Residency planning after 2026 reforms

The 2026 reforms tightened the edges of several long-standing residency regimes, but the core planning logic is unchanged. The question is no longer 'what's available' but 'what aligns with how you actually live'.

What changed

• Tighter substance and physical-presence tests.
• Clearer rules on the treatment of foreign-source income.
• More granular reporting where multiple regimes interact.

Planning windows that remain

• Pre-arrival planning around capital vs. income recognition.
• Trust and foundation reviews ahead of beneficiary distributions.
• Coordinated exit planning where multiple jurisdictions tax the same gain.