Illustrative sample · fictional client
Tax position and options
This is what a delivered getax report looks like. A fictional UK-resident founder weighs staying in the UK against relocating to Cyprus or Portugal; each factual sentence carries a fact version, a source and an effective date, and the last line states how many claims the factuality check supported.
22/22
claims supported at the factuality gate
22
claims across four scenarios, each bound to a fact version or derived from the profile
20
source passages quoted, in English, Greek and Portuguese
3
jurisdictions: United Kingdom, Cyprus, Portugal
What you are looking at
- The structure, the citation keys and the evidence cards are the delivered format. The client profile is fictional; no client data appears here.
- Every factual finding names a fact version from the getax fact base, current as of 1 September 2026, with its effective date where the law moves.
- Every fact-backed finding carries its source passage verbatim, quoted in the language the authority published it in: English, Greek and Portuguese.
- A relief whose conditions the client's answers do not establish is listed as conditions to verify, for the adviser to settle.
Four scenarios
The report at a glance
One baseline, the exposures that survive a move, and two destinations. Each card links to the sourced section below.
Remain in the UK
24%
on most of the gain, from 6 April 2026
Income tax reaches 45% above £125,140. Gains made from 6 April 2026 are charged at 18% within the basic band and 24% above it, and dividends above the £500 allowance reach 39.35%.
Full detail ↓
What the UK keeps
40%
inheritance tax above £325,000, whichever destination
The rental property's gain stays within UK capital gains tax after residence ends, and gifts carry the 7-year rule. Two exposures travel with the client: the property and the estate.
Full detail ↓
Relocate to Cyprus
0%
Special Defence Contribution on dividends, as a non-dom
Securities gains are exempt from income tax, and non-dom status removes SDC on dividends and interest until domicile is deemed after 17 of the last 20 years. The 2.65% health-system contribution stays, capped at €180,000 a year.
Full detail ↓
Relocate to Portugal
20%
IFICI rate on qualifying income, for ten years
Most foreign-source income is exempt under IFICI, and every gateway into the regime routes through a Portugal-anchored entity the profile does not yet have. Gains and dividends outside the exemption run at 28%.
Full detail ↓
Want to evaluate this format using one of your completed matters?
The disclosed facts
What the client told us
Every finding below is derivable from this list, and it is printed first so you can check that it is. A condition these answers do not establish stays open for the adviser.
- Client
- Edward Langley (fictional)
- Residence
- United Kingdom, tax resident
- Occupation
- Software founder; sold his company during the tax year
- Realized gains
- ≈ £600,000 on shares from the exit
- Dividend income
- From retained holdings; amount not disclosed
- Real property
- One residential rental property in the UK
- Destination
- Considering Cyprus and Portugal; no move date fixed
- Prior foreign residence
- Not disclosed
- Family
- Not disclosed
Trust vocabulary
How to read it
Every line says how it earned its place.
Validated fact
A rule of law, held as an immutable fact version. Keys look like CY-NONDOM:v1. The card shows the source passage in the language it was published in.
Derived
Computed by applying facts to this client's answers. Keys start with DF-.
Conditions to verify
A relief whose statutory conditions are listed against the disclosed profile. A condition the answers do not establish stays open for the adviser.
Side by side
Compare the rates
The exit gains and the dividend stream, across the three jurisdictions. Every value is labeled, and conditional rates are drawn as hollow marks.
Gains on listed shares, on disposal
Remain in the UK· today
18% or 24%
18% within the basic income tax band and 24% above it, for gains made from 6 April 2026. On the disclosed income, most of the gain sits at 24%.
Relocate to Cyprus
0%
Securities gains are exempt from income tax. The 20% capital gains tax reaches Cyprus immovable property and property-rich shares.
Relocate to Portugal
28% or 48%
28% autonomous rate. Aggregation at general rates, reaching 48%, is mandatory for holdings under 365 days where total income reaches the top bracket.
Dividends from the retained holdings
Remain in the UK· today
10.75–39.35%
Band rates above the £500 allowance: 10.75% basic, 35.75% higher, 39.35% additional.
Relocate to Cyprus
0% SDC
No Special Defence Contribution as a non-dom, subject to the conditions in scenario 3. The 2.65% health-system contribution is a separate charge.
Relocate to Portugal
0% or 28%
28% is the standard rate. Foreign-source dividends can be exempt under IFICI while the regime holds, on the conditions in scenario 4.
Headline statutory rates from the cited fact versions, on a shared 0–50% scale. A hollow mark applies only on the condition named in its row, and nothing here is a computed liability.
The artifact
The full report
Open any finding for the claim, the statutory conditions it depends on, and the source behind it. Download the PDF.
Illustrative sample — fictional client
getax · R-58c21f7a
Scenario 1 of 4
Scenario 1: remain UK resident
The baseline the relocation scenarios are priced against.
What this means
Staying put sets the reference numbers. Income tax reaches 45% above £125,140. Gains made from 6 April 2026 are charged at 18% within the basic income tax band and 24% above it, so most of a £600,000 gain sits at 24%. Dividends above the £500 allowance are taxed at 10.75%, 35.75% or 39.35% by band. These are headline statutory rates on the disclosed facts; nothing in this scenario depends on an unverified condition.
45%
additional rate of income tax, above £125,140
18/24%
capital gains by band, from 6 April 2026
39.35%
additional-rate dividend tax
£500
dividend allowance
The findings — open any line for the claim, its conditions and its source
Income tax: the additional rate is 45%, above £125,140
The additional rate of income tax is 45%, on taxable income above £125,140. Dividend income is taxed under its own rate table, set out below.
Source passage
Additional rate: over £125,140: 45%
Capital gains on the exit shares: 18% and 24% by band, from 6 April 2026
Chargeable gains are stacked on top of taxable income to find the band. The portion within the basic income tax band is charged at 18%, and the portion above it at 24%, for gains made from 6 April 2026. Each rate is held as its own fact version, and both carry that effective date.
Source passage
If this amount is within the basic Income Tax band, you'll pay 18% on your gains made from 6 April 2026 […] For any amount above the basic Income Tax band, you'll pay 24% on gains made from 6 April 2026
Dividends: 10.75%, 35.75% and 39.35% by band, above a £500 allowance
Dividend income above the £500 dividend allowance is taxed at 10.75% in the basic band, 35.75% in the higher band and 39.35% in the additional band. These are the rates following the Autumn 2025 Budget; each band's rate and the allowance are held as separate fact versions.
Source passage
How much tax you pay — Tax band: Basic rate; Tax rate on dividends over the allowance: 10.75% […] Tax band: Higher rate; Tax rate on dividends over the allowance: 35.75% […] Tax band: Additional rate; Tax rate on dividends over the allowance: 39.35% […] You also get a dividend allowance of £500 each year. You only pay tax on any dividend income above the dividend allowance.
The disposal dates decide which rate table applies
The 18% and 24% rates are stated as effective for gains made from 6 April 2026. Disposals earlier in the year fall under the rates then in force, which this report does not restate. The adviser prices each of the exit disposals against its date.
How this line earned its placeDerived from the profile and the effective date the cited fact versions carry. No liability is computed in this sample.
Scenario 2 of 4
Scenario 2: relocate, keep the UK property
The exposures that remain after UK residence ends.
What this means
Leaving does not detach everything. An interest in UK residential property stays within the UK capital gains tax charge after residence ends, so a later sale of the rental property is still a UK tax event. Inheritance tax at 40% above the £325,000 threshold and the 7-year gift rule shape the estate whichever destination is chosen. The regime that replaced non-dom treatment matters only if a later return to the UK is contemplated.
In scope
UK property CGT, after residence ends
40%
inheritance tax above £325,000
7 years
the gift rule's survival period
6 Apr 2025
the non-dom regime ended
The findings — open any line for the claim, its conditions and its source
UK residential property stays within UK capital gains tax after departure
An interest in UK residential property remains within the scope of the UK capital gains tax charge when a person ceases to be UK resident. Selling the rental property after the move does not take the gain out of UK tax.
Source passage
Certain assets — including an interest in UK residential property — remain within the scope of the UK CGT charge when a person ceases to be UK resident
Inheritance tax: 40% above the £325,000 threshold
The standard rate of inheritance tax is 40%. It is charged only on the part of the estate above the threshold, and the standard threshold is £325,000. How far the estate remains exposed after relocation is scoped with the UK adviser.
Source passage
The standard Inheritance Tax rate is 40%. It's only charged on the part of your estate that's above the threshold.
Gifts made within 7 years of death come back into charge
No inheritance tax is due on a gift where the giver survives it by 7 years, outside trusts. Gifts made within the 7 years before death are brought back into account, so the timing of any pre-departure gifts matters for 7 years after each one.
Source passage
No tax is due on any gifts you give if you live for 7 years after giving them - unless the gift is part of a trust. This is known as the 7 year rule.
The non-dom regime ended on 6 April 2025
The rules for non-domiciled residents ended on 6 April 2025. UK planning built on non-dom status no longer applies, in either direction of travel.
Source passage
Before 6 April 2025, UK residents who had their permanent home (‘domicile’) outside the UK did not have to pay UK tax on foreign income.
A foreign income and gains relief exists for new UK arrivals
The regime that replaced non-dom treatment provides relief on foreign income and gains for qualifying new arrivals. It is relevant to this profile only if a later return to the UK is contemplated; its conditions and duration are checked with the adviser at that point.
Source passage
UK residents may not have to pay UK tax on foreign income if they’re eligible for Foreign Income and Gains relief.
What follows this profile after departure
On the disclosed facts, two exposures stay attached after residence ends: the rental property's gain, which remains within UK capital gains tax on a future disposal, and the estate's inheritance tax position, which the UK adviser scopes before any move is priced.
How this line earned its placeDerived from GB-EXIT-001:v5 and the inheritance tax facts, applied to the disclosed profile. The estate analysis itself is out of scope for this sample.
Scenario 3 of 4
Scenario 3: relocate to Cyprus
Non-dom treatment and the securities-gains exemption.
What this means
Special Defence Contribution reaches only residents who are also domiciled in Cyprus, so a non-dom pays none of it on dividends or interest until domicile is deemed after 17 of the last 20 years. Gains on shares and bonds are exempt from income tax, which matters for any further disposals from the retained holdings. General Healthcare System contributions are a separate charge at 2.65%, capped at €180,000 of annual income. The corporate rate is 15% from 1 January 2026 if a Cyprus company enters the picture. None of the eligibility conditions is established by the disclosed profile, and scenario 2's UK exposures apply in full.
0% SDC
on dividends and interest as a non-dom
2.65%
health-system contribution, capped at €180,000
0%
income tax on gains from shares and bonds
15%
corporate rate, from 1 January 2026
The findings — open any line for the claim, its conditions and its source
Non-dom: no Special Defence Contribution on dividends and interest
Special Defence Contribution reaches only individuals who are both Cyprus tax resident and domiciled in Cyprus, so a non-domiciled resident pays no SDC on dividends or interest. Domicile is deemed acquired after residence in Cyprus in 17 of the last 20 years. The exemption covers SDC alone; General Healthcare System contributions are a separate charge, set out below.
Non-dom status: conditions to verify
- Domicile of origin outside Cyprus, and not deemed domiciled by residence in 17 of the last 20 years. The profile discloses no domicile history.
- Cyprus tax residence established in the relevant year
Open conditions are established by the adviser before the relief is priced into any decision.
Source passage
«κάτοικος της Δημοκρατίας», όταν ο όρος αυτός εφαρμόζεται στην περίπτωση ατόμου, σημαίνει άτομο που είναι κάτοικος της Δημοκρατίας, όπως ορίζεται από τις διατάξεις του περί Φορολογίας του Εισοδήματος Νόμου, το οποίο επιπλέον έχει κατοικία (domicile) στη Δημοκρατία·English'resident of the Republic', when this term is applied in the case of an individual, means an individual who is a resident of the Republic as defined by the provisions of the Income Tax Law, who in addition has domicile in the Republic.
General Healthcare System contributions: 2.65%, on income up to €180,000
General Healthcare System contributions are charged at 2.65% for an employee, and the maximum annual income on which contributions are payable is €180,000. The charge is separate from income tax and from the Special Defence Contribution, and non-dom status does not remove it. Which of this profile's income categories it reaches after relocation is confirmed with the Cyprus adviser.
Source passage
Πλήρης εφαρμογή (Από 1/3/2020): 2,65% … επί του εισοδήματός του. Το μέγιστο συνολικό ετήσιο ποσό για κάθε φυσικό πρόσωπο πάνω στο οποίο καταβάλλονται εισφορές, είναι το ποσό των €180.000.EnglishFull implementation (from 1/3/2020): 2.65% … on his income. The maximum total annual amount per natural person on which contributions are payable is €180,000.
No income tax on gains from shares and bonds
Profit from the disposal of securities is exempt from income tax. Capital gains tax at 20% reaches Cyprus-situated immovable property and shares deriving value from it: from 1 January 2026 the indirect-holding threshold fell from 50% to 20% of market value.
Source passage
(22) κέρδος από τη διάθεση τίτλων. […] «τίτλοι» σημαίνει μετοχές, χρεόγραφα, ομολογίες, ιδρυτικοί και άλλοι τίτλοι εταιρειών ή άλλων νομικών προσώπων, που έχουν κατά νόμο συσταθεί στη Δημοκρατία ή την αλλοδαπή και δικαιώματα επ' αυτών·English(22) [exempt from tax:] profit from the disposal of securities. […] 'securities' means shares, debentures, bonds, founders' and other securities of companies or other legal persons duly incorporated in the Republic or abroad, and rights thereon.
Corporate income tax: 15%, from 1 January 2026
The Cyprus corporate income tax rate is 15%, applying from 1 January 2026. It was 12.5% until then. It matters here only if the client forms or redomiciles a company in Cyprus, which the profile does not disclose.
Source passage
2. Οι Εταιρείες, υπόκεινται σε εταιρικό φόρο με συντελεστή δεκαπέντε τοις εκατόν (15%) για κάθε ευρώ φορολογητέου εισοδήματος.English2. Companies are subject to corporate tax at a rate of fifteen per cent (15%) for each euro of taxable income.
50% income-tax exemption for new residents
A new resident taking first Cyprus employment with remuneration above €55,000 receives a 50% exemption from income tax on that employment income for 17 tax years, subject to prior non-residence of at least 15 consecutive years. It is granted once in a lifetime and cannot be combined with the other employment exemptions in art. 8.
First-employment exemption: conditions to verify
- A first employment is taken up in Cyprus. The profile discloses no Cyprus employment.
- Remuneration from that employment exceeds €55,000
- Not resident in Cyprus for at least 15 consecutive years beforehand
- The exemption has not been used before. It is available once in a lifetime.
Open conditions are established by the adviser before the relief is priced into any decision.
Source passage
(23Α) το πενήντα τοις εκατόν (50%) της αμοιβής από εργοδότηση στη Δημοκρατία από άτομο το οποίο δεν ήταν κάτοικος της Δημοκρατίας για χρονική περίοδο τουλάχιστον δεκαπέντε (15) συνεχόμενων ετών αμέσως πριν από την έναρξη της πρώτης εργοδότησής του στη Δημοκρατία […] (i) η απαλλαγή χορηγείται για χρονική περίοδο δεκαεπτά (17) φορολογικών ετών […] (ii) η απαλλαγή χορηγείται για οποιοδήποτε έτος στο οποίο η αμοιβή από εργοδότηση στη Δημοκρατία υπερβαίνει τις πενήντα πέντε χιλιάδες ευρώ (55.000)English(23A) fifty per cent (50%) of the remuneration from employment in the Republic by an individual who was not a resident of the Republic for a period of at least fifteen (15) consecutive years immediately before the commencement of his first employment in the Republic […] (i) the exemption is granted for a period of seventeen (17) tax years […] (ii) the exemption is granted for any year in which the remuneration from employment in the Republic exceeds fifty-five thousand euro (€55,000).
Assessment: Cyprus warrants a full calculation. Confirm non-dom status against the deemed-domicile rule, then price the package next to the UK exposures in scenario 2.
Scenario 4 of 4
Scenario 4: relocate to Portugal
The IFICI 20% rate and the foreign-income exemption.
What this means
IFICI taxes qualifying category A and B income obtained in Portugal at 20% for ten years, and most foreign-source income is exempt while the regime holds. The demanding condition is the entity gateway: the activity has to sit in a Portugal-anchored employer or company, and the profile discloses none yet. Outside the exemption, dividends run at 28% and securities gains at 28%, with aggregation at general rates mandatory for holdings under 365 days where total income reaches the 48% top bracket.
20%
IFICI rate on qualifying income, for 10 years
Exempt
most foreign-source income under IFICI
28%
gains and dividends outside the exemption
48%
top IRS rate where aggregation is mandatory
The findings — open any line for the claim, its conditions and its source
IFICI: a special 20% rate for qualifying roles
Under IFICI, net category A and B income obtained in Portugal from eligible activities is taxed at a special rate of 20% for ten consecutive years from the year of registration as a resident.
IFICI access conditions: conditions to verify
- Becomes tax resident in Portugal in the year the regime is to start
- Not resident in Portugal in any of the five immediately preceding years; see PT-SPECIAL_RE-0AD4A5:v1 below
- The activity falls within art. 58.º-A n.º 1 and is exercised in an eligible Portugal-anchored entity. The profile discloses no Portuguese employer or company.
- Holds the qualification level the regime requires, or the evidenced professional-experience alternative
- Has not used the non-habitual resident regime or IFICI before, and registers by 15 January of the year after becoming resident
Open conditions are established by the adviser before the relief is priced into any decision.
Source passage
Este regime consagra, designadamente, a tributação à taxa especial de 20%, dos rendimentos do trabalho (rendimentos líquidos das categorias A e B) obtidos em Portugal, no âmbito das atividades consideradas elegíveis, durante um período de 10 anos consecutivos, a partir do ano da inscrição como residente em território português, sem prejuízo da opção pelo englobamento.EnglishThis regime provides, in particular, for taxation at the special rate of 20% of employment income (net category A and B income) obtained in Portugal, within the activities considered eligible, for a period of 10 consecutive years from the year of registration as a resident in Portuguese territory, without prejudice to the option to aggregate.
IFICI requires five prior years outside Portuguese residence
Eligibility requires that the individual was not resident in Portugal in any of the five years preceding the year of becoming resident. Nothing in the profile discloses prior Portuguese residence, and nothing establishes its absence either; the condition is verified with the adviser.
Source passage
Beneficiam do regime de incentivo fiscal à investigação científica e inovação os sujeitos passivos que, tornando-se fiscalmente residentes nos termos dos n.os 1 e 2 do artigo 16.º do Código do IRS, não tenham sido residentes em território português em qualquer dos cinco anos anteriores e que exerçam atividades que se enquadrem em: a) Docência no ensino superior e investigação científica […]EnglishThe tax incentive regime for scientific research and innovation benefits taxpayers who, becoming tax resident under paragraphs 1 and 2 of article 16 of the IRS Code, have not been resident in Portuguese territory in any of the five preceding years and who carry on activities falling within: (a) teaching in higher education and scientific research […]
Under IFICI, most foreign-source income is exempt
For the ten-year IFICI period, most categories of foreign-source income are exempt from IRS; income paid from a listed low-tax jurisdiction is the exception, taxed at 35%. For this profile, the exemption is what would govern dividends from the retained UK holdings while the regime holds.
Source passage
isenção sobre rendimentos das categorias E, F e G... obtidos no estrangeiroEnglishexemption on income of categories E, F and G... obtained abroad
Capital gains on securities: 28%, unless aggregation is mandatory
The positive balance of gains and losses on securities is taxed at an autonomous rate of 28%. Where the assets were held for less than 365 days and total taxable income, including that balance, reaches the top bracket of art. 68.º, aggregation at general IRS rates is mandatory.
Source passage
Não obstante o disposto na alínea c) do n.º 1, o saldo entre as mais-valias e menos-valias, resultante das operações previstas na alínea b) do n.º 1 do artigo 10.º, incluindo os rendimentos referidos nas alíneas b) e c) do n.º 18, são obrigatoriamente englobados quando resultem de ativos detidos por um período inferior a 365 dias e o sujeito passivo tenha um rendimento coletável, incluindo este saldo, igual ou superior ao valor do último escalão do n.º 1 do artigo 68.ºEnglishNotwithstanding subparagraph (c) of paragraph 1, the balance between gains and losses resulting from the operations provided for in subparagraph (b) of paragraph 1 of article 10, including the income referred to in subparagraphs (b) and (c) of paragraph 18, must be aggregated where it results from assets held for a period of less than 365 days and the taxpayer has taxable income, including that balance, equal to or above the value of the top bracket of paragraph 1 of article 68.
Dividends: 28%
Dividend income of a resident individual is taxed at 28%, unless the taxpayer elects aggregation at general rates. How this sits alongside the IFICI foreign-income exemption for the retained holdings is settled with the Portugal adviser.
Source passage
taxa liberatória de 28%Englishfinal withholding rate of 28%
The top IRS bracket: 48%, plus the solidarity rate
The top bracket of the general IRS rates table applies a marginal rate of 48% to taxable income above €86,634. An additional solidarity rate under art. 68.º-A adds 2.5% above €80,000 and 5% above €250,000.
Source passage
Superior a 86 634 — 48,00EnglishAbove 86,634 — 48.00 [per cent]
Home-sale gains excluded if the proceeds are reinvested
Gains on the sale of a property used as the taxpayer's own permanent residence are excluded from tax where the proceeds, net of any acquisition loan, are reinvested in another permanent residence in Portugal, the EU or the EEA, between 24 months before and 36 months after the sale, and the intention is declared in the return for the year of sale.
Home-sale reinvestment test: conditions to verify
- A sale of a home used as the taxpayer's own permanent residence. The disclosed UK property is let, and a let property does not meet that condition.
- Proceeds, net of any acquisition loan, are reinvested in a permanent residence in Portugal, the EU or the EEA within the window
- The intention to reinvest, and the amount, are declared in the return for the year of sale
Open conditions are established by the adviser before the relief is priced into any decision.
Source passage
São excluídos da tributação os ganhos provenientes da transmissão onerosa de imóveis destinados a habitação própria e permanente do sujeito passivo ou do seu agregado familiar, desde que verificadas, cumulativamente, as seguintes condições: […] b) O reinvestimento previsto na alínea anterior seja efetuado entre os 24 meses anteriores e os 36 meses posteriores contados da data da realização; c) O sujeito passivo manifeste a intenção de proceder ao reinvestimento, ainda que parcial, mencionando o respetivo montante na declaração de rendimentos respeitante ao ano da alienação;EnglishGains from the onerous transfer of property intended as the taxpayer's or the household's own permanent residence are excluded from taxation, provided the following conditions are cumulatively met: […] (b) the reinvestment provided for in the preceding subparagraph is made between 24 months before and 36 months after the date of realisation; (c) the taxpayer declares the intention to reinvest, even partially, stating the amount in the income tax return for the year of the disposal.
Assessment: Portugal warrants a full calculation once the IFICI entity question is settled. On the disclosed profile it is open, not established.
Assumptions, and what this does not answer
Naming what is assumed and what is excluded is part of the deliverable. Each item here is a question for the adviser.
Assumptions
- The profile above is complete and accurate. Nothing has been assumed beyond it.
- Rates and thresholds are those the cited fact versions carry as of 1 September 2026, including the UK capital gains rates that take effect from 6 April 2026.
- In the relocation scenarios, UK tax residence is assumed to end cleanly. The timing analysis sits with the adviser; see out of scope.
- No double-tax treaty relief has been modelled. UK–Cyprus and UK–Portugal treaty positions are not analysed.
- No figures are quantified. There is no computation of liability under any scenario, in any currency.
Outside the scope of this report
- UK statutory residence timing: the statutory residence test, split-year treatment and the date residence ends. The report assumes a clean break and flags the timing for the adviser.
- Treaty analysis: the UK–Cyprus and UK–Portugal double-tax treaties, including tie-breakers and relief on the retained property's income.
- Pensions: UK pension savings, transfers, and their treatment in either destination.
- Social security: UK National Insurance, Cyprus and Portugal contributions, and any coordination between them.
- Immigration and the right to reside in either destination.
- Corporate structuring: residence, management and control, and permanent establishment for anything the client retains or forms.
- Anti-avoidance provisions in the three jurisdictions, including the UK temporary non-residence rules.
- Quantification: no scenario is modelled in money.
No person qualified in UK, Cypriot or Portuguese tax law has reviewed this sample. In a delivered engagement, your firm's reviewer inspects and refines the draft in the console.
getax provides decision support and does not provide licensed tax advice. A tax adviser qualified in each jurisdiction must review every conclusion before it is relied on.
Printed on the report’s last line
Report R-58c21f7a · factuality gate: 22/22 claims supported.
The 22 claims, counted
| Section | Facts | Derived |
|---|---|---|
| Scenario 1 · Remain in the UK | 3 | 1 |
| Scenario 2 · What the UK keeps | 5 | 1 |
| Scenario 3 · Relocate to Cyprus | 5 | 0 |
| Scenario 4 · Relocate to Portugal | 7 | 0 |
| Total | 20 + 2 = 22 | |
The check runs on every draft. Every factual sentence must bind to a validated fact version in the fact base; a sentence that cannot is flagged to the firm's reviewer, and the last line states how many were supported.
Rates and thresholds go stale at 90 days. A stale load-bearing fact is withheld, and the report says so instead of citing it.
The inventory above is countable. Open any finding in the scenarios to see the fact version and the source behind it.
Every source, once
Sources index
Each authority the report cites, with the provision, the document date and the retrieval date.
- [1]HM Revenue & Customs, GOV.UKIncome Tax rates and Personal Allowances, rate table, additional-rate row · document Rates page current for the tax year, as published on GOV.UK · retrieved 1 September 2026https://www.gov.uk/income-tax-rates
- [2]HM Revenue & Customs, GOV.UKCapital Gains Tax rates, gains made from 6 April 2026 · document Rates stated as effective for gains made from 6 April 2026 · retrieved 1 September 2026https://www.gov.uk/capital-gains-tax/rates
- [3]HM Revenue & Customs, GOV.UKTax on dividends: dividend allowance and rate table by income tax band · document Rates following the Autumn 2025 Budget · retrieved 21 August 2026https://www.gov.uk/tax-on-dividends
- [4]HM Revenue & CustomsCapital Gains Manual, CG13400 · document HMRC internal manual, as published on GOV.UK · retrieved 1 September 2026https://www.gov.uk/hmrc-internal-manuals/capital-gains-manual/cg13400
- [5]HM Revenue & Customs, GOV.UKHow Inheritance Tax works: thresholds, rules and allowances · document Guidance page current as at the retrieval date · retrieved 1 September 2026https://www.gov.uk/inheritance-tax
- [6]HM Revenue & Customs, GOV.UKHow Inheritance Tax works: rules on giving gifts · document Guidance page current as at the retrieval date · retrieved 1 September 2026https://www.gov.uk/inheritance-tax/gifts
- [7]HM Revenue & Customs, GOV.UKTax on foreign income: non-domiciled residents, end of the regime · document Guidance page current as at the retrieval date · retrieved 21 August 2026https://www.gov.uk/tax-foreign-income/non-domiciled-residents
- [8]HM Revenue & Customs, GOV.UKTax on foreign income: relief on foreign income and gains for qualifying new residents · document Guidance page current as at the retrieval date · retrieved 21 August 2026https://www.gov.uk/tax-foreign-income/non-domiciled-residents
- [9]Παγκύπριος Δικηγορικός Σύλλογος (Cyprus Bar Association), CyLaw consolidated statuteSpecial Defence Contribution Law 117(I)/2002, art. 2, definition of «κάτοικος της Δημοκρατίας» · document Consolidation reflecting Ν. 245(Ι)/2025 · retrieved 1 September 2026http://www.cylaw.org/nomoi/enop/non-ind/2002_1_117/full.html
- [10]Οργανισμός Ασφάλισης Υγείας (Health Insurance Organisation), General Healthcare SystemGHS contribution rates and the annual contribution cap · document The page carries no last-updated date; its substance was checked against the Cyprus Tax Department's live compliance calendar. · retrieved 1 September 2026https://www.gesy.org.cy/el-gr/hiofinancing
- [11]Παγκύπριος Δικηγορικός Σύλλογος (Cyprus Bar Association), CyLaw consolidated statuteIncome Tax Law 118(I)/2002, art. 8(22), with the definition of «τίτλοι» in art. 2 · document Consolidation current through Ν. 67(Ι)/2026 · retrieved 1 September 2026http://www.cylaw.org/nomoi/enop/non-ind/2002_1_118/full.html
- [12]Παγκύπριος Δικηγορικός Σύλλογος (Cyprus Bar Association), CyLaw consolidated statuteIncome Tax Law 118(I)/2002, Second Schedule para. 2, as amended by Ν. 244(Ι)/2025 · document Consolidation current through Ν. 67(Ι)/2026. The Cyprus Tax Department's presentation of Ν. 244(Ι)/2025 states it enters into force from 1/1/2026. · retrieved 1 September 2026http://www.cylaw.org/nomoi/enop/non-ind/2002_1_118/full.html
- [13]Παγκύπριος Δικηγορικός Σύλλογος (Cyprus Bar Association), CyLaw consolidated statuteIncome Tax Law 118(I)/2002, art. 8(23Α) · document Consolidation current through Ν. 67(Ι)/2026 · retrieved 1 September 2026http://www.cylaw.org/nomoi/enop/non-ind/2002_1_118/full.html
- [14]Autoridade Tributária e Aduaneira (Portuguese Tax and Customs Authority)Informative leaflet, IFICI — Incentivo Fiscal à Investigação Científica e Inovação, on art. 58.º-A of the Estatuto dos Benefícios Fiscais · document Published by the AT in its contributor-support library · retrieved 1 September 2026https://info.portaldasfinancas.gov.pt/pt/apoio_contribuinte/Folhetos_informativos/Documents/incentivos_investigacao.pdf
- [15]Autoridade Tributária e Aduaneira — Estatuto dos Benefícios Fiscais (EBF), consolidated textEBF art. 58.º-A n.º 1, prior non-residence condition · document Consolidated text as published by the AT · retrieved 19 August 2026https://info.portaldasfinancas.gov.pt/pt/informacao_fiscal/codigos_tributarios/bf_rep/Pages/EBF58A.aspx
- [16]Autoridade Tributária e Aduaneira — Estatuto dos Benefícios Fiscais (EBF), consolidated textEBF art. 58.º-A n.os 10 to 12, foreign-source income · document Consolidated text as published by the AT · retrieved 14 August 2026https://info.portaldasfinancas.gov.pt/pt/informacao_fiscal/codigos_tributarios/bf_rep/Pages/EBF58A.aspx
- [17]Autoridade Tributária e Aduaneira — Código do IRS (CIRS), consolidated textCIRS art. 72.º n.º 14 · document Consolidated text as at 1 September 2026, last amended by Lei n.º 73-A/2025 of 30 December · retrieved 1 September 2026https://info.portaldasfinancas.gov.pt/pt/informacao_fiscal/codigos_tributarios/cirs_rep/Pages/irs72.aspx
- [18]Autoridade Tributária e Aduaneira — Código do IRS (CIRS), consolidated textCIRS art. 71.º, the 28% withholding rate on capital income · document Consolidated text as at the retrieval date · retrieved 14 August 2026https://info.portaldasfinancas.gov.pt/pt/informacao_fiscal/codigos_tributarios/cirs_rep/Pages/irs71.aspx
- [19]Autoridade Tributária e Aduaneira — Código do IRS (CIRS), consolidated textCIRS art. 68.º n.º 1, top bracket · document Consolidated text as at 1 September 2026, last amended by Lei n.º 73-A/2025 of 30 December · retrieved 1 September 2026https://info.portaldasfinancas.gov.pt/pt/informacao_fiscal/codigos_tributarios/cirs_rep/Pages/irs68.aspx
- [20]Autoridade Tributária e Aduaneira — Código do IRS (CIRS), consolidated textCIRS art. 10.º n.º 5 · document Consolidated text as at 1 September 2026 · retrieved 1 September 2026https://info.portaldasfinancas.gov.pt/pt/informacao_fiscal/codigos_tributarios/cirs_rep/Pages/irs10.aspx
After reading
What to do next
A report is where a firm checks the sourcing before a client acts. These are the specialists this profile needs, and the questions the report hands them.
A UK tax adviser
To run the statutory residence analysis and fix the departure date, price each disposal against the 6 April 2026 rate change, and scope the estate's inheritance tax position.
A Cyprus adviser
To test non-dom status against the deemed-domicile rule and confirm which income categories the health-system contribution reaches.
A Portugal adviser
To settle the IFICI entity gateway, check the five-year non-residence condition, and meet the registration deadline in the year of arrival.
Open questions this report leaves for the advisers
- UK statutory residence timing: the statutory residence test, split-year treatment and the date residence ends. The report assumes a clean break and flags the timing for the adviser.
- Treaty analysis: the UK–Cyprus and UK–Portugal double-tax treaties, including tie-breakers and relief on the retained property's income.
- Pensions: UK pension savings, transfers, and their treatment in either destination.
- Social security: UK National Insurance, Cyprus and Portugal contributions, and any coordination between them.
Evaluate this format on a matter you have already closed.
If the source passages and the condition checks above are what your firm wants to see, a shadow pilot runs them on your own closed files, with no client involved.