lifetime; leave Beckham and you can’t opt in again
  • Under IFICI, you need to be resident and earn qualifying income in a year to get that year’s 20%. If you start new qualifying work within six months of the last job ending, nothing is lost. A longer gap pauses the benefit, and you can pick it up again for the years you have left.[1]
  • Under the Beckham Law, your first year is the first calendar year after the move in which you spend more than 183 days in Spain. So if you move in November 2026 and become resident in 2027, your six years run from 2027 to 2032.[10]
  • Under the Beckham Law, if you stop meeting the conditions, the regime ends that same year. You have to report it within one month, and you can’t opt back in.[10]

What are the deadlines for IFICI and the Beckham Law?

IFICI: file by 15 January of the year after you become resident. Beckham: file Modelo 149 within six months of your Social Security start date. You file both online, but the two clocks start at different moments.

Portugal: how your IFICI year runs

1

You become a Portuguese tax resident: year one

2

Your qualifying pay runs in that year

3

You file the request by 15 January

4

The verifying body reports by 15 February

5

Your status shows by 31 March

File late and the 20% runs from the year you file. The ten years still count from your residence year.

You file the IFICI request on Portal das Finanças once it shows you as resident. The agency in charge of your route reports back by 15 February, and you’ll see your status by 31 March.[3]

If you miss 15 January, you can still file. The 20% then starts from the year you file, for whatever’s left of the ten. The tax authority’s own example is someone resident in 2025 who files in January 2029 and gets six years, 2029 to 2034.[4]

A marble café table on a cobbled street in front of blue azulejo tiles, with an open notebook, a pen, a blank desk calendar, a glass of water and an espresso
Illustrative image.

Spain: how your Beckham clock runs

1

Your job or role comes first, then you move

2

Your Social Security start date starts the clock

3

You file Modelo 149 within six months

4

The tax agency confirms your option

5

You file Modelo 151 every spring

The law sets six months as the maximum and gives no late route. The clock doesn’t wait for your tax residence.

Your Beckham clock starts on the date your Spanish Social Security registration begins, or the date on the certificate that keeps you in your home country’s system.[10]

  • It doesn’t wait until you’re tax resident. If you register in September and only become resident the following year, you still have to file by March.
  • Six months is the limit. If you miss it, there’s no way back in.
  • Each family member files their own Modelo 149, within six months of their own arrival or by your deadline, whichever is later.
  • Every spring you file Modelo 151 in place of the ordinary return. In 2026 it was due by 30 June, with direct debit closing on 25 June.[13]

Can a founder with their own company use IFICI or the Beckham Law?

Yes, in both countries, as a paid director. But each country checks different things.

Portugal: IFICI

The paid gerente of your own Lda

The tax authority’s guidance accepts the sole shareholder-manager of a one-person company as a member of a corporate body.

  • Your company’s main activity code is on IAPMEI’s list
  • There’s no export test on this route
  • Management consultancy isn’t on the list
  • Only your payroll pay gets the 20%; your dividends don’t

Spain: Beckham Law

The director of your own Spanish company

Any stake in a trading company works. In an asset-holding company, you need less than 25%.

  • You move because of the appointment, so the company comes first
  • Your pay as director is taxed at 24%
  • Your dividends go on the 19% to 30% savings scale
  • Invoicing the company for other work from Spain breaks the regime

IFICI with your own Portuguese company

The tax authority accepts you even if you’re the only owner and the only manager of your company (that’s route d). Just owning shares isn’t enough, though: you need the manager’s role.[4]

Your company qualifies if two things are true:

  • Its main activity code is on IAPMEI’s list. A secondary code doesn’t count.[5][6]
  • You’re its paid gerente, the manager named on the company’s registry certificate, with your pay going through payroll.

The list covers IT and software, engineering, research, manufacturing and a few other sectors. Management consultancy isn’t on it. There’s no export test on this route.[5]

Only your gerente pay gets the 20%. Your dividends from the company don’t, so if you only pay yourself in dividends, IFICI doesn’t save you anything. Our guide to IFICI com a sua própria empresa explains what to do in what order.

The Beckham Law with your own Spanish company

You can hold any stake in a trading company, even all of it. The only exception is an asset-holding company, where your stake has to stay under 25%.[9]

Becoming director has to be the reason you move. A Spanish tax firm reported in June 2026, citing elEconomista, that the tax agency was refusing directors whose company didn’t yet exist when they arrived, even when it was formed days later.[16] So have the company and your appointment in place before you move.

  • Your pay as director is taxed at 24%.
  • Your dividends from the company go on the 19% to 30% savings scale.
  • If you also invoice the company for other work from Spain, you’re earning through a Spanish business base, and that ends the regime.[9]

Do remote workers and freelancers qualify?

Remote employees qualify for the Beckham Law but usually not for IFICI. And right now, freelancers billing their own clients don’t qualify for either.

If you work remotely for an employer abroad

Spain’s law covers you by name. Working remotely for an employer, entirely by computer and phone, counts for the employment route, and so does holding the digital nomad visa.[9] You don’t need the visa itself, which is how EU citizens use this route.

Portugal’s routes need an employer whose activity is on the list. A remote job for a foreign employer with no presence in Portugal doesn’t fit them. And any work you do while living in Portugal counts as Portuguese income, wherever your employer is, so the foreign-income exemption doesn’t cover your salary.[7]

If you freelance

In Spain, freelancing from Spain counts as a Spanish business base, and that rules you out. The rules list the only business activities you’re allowed in the regime: the ENISA-backed entrepreneur route, services to certified startups, and training, research and innovation.[10]

In Portugal, freelancing on green receipts doesn’t fit IFICI’s routes. A “job” on those routes means an employment contract, and the tax authority says a services contract doesn’t count.[4]

In both countries, what changes this is setting up a company and paying yourself as its director. In Spain the company has to exist before you move. In Portugal the activity code has to be right from the day you register it.

Which regime suits whom?

It depends on who pays you and what you earn outside your salary. Here’s how it works out for four common situations.

You work remotely for a company abroad

Spain’s regime names you

Spain’s law covers remote work for any employer, with or without the digital nomad visa. IFICI’s routes need a contract with an employer whose activity passes the test, so a foreign employer with no presence in Portugal doesn’t fit them as written.

You’re founding a company in a listed activity

Both can work

IFICI gives you 20% on your gerente pay for ten years. The Beckham Law gives you 24% on your director’s pay for six, if the company and your appointment come before the move.

A local employer is hiring you

Both can work

In Portugal, your employer’s activity and your role both have to pass. In Spain, a new job with an employer there qualifies, and so does a posting from your current employer.

You freelance, or live on a pension or investments

Neither, as things stand

Neither regime has a route for your own invoices, a pension or investment income on its own. A paid directorship of your own company is the way in, on each country’s conditions.

  • If most of your wealth is a foreign portfolio, both regimes leave its income outside local tax, and the Beckham Law also keeps your foreign assets outside Spanish wealth tax.
  • If you’ll pay yourself a modest salary, IFICI’s 20% barely helps below about €32,500, and Spain’s 24% on gross pay can cost you more than the ordinary scale. The tax break on your foreign income may be the real reason to sign up.
  • If you need treaty residence for a large foreign payment, the Beckham Law won’t give it to you.
  • If you’re under 35 and moving to Portugal, IRS Jovem is the other option. Once you’ve had IFICI, you can’t use IRS Jovem afterwards.[4]

Before you choose, check these

  1. ✓Were you tax resident in Portugal or Spain in any of the last five years?
  2. ✓Who will pay you: an employer abroad, a local employer, or your own company?
  3. ✓If it’s your own company, is its main activity on IAPMEI’s list, and can it exist before you move to Spain?
  4. ✓How much of your income is foreign investment income, and how much is a pension?
  5. ✓Did you ever have NHR, or opt into Programa Regressar?
  6. ✓Which date will your Spanish Social Security registration show, and which year will be your first resident year in Portugal?

Your visa doesn’t decide either one. IFICI depends on your tax residence and your work, and the Beckham Law on why you moved. Each country’s tax authority checks your case after you file, so think of any assessment, ours included, as getting ready for that check.

A miradouro view over Lisbon rooftops at golden hour
Check your IFICI route

If Portugal is on your list, an OCC-certified accountant checks your route, your company’s main activity code or your job, and the year you’ll file, and gives you a written verdict. The assessment is €200, credited against the €1,500 application if it says you qualify. For the Portuguese side of your numbers more broadly, there’s a €99 tax consultation.

Perguntas frequentes

Is IFICI the same as the Beckham Law?

Não. IFICI is Portugal’s regime and the Beckham Law is Spain’s, and they work differently. IFICI taxes qualifying work income at 20% for ten years. The Beckham Law taxes your salary at 24% for six tax years.

Which is lower, IFICI or the Beckham Law?

IFICI’s 20% is lower than the Beckham Law’s 24%, and it applies to net income while Spain’s applies to gross pay. Above €600,000 of salary, Spain’s rate rises to 47%.

Can a remote worker for a foreign company get IFICI or the Beckham Law?

The Beckham Law, yes; IFICI, usually not. Spain’s law covers remote work for any employer, with or without the digital nomad visa. IFICI’s routes need an employer whose activity is on the list.

Can freelancers use either regime?

No, as things stand. Spain excludes income earned through a business base in Spain, and IFICI’s routes need an employment contract or a seat on a company’s board. Setting up your own company and paying yourself as its director is how you get in.

Do foreign pensions get relief under IFICI or the Beckham Law?

Não. IFICI taxes a foreign pension on Portugal’s normal scale, and the Beckham Law has no route in for someone moving on a pension.

Are foreign dividends taxed under IFICI or the Beckham Law?

Under both, foreign dividends are outside local tax, unless under IFICI they come from a blacklisted jurisdiction, where you pay 35%. Under IFICI they still count when Portugal sets the rate on your other income.

How long do IFICI and the Beckham Law last?

IFICI lasts ten consecutive years from your residence year. The Beckham Law lasts six tax years: your residence year and the five after.

What happens if I miss the deadline?

In Portugal, you can still file, but you lose the years you missed. The 20% runs from the year you file, and the ten years still count from your residence year. In Spain, there’s no late route once the six months have passed.

Can my spouse and children join?

Under the Beckham Law, yes, on conditions. Your spouse and children under 25 can opt in if they arrive before the end of your first regime year and their combined taxable income stays below yours. IFICI is personal, so your spouse needs a qualifying activity of their own.

Does living in Spain stop me getting IFICI later?

Não. IFICI only asks whether you were resident in Portugal in the last five years, and the Beckham Law only asks about Spain. Each regime looks at your past residence in its own country.

I had NHR before. Can I get IFICI?

Não. Anyone who has had NHR is excluded from IFICI, and so is anyone who opted into Programa Regressar.

Does IFICI affect IRS Jovem?

Yes. Once you’ve had IFICI, you can’t use IRS Jovem afterwards, so if you’re under 35 with qualifying income, you choose one of the two.

Sources and how we checked

  1. Portugal’s Tax Benefits Statute, article 58-A, Portal das Finanças consolidated text, read 4 November 2026: the routes, the 20% rate, ten years, the five-year test, the NHR and Programa Regressar exclusions, the six-month rule, late registration and the once-only rule.
  2. Portuguese income tax code (CIRS), article 81, paragraphs 4 and 5: the exemption for foreign income in categories A, B, E, F and G, counted to set the rate, and the blacklist rule.
  3. Portaria 352/2024/1, the IFICI procedure order, article 2 (filing by 15 January) and article 6 (15 February reports, status by 31 March).
  4. Ofício Circulado 20276/2025, the tax authority’s IFICI guide and its answers on foreign pensions, the 35% example, services contracts, single-member companies, late filing and IRS Jovem.
  5. IAPMEI, Aviso 4812/2025/2, Annex B: the activities recognised for route d).
  6. IAPMEI, Aviso 9709/2025/2, 27 March 2025: the listed code has to be the company’s main activity.
  7. Portuguese income tax code (CIRS), article 18: employment income from work done in Portugal is Portuguese-source.
  8. Portuguese income tax code (CIRS), article 71: the 28% rate on Portuguese investment income.
  9. Spain’s personal income tax law (Ley 35/2006), article 93, BOE consolidated text, read 4 November 2026: the routes, the five-year test, the business-base rule, the 24% and 47% scale, the 19% to 30% savings scale, wealth tax by real obligation and the family extension.
  10. Spain’s income tax regulation (Real Decreto 439/2007), articles 113 to 120, BOE consolidated text: duration, the six-month option, renunciation, exclusion, the documents and the ten-working-day acknowledgement.
  11. Spain’s startup law (Ley 28/2022, 21 December 2022), preamble and third final provision: the changes in force from 1 January 2023.
  12. Spain’s non-resident income tax law (Real Decreto Legislativo 5/2004), article 24: the taxable base is the gross amount.
  13. Spanish tax agency, 2026 filing and direct-debit calendar: Modelos 100, 151 and 714 due by 30 June 2026, direct debit by 25 June.
  14. Spanish tax agency, Modelo 720 questions: people in the regime don’t file the foreign-assets return.
  15. Spanish tax agency, non-residents manual, special regime: people in the regime aren’t resident for double tax treaty purposes.
  16. Pérez Parras Economistas & Abogados, 10 June 2026, on refusals where the company was formed after the move, citing elEconomista.

We read every law above in Portuguese or Spanish on the official sites. The €32,500 figure comes from our own income tax calculator, for an employee on 2026 rates. This post isn’t tax advice: whether either regime works for you depends on your facts and on the checks each country’s tax authority makes after you file.

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