Moving to Europe after a company sale: the 2026 tax and residency playbook

Relocating to Europe after a liquidity event is, above all, a tax-timing decision. Where you become resident, and when, determines how the proceeds of a company sale or a large dividend are taxed, and which residency route gives you the base you actually want. The destination matters, but the sequence matters more.

Quick answer: For most people selling a business and moving to Europe in 2026, the two big levers are when you change tax residency relative to the sale, and which tax regime you enter. Portugal, Greece’s 100,000 euro annual flat tax and Italy’s 300,000 euro annual flat tax each suit different profiles. The right answer depends on the size of the gain, its timing, and whether your priority is a one-off sale or ongoing income.

Key facts at a glance

Why the timing of your move matters more than the destination

Most European countries treat you as a tax resident once you spend more than 183 days there in a twelve-month period, though other ties can trigger it sooner. The single most important point for anyone selling a business is this: a gain you realise before you become tax resident in your new country is generally outside that country’s tax net, while a gain realised after you arrive is usually within it.

That means the calendar around your sale is often worth more than any single regime. Crystallising a sale while still resident in a low or nil capital-gains jurisdiction, or before the clock starts in your destination, can be decisive. Equally, moving first and selling later can expose the whole gain to your new country’s rules. None of this removes the need to check the exit-tax and anti-avoidance rules in the country you are leaving, which increasingly tax unrealised gains on departure.

Portugal: still the default, but the tax story has changed

Portugal remains the most common answer for internationally minded families moving to Europe, and it is our primary focus for good reason: a clear residency route, an established expatriate infrastructure, and a genuine path to EU citizenship. The Golden Visa fund route now requires a qualifying investment of at least 500,000 euros in an eligible Portuguese fund, since the real-estate and capital-transfer options were removed in 2023. Physical presence is light, at roughly seven days per year on average.

Two things have changed that anyone relocating for tax reasons must understand. First, the route to citizenship has lengthened: from 2026, most non-EU applicants face around ten years of residency before they can apply, up from five. Second, and more importantly for retirees, the old Non-Habitual Residency regime has closed to new applicants and been replaced by IFICI, sometimes called NHR 2.0. IFICI keeps a 20% flat rate but only on qualifying professional income in specific high-value sectors such as technology, science and research. Crucially, it does not shelter foreign pensions: pension income is now taxed at Portugal’s standard progressive rates, which reach 53%. The widely held belief that Portugal is a tax-free retirement haven is out of date.

For a one-off company sale, the picture is more favourable. Portuguese tax residents pay a flat 28% on gains from selling shares, and since June 2024 long-held securities benefit from partial exclusions of the taxable gain: 10% is excluded after two years, 20% after five, and 30% after eight. Combined with careful timing of when you become resident, Portugal can be efficient for a sale, even though it is no longer the pensioner haven it once was.

Greece: a flat 100,000 euros on all foreign income

Greece offers one of the cleanest propositions for a large, ongoing foreign income. Under its non-dom regime, a qualifying newcomer pays a flat 100,000 euros per year that covers all foreign-source income, whatever its size, for up to fifteen years. You do not even declare the foreign income. Family members can join for 20,000 euros each per year.

The entry conditions are specific: you must not have been Greek tax resident for seven of the previous eight years, and you must invest at least 500,000 euros in Greek real estate, businesses or securities within three years. For someone with very large recurring foreign income, or a sale that will keep generating investment returns, a fixed annual bill of 100,000 euros can be far cheaper than a percentage-based charge.

Italy: a flat 300,000 euros, and the capital-gains catch

Italy runs a similar lump-sum regime, but the price rose sharply for new arrivals. Anyone transferring residency to Italy from 1 January 2026 pays 300,000 euros per year, up from 200,000, for up to fifteen years. Those who entered earlier keep their original rate, so 2024 entrants stay at 100,000 euros and 2025 entrants at 200,000. Family members are 50,000 euros each.

The flat charge covers most foreign income, including most foreign capital gains, which is attractive for a business sale. There is one important exception: gains from selling a qualified shareholding within the first five years of the regime remain subject to ordinary Italian taxation. After that five-year window, gains on substantial shareholdings can generally fall inside the lump sum. For a founder whose main asset is a large stake in their own company, that carve-out can be the difference between a sheltered and an exposed sale, and it makes the timing of the disposal central to the decision.

So which fits a company sale?

There is no single winner, but there is a clear way to think about it. If your priority is a large, already-crystallising gain, a flat-tax regime often wins, provided you fit its rules. Greece shelters all foreign income for a fixed 100,000 euros, with no carve-out for share sales, which is simple and predictable. Italy is powerful for ongoing foreign income and most gains, but its five-year exclusion on qualified-shareholding disposals means a founder selling their own company should either complete the sale before entering, or plan to wait out the five years. Portugal can be efficient for a sale that is timed carefully around the date you become resident, and for long-held securities, but it no longer helps a retiree living mainly on a foreign pension.

Put plainly: if the question is “where do I take the proceeds of selling my business,” start with Greece and Italy on the tax, and Portugal on the lifestyle, residency and citizenship. If the question is “where do I retire on a pension,” Portugal’s tax case is weaker than its reputation suggests, and the comparison shifts.

What about Spain?

Spain used to be a natural comparison, but it abolished its Golden Visa on 3 April 2025, closing the investment-residency door for new applicants. That has pushed demand toward Portugal, Greece and Italy, and it is a useful reminder that these routes can close with limited notice. Acting while a route and a regime are open, rather than assuming they will always be there, is part of the planning.

A practical sequence

1. Model the gain and its timing first. Establish what you will realise, when, and how it is taxed where you are now, including any exit tax on departure.
2. Decide your tax-residency change date deliberately, rather than letting 183 days decide it for you.
3. Choose the regime that fits the shape of your wealth: a fixed flat tax for large recurring foreign income, a well-timed sale for a one-off gain.
4. Pick the residency route that gives you the base and the citizenship path you want, with Portugal the common anchor.
5. Take advice before you sell, not after. Almost every efficient outcome depends on steps taken before the transaction closes.

Common mistakes we see

• Moving first and selling later, so the entire gain falls into the new country’s tax net.
• Assuming Portugal still offers the old NHR pension deal. It does not; foreign pensions are now taxed progressively up to 53%.
• Overlooking Italy’s five-year exclusion on qualified-shareholding gains, then selling the company inside that window.
• Triggering tax residency accidentally by drifting past 183 days before the sale is done.
• Ignoring exit taxes and treaty rules in the country being left behind.

Frequently asked questions

Is Portugal still tax-free for retirees?

No. The Non-Habitual Residency regime is closed to new applicants and its replacement, IFICI, excludes foreign pensions. Foreign pension income is now taxed at Portugal’s standard progressive rates, which reach 53%.

Will I pay Portuguese tax if I sell my company after moving there?

If you are Portuguese tax resident when you sell, gains on shares are generally taxed at a flat 28%, with partial exclusions for securities held over two, five and eight years. A gain realised before you become resident is generally outside Portuguese scope, so timing is central.

How much is Greece’s flat tax?

A flat 100,000 euros per year covers all foreign income, for up to fifteen years. It requires a 500,000 euro investment in Greece and that you were not Greek tax resident for seven of the previous eight years. Family members can join for 20,000 euros each.

How much is Italy’s flat tax in 2026?

For new residents from 1 January 2026 it is 300,000 euros per year, covering most foreign income and most capital gains. Gains on qualified shareholdings sold within the first five years are excluded and taxed normally. Family members are 50,000 euros each.

Which country is best for selling a business?

It depends on the size and timing of the gain. Greece and Italy’s flat-tax regimes can be decisive for large gains, subject to Italy’s five-year shareholding carve-out, while Portugal can work for a well-timed sale and offers the stronger residency and citizenship path.

Does Spain still have a Golden Visa?

No. Spain abolished its Golden Visa on 3 April 2025. Existing holders keep their rights, but no new applications are accepted.

This article is general information, not legal, tax or investment advice. Investment migration rules and tax rules change frequently and depend on your personal circumstances. Figures are correct as at the date shown and should be confirmed before you act. Speak to a qualified adviser, and contact Citizenship360 for guidance specific to your situation.

Sources: Portugal tax authority (portaldasfinancas.gov.pt) and PwC Tax Summaries (Portugal); Greece tax authority AADE (aade.gr) and PwC Tax Summaries (Greece); Italy Agenzia delle Entrate (agenziaentrate.gov.it), the 2026 Budget Law and PwC Tax Summaries (Italy); Spain Official Gazette, Organic Law 1/2025 (boe.es) and EY. Figures verified July 2026.