Hello, everyone. Thank you for attending this webinar. We're going to discuss today about tax impatriation. This webinar is addressed to all tax directors, all tax professionals, that are involved with the global movement of executives, and also is addressed to persons that are in the private client, private wealth management, and wish to know a little bit more what happens in the jurisdictions that we have selected when an individual emigrates to that country. So that's a little bit of the idea, especially now it's a hot topic because, I mean, we see a lot of movement of workers, globalization, nomads. Also, we see some conflicts in areas that force people to leave certain jurisdictions, and they have to land somewhere. So I think this webinar is going to give you a helicopter view on what happens in each jurisdiction. Obviously, we could not cover all the jurisdictions wherever Chelsea is present, because then it would be a webinar of two days. But we have made a selection for you. Well, thanks a lot again for attending. This webinar will last one hour, and you can obviously ask questions. There's a Q&A section in Zoom, and you can ask the questions, and the speakers will either reply as they see the question, or they will reply in return during the webinar. So thanks a lot again. I hope you will enjoy this webinar. And I think we're going to start with the jurisdiction of Switzerland. Then we will discuss about Italy, then US, UK, and then Germany, and then Luxembourg with my colleagues here present. So thank you very much. And René, the floor is yours. Yeah, thank you very much, Rafael. Hello, everybody. My name is René Schreiber. I'm a tax partner at Everset Sutherland, Switzerland. The next few minutes, I will give you a quick overview about migration to Switzerland, please. Next slide. Once you can go ahead, yeah. We start with migration. Migration to Switzerland for EU and EFTA citizens. It's a quite easy task because these nationals are legally entitled to live and work in Switzerland. The process is a straightforward registration. For third country nationals, the situation is a little bit more complex, and the admission is generally reserved to live in the countries of Switzerland for highly qualified profiles if they are workers or ultra-high network individuals, and all applicants must demonstrate an overriding economic interest. Then a practical tip here. Start the process early because federal quotas to come to Switzerland for non-EU or EFTA citizens is set for each year. And if these quotas are exhausted, you may face significant delays. Next slide, please. Regarding Swiss tax system, it's a little bit similar to the US tax system. We have three levels of taxation, the federal, canton, and communal level. The income tax and wealth tax rates for individuals are progressive on the income tax level. The combined tax charge for all three levels range between roughly 20% to 45%. These are always the highest tax brackets because it's a progressive system. The net wealth tax is levied annually and is between 0.1% to some 0.9% of the net wealth. Again, highest tax brackets. And depending on where you are tax resident, in which canton, which city of Switzerland. Two other important points. Switzerland has a very extensive treaty network with roughly more than 110 double tax treaties. And also, it is a ruling jurisdiction, which means advanced tax rulings are available or in some instances, even strongly recommended by the tax authorities. So, you can get legal certainty about the tax consequences of a transaction, EG, before you implement it. On the next slide, we quickly touch upon capital gains for individuals. And being in the private wealth, this is very, very important. Privately held, movable assets. If you sell them in Switzerland, in general, you can realize a totally tax-free capital gain, which is obviously where we want to go to. For real estate capital gains resulting from the sale of Swiss-located real estate, the situation is a little bit different. There we have a real estate capital gains tax, which is levied on a cantonal level only in private wealth. The rates vary significantly between some 10% up to 50%. And the holding period is determining, and also, of course, the amount of the capital gain is determining the tax rate. Maybe as a takeaway, foreign real estate, be it in a treaty jurisdiction or at tax havens, are not taxed at all. Foreign real estate are not taxed in Switzerland. Wherever they are located. Now, what's about dividends? The next slide, please. Taxation of dividends in Switzerland from qualifying participations, i.e. bigger than 10%. They are taxed on a reduced level. The tax, effective tax rate, again, depending on the canton, varies between some 12% to some 32%, depending on the amount of the dividend paid out, and the canton again. From other participations, there is, for other participations, for dividends from them, there is no reduced taxation, and these dividend payments are taxed with the overall taxable income. If we talk about, on the next slide, withholding tax, the statutory rate is significantly high in Switzerland. 35% levied on dividend payments or interest from banking loans or bond-like loans. For Swiss tax residents, there is a full refund subject to the declaration. The correct declaration of this income, full refund, so it's only a provisional tax. For non-residents, it depends whether they are located in a treaty jurisdiction. The standard rate is 15%, according to OECD model tax treaty. If we talk about the special tax regime, which may be, on the next slide, very interesting, for early retired or retired individuals, ultra-high net worth individuals, there is the lump sum tax system. Swiss citizens are not eligible, and the clue of this tax system is that the individual is only taxed on an assumed expenditure, and not on effective worldwide income and wealth. which means this individual does not have to disclose the income and the wealth, but just the expenditures. No gainful activity allowed in Switzerland, and these individuals who want to apply for it are not allowed to stay in Switzerland before they want to have this tax regime for the last 10 years. 21 of 26 countenance, this is available, and you always should go for an advanced tax ruling for these cases. We have quite a lot of cases to deal with for ultra -high net worth individuals and wealthy families. What's about inheritance and gift taxes? On the next slide, there is no federal, that's important, no federal inheritance or gift tax. The left parties from time to time want to implement one. Swiss voters, Swiss people have always voted against it. It's only levied at cantonal level and at progressive rates. Most importantly, any transfers to spouses and direct descendants in 24 of the 26 cantons, they're fully tax exempt, notwithstanding the amount which is transferred. So, it's the rule for Swiss real estate, foreign real estate, again, not taxed. Now, what are the key takeaways on the last slide of my short speech? The key takeaways are, before you want to come to Switzerland, you have to deal at the early stage with the migration questions. When it comes to taxes, the most important message is carefully choose the place you want to go, the canton. We also have four official languages in the country in which canton you want to stay. The tax rates are significantly low and this lump sum tax regime may be advantages for wealthy families, wealthy individuals. A succession is mostly tax -free and advanced tax rulings you should go for because it's very advantageous. So, that was a quick rush and an overview, a short overview about the taxation in Switzerland for migration cases. I'm now, if I don't doubt Rafael, I'm very happy to hand over to the next speaker, my colleague Gianluca from Italy. Thank you very much. Thank you, Reme. I am Gianluca Nemec, tax partner in Italy, based in Milan. I will briefly provide you with an overview on two favorable tax regimes for individuals in Italy. So, post Brexit and amid growing global tax pressure, Italy has positioned itself as an attractive destination for high net worth individuals seeking favorable tax treatment. The decision to transfer the tax residence is never taken lightly. However, Italy's flat regime has changed the game for many entrepreneurs, international investors, professionals, actors and sport people. In our experience, advising clients through the intricacies of this Italian transfer, we have witnessed at first hand how Italy's flat regime can deliver substantial tax efficiencies when properly navigated. So, the key features are the flat annual substitute tax, no link to the actual amount of foreign income, optional irrevocable election, maximum duration of 15 years, and Italian sourcing can remain subject to ordinary Italian taxation. We will see in the next slide who can access the regime. So, the individual must offer tax residence to Italy, the applicant must not have been taxed in Italy for at least 9 out of 10 tax years preceded in the transfer. A formal action must be made in the tax return, and the regime applies on an individual basis and may be extended to eligible family members upon request. So, Italy first introduced its flat tax regime for high net worth in the rules in 2017, and the initial program established 100,000 annual substitute tax. Most recently, in August 2024, the Italian government increased increased to 200,000 euro and now currently the amount has been increased up to a flat tax of euro 300,000. Let's find on the next slide what the flat tax replaces. So, the substitute tax replaces Italian ordinary personal income tax, wealth taxes, and inheritance gift taxes on foreign sourced income and assets. So, Italy's flat tax offers a remarkable simplification, replacing this entire structure with a single annual payment that covers all foreign sourced income. So, it covers foreign sourced income like dividends, interest, capital gains, rental income, foreign pension income, capital gains from the sale of qualifying foreign shareholding, foreign estate and financial assets, so wealth taxes, foreign assets for foreign income and gift tax purposes, and it is crucial to understand that domestic sourced Italian income remains subject to ordinary taxation under Italy's progressive tax rates. So, in the next slides I will briefly touch another very favorable tax regime in Italy, the so-called impatriate regime. So, this special regime applies to inbound workers and then ties the beneficial tax treatment of Italian sourced employment and self-employment income. So, it is, let me say, direct mainly to employees within multinational income and international income. Due to the EU, the minimum wage, the minimum wage restrictions, the tax benefit for the self-employment income is capped at a maximum amount of Euro 300,000 over the three-year period. So, how does this regime work? The regime provides that under central condition, employment, and self-employment income, or self-employment income, derived from Italian activities, gained by individuals who transfer their tax residence to Italy, is taxable as to 50% of its amount, with the other 50% being exempt, up to a maximum annual income of 600,000 Euro. The portion of taxable income is reduced to 50% of its amount of income income is reduced to 50% to 40%, sorry, with the 60% being exempt if the worker moves to Italy with a minor child or in case of a birth of a child during the period of application of the regime. In this case, the higher exemption will start apply for the tax period in which birth occurs. In any case, it is required that the minor child remains an Italian tax resident during the period of application of the regime. Who can be eligible? The application of the paternal regime is subject to the following requirements. The employee must have been changed during the years several times. The employee must not have been tax resident in Italy in three tax periods preceding the first tax period of Italian tax residence. However, if the employee carries out to work in Italy for the same entity employer which employed him or her abroad before the relocation or for an entity belonging to the same group, the requirement of past foreign residents is longer and is respectively. Six tax periods if the employee has not previously been employed in Italy by the same company or by a company belonging to the same group or seven tax periods if the employee prior to moving abroad was employed in Italy by the same company or by company belonging to the same group. This recent modification has been changed in the last last provision of law from the beginning of 2025. So next slide. Here just some condition that the tax residents in Italy must be maintained for at least four years, failing which the tax relief will be withdrawn and the benefit already received will be recovered, together with the interest but with no penalties. The work must be performed within the Italian territory for the majority of the tax year, and the requirement for high qualification and specialization applies for the new transfer in Italy. So the tax benefit is directly applied by the employer that upon payment of the salary shall levied the reduced with the tax, so on the reduced taxable basis. And an election to the employer is required. Alternately, an election can be made directly in the income tax return by the employee. So we believe that these two regimes, let me say, keep the Italian regime very favorable for this kind of multinational transfer across Europe within multinational group. Thank you very much. Okay, excellent. So I think our next speaker is Brigitte. The floor is yours. Thank you. My name is Jo and I'm in the Washington D.C. Now I'm going to take us through the U.S. perspective on relocation to the U.S. And starting with the foundational principle, U.S. citizens and green card holders, that is lawful and permanent residents, are subject to U.S. tax on their worldwide income, regardless of where they live. For everyone else, non-U.S. citizens or aliens, as they're referred to in the Internal Revenue Code, are The tax treatment depends on whether they are classified as a resident or non-resident alien. Resident aliens are taxed on worldwide income, just like U.S. citizens. However, non-resident aliens are taxed only on U.S. income. So the threshold question for anyone relocating to the U.S. is, what is their residency status? U.S. domestic law uses two main tests to determine residency for tax purposes, which we'll look to on the next slide. First test is the green card test. So if a person holds a green card for any portion of the taxable year, they will be treated as a resident alien for the entire taxable year. The substantial presence test is a little bit more complicated. It's a mathematical formula where the individual must be present in the U.S. for at least 31 days in the current calendar year and must accumulate at least 183 days under a weighted formula, counting all the days in the current year, one-third of the days in the immediately preceding year, and one-sixth of the days in the second preceding year. There are certain exclusions to days spent in the U.S. for purposes of the substantial presence test. So if you're in the U.S. on a certain visa or days when you're prevented from leaving to the U.S., those would not be counted for purposes of the substantial presence test. However, generally, if you're in the U.S. for at least six months within the first taxable year or within the current taxable year, then you'll be considered a resident under the substantial presence test. However, on the next slide, we'll discuss an exception to the substantial presence test. So if you're in the U.S. for fewer than 183 days in the current year and maintain a tax home in a foreign country and a closer connection to that country, you may avoid U.S. tax residency even if the substantial presence test would otherwise be met. And additionally, tax treaties can provide a role in residency determination. So on the next slide, it's common for individuals to qualify as a tax resident of two countries simultaneously under respective domestic laws. And when that happens, an applicable tax treaty will provide a series of tiebreaker rules. On the next slide, we'll turn to the discussion of taxation of certain types of income in the U.S., beginning with compensation. The key sourcing rule is that compensation is sourced based on where the services are performed. So for a non-resident alien, they are subject to tax on U.S. source services unless a treaty exception applies. U.S. citizens, green card holders, and resident aliens will be subject to U.S. tax regardless of source. And compensation in the U.S. is treated as ordinary income and is subject to federal income tax at graduated rates ranging from 10 to 37 percent. And in addition to federal income tax, we also have state and local income taxes in many jurisdictions and compensation will typically be subject to that depending on the state or locality. And this varies vastly among the states and cities in the U.S. Compensation will also be subject to social security tax, including Medicare tax, unless there's a totalization agreement between the United States and the individual's home country. Turning to the taxation of capital gains, a non-resident alien in the U.S. is generally not subject to any U.S. tax on capital gains. However, there is an exception for capital gains related to U.S. real estate. On the other hand, U.S. citizens, residents, and green card holders will be subject to tax on capital gains regardless of the source of that income. The holding period of the asset is relevant for the rate of taxation. So if an asset is held for one year or less, it will be taxed at the same ordinary income rates as compensation, up to 37 percent. However, if the asset is held for more than one year, there are preferential tax rates of zero, 15 or 20 percent. There's also a 3.8 percent surtax on certain taxpayers with income that exceeds threshold amounts. Turning briefly to interest income. So on the next slide, interest income is sourced by the residents of the payor. So any interest from, for example, a U.S. bank account is U.S. source, but any interest from a non-U.S. bank account would be non-U.S. source. Non-resident aliens are subject to a 30 percent withholding tax on their U.S. source interest unless there's a treaty exception or a portfolio interest exemption. U.S. citizens, green card holders, and resident aliens will be subject to U.S. tax on interest income regardless of the source of that income. Turning to dividend income on the next slide, it's very similar to interest income where the source of the dividends is determined by the incorporation of the payor or whether the payor is carrying on a U.S. business. Non-resident aliens, like on interest income, will be subject to a 30 percent withholding tax on U.S. source dividends. And U.S. green card holders and resident aliens are subject to U.S. tax regardless of the source of that income. Now for carried interest, on the next slide, non-resident aliens will be subject to U.S. tax on their carried interest if it originates from a U.S. trade or business. However, U.S. citizens, residents, and green card holders will be subject to tax on worldwide carried interest. Carried interest is generally taxed at ordinary rates unless the interest is held for more than three years, in which case carried interest will be taxed at the same preferential rates as long-term capital gains. There's an ongoing legislative debate in the U.S. regarding proposals of taxation of carried interest. So this is an area where things may shift in the future. The next slide, we briefly cover information reporting that's required of U.S. citizens, green card holders, and resident aliens. So it's important to note what your non-U.S. assets are and whether you would be required to comply with any of these reporting regimes. And it is not required if you are not a U.S. resident. And on the next slide, a brief overview for planning for a U.S. resident. You'll want to consider whether it's worth it to dispose of any assets or recognized gain prior to your residency in the U.S. to avoid any U.S. taxation. Another key thing to note is analyzing interests in foreign businesses to determine whether any of those interests may become a controlled foreign corporation based on U.S. attribution rules, which would subject that income to current U.S. tax under certain regimes. And finally, on the last slide, we have a brief example of a non-U.S. citizen who is working abroad for five years, earning a salary, a performance bonus, and interest income from a non-U.S. bank account. On April 1st, 2026, she moves to the U.S. and will live in the U.S. full time for at least a year. So in this case, assuming no exceptions apply, she should be treated as a U.S. tax resident. And would be taxed in the same manner as a U.S. citizen on worldwide income. And she would satisfy the substantial presence test and may have certain information reporting requirements. And that is all from the U.S., the brief overview of the U.S. side. So I will turn it over to Charlie to discuss the U.K. Thanks very much. So this is going to be a bit of a canter through because there's obviously so much to talk about. But I think that the starting point at a 10,000 feet level is that before the last few years, the U.K., I think, it's fair to say, was seen as a middling to actually pretty good destination for high net worth individuals, considering where to get good rates on their carry, potential inheritance and offshore wealth. But following the last two years, we've had a series of reforms that I think put the British definitely no higher than the middle of the pack amongst Western nations. So what we used to have, and this is this predates the new foreign income and gains regime, which you're seeing on this slide, was something called the remittance basis and the concept of a non-DOM. How this used to work is that if individuals said they regarded another country as their permanent home, all of their offshore wealth was exempt from U.K. tax on income and gains, provided all that wealth was kept offshore. And there was an annual charge that kicked in after a certain period of time. But this status expired after 15 years, so a very long time that it was available. That's gone. So in the new regime, yes, the U.K. offers new arrivals, a four-year period, during which they'll be exempt on their offshore income and gains, whether remitted or not. So I guess that's a plus. But four years is obviously much lower than 15. But the eligibility for this new regime is much sort of tighter and difficult. You have to have been U.K. non-resident for 10 years prior to your first year of using the foreign income and gains regime. There's no annual charge to use this new regime, so I guess that's a plus. But it has to be claimed annually for each year through the U.K. self-assessment procedure. And whilst not all income and gains that are offshore are technically covered, there are some exceptions, all of the income and gains that are offshore that the individual intends to benefit from the regime have to be reported. And it's worth noting that there are special rules which are far too complicated for the purposes of this presentation for trusts and settlements, which we can help with. And I should also just say that this new regime that was brought in sits alongside probably the most complex statutory residence test in the world. So the U.K. is kind of infamous in tax circles for having these very surprising ways in which individuals can become U.K. tax resident. So we can help kind of not only with navigating new arrivals intending to use the FIG regime, but whether there are people who come to the U.K. a lot and want to know for sure where they stand with regard to U.K. residents. So on the next slide, please, I will discuss. Hello. Thank you. I will discuss just sort of the basics on income and gains that are good to know. So I think most people will be aware the U.K. has got a progressive system of tax with rates staggered across the basic additional and the higher bands. These bands, which are not on the slide, they are the reference point for how most income and gains are taxed. It's worth noting, though, that these bands are not, they don't apply equally across dividends. So, for example, dividends have a lower rate of income tax applicable to them than interest. And gains are taxed at the highest at 24 percent. That's at additional and higher rates, whereas income goes from 20 to 40 to 45, depending on which band you sit in. Employment taxes. So the way employment taxes work in the U.K., as I think a lot of people will know, is through a system called PAYE, where the employer remits to HMRC the national insurance contributions and the tax due in respect of their employees. It's an interesting system. And we recently advised a large U.S. asset manager on relocating an individual from Dubai to London, bearing in mind that she was employed by the Dubai entity. And in London, they already had a branch. It's not always the case that foreign employers need to operate PAYE in respect of their U.K. employees. So there are some nuances to watch out for there. And we can help with that. In fact, in this case, we ultimately recommended that PAYE wasn't necessary. So it's worth just being alive to that. I'll also touch on carried interest. So we have had a new qualifying carried interest regime that's come into force from the 6th of April, 2026. Carried interest used to be taxed in the U.K. as gains at 28 percent. But over the last year, the rate in the year before this year, the rate went up to 32 percent. And this year we find ourselves in an entirely kind of new carried interest universe. The effective rate is 34.1 and it's deemed trading income. This is not a change that was obviously brought in to make the U.K. more competitive. It was brought in to sort of level the playing field in response to kind of public opinion on carry. This shift to deemed trading income does bring with it some significant implications. So there's a potential for extraterritorial taxation. So people have to be careful that if they're coming to London to work and that period of work results in them realizing carried interest when they're then offshore, they could still be subject to U.K. tax, although we're yet to see how that kind of plays out. And it's worth noting that this 34.1 percent rate is only available to carried interest holders whose funds meet the newly sort of established average holding period, which is a minimum of 40 months. So the rules look at whether funds have held their assets for at least 40 months before disposing of them. Otherwise, and if you don't meet that, you're into normal income tax rates. So up to 47 percent on carry. Last slide, please. Finally, so there's the inheritance tax regime. And again, we used to sort of we used to have a friendlier regime. The basics are that inheritance tax is taxed at 40 percent on worldwide assets for U.K. residents above 325,000. But under the old regime, the inheritance tax of U.K. residents was based technically on their domicile. So it was possible for individuals who had significant offshore wealth to claim that they were actually non-dom. And so that portion of their offshore wealth could escape U.K. taxation. That's now gone. And whether someone falls into the U.K. inheritance tax net is now based on residence. And so if you were resident in the U.K. for 10 out of the last 20 years, you could potentially be in the U.K. income tax net. People have worry about this new sort of tail that follows them even after they leave the U.K. And finally, there is still this seven year rule. So in the U.K., gifts generally go tax free and aren't subject to inheritance tax. But if an individual gives an asset and dies before seven years have elapsed, a portion of that asset could be subject to inheritance tax. So with that incredibly fast canter through, I will gratefully hand over to Stefan, who's going to talk about Germany. Good afternoon. Yeah, my name is Stefan. I'm a tax lawyer and tax partner in Germany. Germany is generally viewed as a high tax jurisdiction. And that is usually the right starting assumption for anyone thinking about a move back to Germany or a relocation into Germany. That said, there are some important exceptions. And those exceptions often drive planning discussions. Certain income and capital gains from capital investments can fall outside the normal high tax picture. The same is true for capital gains from real estate if the property has been held for more than 10 years. And truly exempt income can also be important because Germany has a broad double tax treaty network and in many cases applies the exemption method. So while the general reputation is high tax, the practical result depends very much on the type of asset, the holding period and whether treaty protection applies. With that German specific context in mind, let me turn from the headline position to the basic income tax framework. Turning the basic income tax framework, Germany taxes individuals on their worldwide income once they arrive in Germany and become tax resident in Germany. There is no FIG regime. So the standard framework is the regular worldwide income approach rather than a special foreign income regime. The rate system is progressive, which means the tax burden rises as income rises rather than applying one single rate across abroad. For 2026, there's a basic tax free allowance of EUR 12,348 per individual. For married couples using specific spousal tax splitting, that amount is effectively doubled. On the top of that, there are additional allowances as induction areas such as employment income, health, insurance and certain other expenses. Next slide, please. Germany is known for high tax rates, as you can see from the table. In 2026, each individual first benefits from the allowance already referred to. And after that, the system rises progressively. So the rate does not jump at all at once. Instead, it increases step by step as income moves higher. That progressive buildup continues through the middle income ranges until the regular top rate of 42% applies. For very high income, the additional top rate is 45%. For international mobile individuals, that matters because the tax cost of relocation depends very much on the type of income, level of income and residence. For those general mechanics, let me move to a more structural point that very often comes into play in country-by-country comparisons. And this is the German CFC regime, which can apply on managers and high net worth individuals moving to Germany. Many such individuals hold assets through foreign holding companies. And that structure have worked perfectly well before they move to Germany. But once they arrive in Germany, Germany may look through the foreign company and in certain cases attributed income back to the shareholder. This becomes relevant, especially where the company is located in low-tech jurisdictions and earns income that Germany regards as passive. What is important in practice is that the rules do not apply to every foreign company and not every type of company. The concern is mainly passive income. Next slide, please. Passive income is a certain type of income. And in simple terms, a low level of taxation applies if the overall taxation of the company is less than 15%. This becomes in particular important if the manager or high net worth individual was a resident or used companies in certain well-known jurisdictions with low taxes, such as the UAE, Saudi Arabia, Hong Kong, certain cantons in Switzerland, Channel Islands or Caribbean jurisdictions. So the practical takeaway is straightforward. Assets and income streams and asset holding companies should be reviewed and, when necessary, restructured before someone enters Germany. Next slide, please. Staying with Germany, a specific part of the comparison is the income regime for which the flat income tax applies. Germany applies a flat income tax of 25% to income on capital gains and from capital investments. In practice, that means this regime can be significantly more favorable than the ordinary progressive income tax, which we discussed earlier. Against this backdrop, the regime typically covers dividends, including dividends for portfolio holdings, as well as dividends and income from investment funds, interest, and so on. The planning point, therefore, is critical and obvious before someone moves to Germany. The detailed review should be made in order to verify whether a specific ongoing income can re -qualify or upforce under the flat tax regime. Next slide, please. Now I want to touch base on some specific issues that often become relevant for managers when they move to Germany. So, when a manager is entitled to severance payments, usually Germany taxes those payments. However, there are specific exemptions if the manager receives the payment from a foreign employer and is taxed in the state where he worked before he went to Germany. Under certain circumstances, treaty relief applies and so taxation in Germany can be avoided to a certain extent. The same rules basically apply to bonuses. When the bonus is paid for work performed by the manager before he moved to Germany. Next slide, please. Pensions and carried interest are also important for managers and high net worth individuals when moving to Germany. Pensions are basically taxed in Germany, irrespective of where the original pension plan was set up. However, under certain circumstances, some treaty relief may be available for pensions earned when people worked abroad. In connection with pensions, it's also important to remember that private and individual set up pensions plans may cause difficulties in Germany, in particular if they are continued after the person arrived in Germany. Carried interest. Carried interest taxation in Germany is a quite complex issue. So it would take quite a while to explain all the relevant details. So I want to just focus on the headlines. Taxation very much depends on how the carried interest is structured. So there are typical structures for which the standard tax rate applies, which can be the top rates of 42 to 45 percent. Or under certain circumstances, income from carried interest is qualified as a subject to the flat tax regime for which 25 percent tax is available. Next slide, please. So finally, I want to give you a brief overview of inheritance tax and gifts tax, which is a very important issue in Germany. Germany tax, Germany applies inheritance and gift tax on every transfer of wealth within, within families or to, to other people. The tax rates are quite high, as you can see from the table on this slide and end up, up to 50 percent of the transferred wealth. Certain limitations, exemptions apply in particular for wealth transfers between close members of a family. Certain allowances are available starting with 100,000 and ending up to 500,000 for transfers between spouses. So for individuals moving to Germany, it is very important to have a proper inheritance and gift tax planning made before they go to Germany. And in particular, if transfers between parents and children and children or between other family members are planned, such transfers should ideally be made before the people arrive in Germany. So with that final German point in mind, I want to hand over to my colleague, Raphael, who will provide you an overview on Luxembourg. Hello. Thank you so much, Stefan. Look, it's really interesting to see all the systems that we have seen, because you can see that there is, you know, there are some countries that don't put many things in place for attracting more people. And you see other countries that put in place tax measures in order to attract talent and sophisticated persons. Luxembourg is clearly the case of a jurisdiction that wants to attract sophisticated people, talent, in order to allow the growth of the country and economy. Luxembourg is a small country, but growing country in terms of population. And it is clear that the growth of Luxembourg would have not been possible without that the immigration of skilled persons that has happened the past years. OK, so I think it's a good thing. So as you will see, as you will see in this presentation, Luxembourg is a good jurisdiction. I would qualify it as a good jurisdiction for impatuating. So to become resident, I think for executives and high net worth individuals, as you will see, the country does the objective to attract these type of persons and has put the tax system in really compatible with these persons. So it will not be really for tax reasons that people will not come. Maybe they will come. They will not come for other reasons, but at least it's not the tax. So as a start, I would like to before I start with this slide of impatriate regime, I would like to highlight three things. First of all, Luxembourg does not have does not have net worth tax. It might seem obvious for many countries that don't have net worth tax, but certain countries in the world have net worth tax. So we're seeing movement of in Luxembourg into Luxembourg from individuals that cannot afford the net worth tax imposed in their home countries. And they decide to move to a country that is no net worth tax. That's something we're seeing a lot. Luxembourg also another good thing we have in Luxembourg is that we have no exit tax for individuals. So for individuals, we have no exit tax, which allows the presence in Luxembourg kind of neutral. It's not that you are in a tax prison that any Latin gain that you may have generated in Luxembourg, Luxembourg will ask you afterwards. You know, some tax, you know, some tax even after you have left the country. So that makes it kind of, let's say, interesting for executives or high net worth individuals, because what you don't want to do is to have an evaluation when you come. And then when you leave another evaluation and then be taxed and have some sort of dry tax or some sort of eternal or long term tax liability in Luxembourg. So that's something we don't have. We don't have no exit tax. And another thing we don't have is we don't have CFC rules. OK, we have seen the presentation of other countries that are more high tax jurisdictions that have CFC rules. We don't have for individuals. We have for companies, but not for individuals, which makes kind of interesting for. For yeah, for individuals to come to Luxembourg. So with this little introduction, I would like to discuss about the impatriate regime. As in Italy, Italy has also a regime in of for impatriates. We have I would not say a similar one, but the numbers look a bit similar. OK, there is the 50 percent exemption. Also is limited for 400000 euros a year. The duration is eight years. I think in Italy was five more extendable. I think in Italy was up to 600000. Here in Luxembourg is 400000. So we have some sort of similar regime. The regime is not applicable to bonuses and variable pay. And who qualifies for this impatriate regime? Well, basically seconded persons from groups. So if you're in a group of companies, that's fine. Or if the Luxembourg employer recruits directly from abroad. So that's that's also OK. You can benefit from that regime. That's for the and then the employee has to have his main residence in Luxembourg. He cannot have been resident the past five years. And he has to perform 75 percent of his work in Luxembourg. OK, and as you will see, this does not apply. This applies to high salaries as from 75000 euros, which is I mean, it's for management. OK, in 75000 in Luxembourg is for managers is as from manager level. So it's not for, you know, more junior people that could have lower salaries. OK, and the employee cannot, let's say, replace a non-impatriate employee. It cannot it cannot replace. It has to bring something new to the economy, to the to the. To the country. OK, there are some other restrictions. For example, you cannot have a company with more than 30 percent of the workforce under this regime. However, for companies that have been just created in the past 10 years, this limit does not apply. So for companies of new creation, startups, this works very well. And well, there is some compliance requirements that have to be fulfilled. So, yeah, it's really interesting. We have seen some recently some people that were in the Middle East that have just moved to Luxembourg and the asset managers. And they have they are benefiting from this regime and combined with the next the next regime we're going to discuss, the current interest regime. And if we can pass to the next slide, that would be great. So you see, we have in Luxembourg a special regime for current interest that can bring the taxation to zero percent. So this is much used by asset managers. We have seen in the newspapers a lot of movement in this respect. We have seen a movement from other jurisdictions of managers, asset managers, individuals moving to Luxembourg this year in 2026 due to this new regime, which is very interesting. And combined with the 50 percent exemption on the taxing patriot regime makes it a good combination. Plus the no net wealth tax, plus no CFC rules, plus no exit tax. It's a good tax environment for attracting sophisticated people. OK, I wanted to also discuss. So I would not go into the details of the current interest regime, but we typically advise to this, you know, to asset managers to in order to benefit from this regime. And also we advise clients on applying the 15 percent regime. If we come back to the next slide, I would like to say that in addition to all what we have discussed, we have also a very good, we have a favorable regime for investment income. OK, so capital gains of participation of less than 10 percent are exempt. And if you wait six months, this makes the happiness of bankers, because when they have a diversified portfolio, as soon as they usually in the portfolio of clients, they don't have significant participations and they sell, if they wait six months, they are exempt. So it's a really interesting rule for high net worth individuals and executives, sophisticated people that may have portfolio and investment income. Also, for dividends, we have a 50 percent exemption, which brings it very, very, also very low, the taxation of financial income. And also you can credit the taxes that you may have paid abroad, which is also very interesting. So, as I said, favorable, no net worth tax, no CFC rules, no exit tax, no good taxation of financial income, impatriate regime, uninteresting carried interest, I think is a good, is a good bunch of measures that make Luxembourg very attractive in this respect. So, yes, and also this is really good because the attraction of these people also bolsters the substance of many fund structures, holding companies and multinationals. And yeah, and it's good for the operations of all these economic actors. And last but not least, my last slide I would like to discuss about, we have a tax step up for participation more than 10 percent. We have your tax, if you do a capital gain, but your tax at the half. So you're just taxed up to 23 percent. But if you come from abroad, basically you have a step up in basis. So you can step up your acquisition cost. So the capital gain generated in the previous, before migration is not taxed in Luxembourg. That's also a great tool for, that's great for high net worth individuals or for entrepreneurs, because their capital gains that were generated before the migration are not taxed here. They will certainly be taxed in the exiting country. OK, so this is a measure to correct. And obviously, if you can play a little bit that in the other country they don't tax, and here we benefit from the step up, then you have some efficiencies. OK, so this is also a very interesting tool in order to, let's say, improve and attract the talent. Well, with all this, I wanted to close about Luxembourg. Obviously, I was the last one, so if you have any questions, don't hesitate to ask them to us via the chat here. We will be more than pleased to reply to them. We will also share the presentations with you, and you will see that over our emails. And obviously, if you have any question, anything, we will be more than happy to support you. So, not only us, the six of us, but also all our colleagues of Everschets, of the International Tax Group. Thank you to the speakers, to Camille Montil and to Kelsey. And thanks, thanks a lot. And we will see you soon in another webinar. Thank you very much. Bye.