By Sonal Shah
09 Sep 2026
Last updated: 11.09.2026
The past few months have been a reminder of just how connected the world has become. People, wealth and information move across borders more freely than ever, while technology continues to transform how we live and work.
For internationally mobile individuals, families and businesses, this creates both opportunities and challenges. Questions around residence, wealth planning, succession and cross-border affairs are becoming increasingly complex and often require a truly international perspective.
In this edition, we explore some of the key developments shaping the international tax landscape, from global mobility and internationally competitive tax regimes to the growing exchange of information between tax authorities.
We hope you enjoy the read.
The ability to work from almost anywhere has changed the way international businesses operate. Employees are increasingly extending holidays to work remotely, dividing their time between countries or simply choosing to live somewhere different from where their employer is based. But while technology may have made borders less relevant to the working day, tax authorities have certainly not forgotten about them.
One of the recurring questions is whether an employee working from their home in another country could inadvertently create a taxable presence for their employer. Recent developments have provided greater clarity around when home-working arrangements may give rise to a permanent establishment, with factors such as the amount of time spent working overseas and whether there is a genuine commercial reason for the business to operate from that location becoming increasingly important.
But permanent establishment is only one part of the puzzle. Employers also need to consider payroll withholding, individual tax residence, social security and local employment obligations. What might start as a relatively innocent request to “work from abroad for a few weeks” can quickly become an international tax question.
The broader message is clear: “work from anywhere” may be a lifestyle choice, but businesses increasingly need a tax framework that can travel with their people.
For decades, international tax competition was largely about attracting companies. Lower Corporation Tax rates, investment incentives and favourable holding company regimes were all part of the race to attract international business. Increasingly, however, countries are competing for people too.
Entrepreneurs, investors and internationally mobile families have more freedom than ever to decide where they want to live, and governments have noticed. A growing number of jurisdictions offer regimes designed, in different ways, to attract wealthy individuals, entrepreneurs, pensioners or new residents. Tax policy is therefore being used not simply to raise revenue, but also to attract capital, investment, talent and spending.
But choosing where to live based on a headline tax rate can be dangerous. Income Tax is only one piece of the equation. Capital Gains Tax, inheritance and estate taxes, wealth taxes, exit taxes, social security and the treatment of trusts, companies and overseas assets can completely change the picture, and becoming resident somewhere new does not necessarily mean the previous country has stopped being interested in you.
For internationally mobile individuals, pre-departure planning can be just as important as pre-arrival planning. The most attractive regime on paper will not necessarily produce the best overall result for a particular individual or family.
Countries are no longer simply competing for businesses and investment, they are increasingly competing for the people behind them.
Modern wealth is rarely confined to one country. A family may hold investments through overseas structures, own businesses in multiple jurisdictions and have future generations living around the world. As wealth becomes increasingly international, tax planning has become less about geography and more about how assets are owned, transferred and preserved.
For business owners and investors, major events such as a sale, acquisition, family succession or corporate restructuring can create significant cross-border tax considerations. Decisions made years before a transaction often determine the eventual tax outcome, particularly where trusts, holding companies or international assets are involved.
Succession planning presents similar challenges. Different countries apply very different approaches to inheritance, estate and gift taxation, meaning a structure that works effectively in one jurisdiction may create unexpected exposure in another. Families with international connections increasingly need to consider not only who will inherit wealth, but where that wealth will sit and how it will pass between generations. Tax has become an increasingly important factor in shaping how wealth is structured, protected and transferred. As families, businesses and investments spread across borders, successful planning requires a joined-up view of transactions, ownership and long-term succession.
In an international world, the question is often not simply where wealth is created, but how it can be preserved for future generations.
International tax transparency is no longer a new concept. Over the past decade, initiatives such as the Common Reporting Standard, FATCA and wider information-exchange arrangements have fundamentally changed the ability of tax authorities to see beyond their own borders. Overseas financial accounts and investments which might once have attracted limited visibility are now routinely part of an international reporting environment.
What is changing now is the breadth and depth of that transparency.
The focus is moving beyond traditional financial accounts into areas such as crypto-assets, digital platforms and, increasingly, overseas property. At the same time, tax authorities are becoming better at connecting information received from different sources and comparing it with what taxpayers have actually reported.
The direction of travel is therefore not simply towards more information exchange, but towards a much more connected international tax picture. An individual may have a bank account in one country, a property in another, investments held through a third jurisdiction and tax residence somewhere else entirely, but those pieces of information are increasingly less likely to remain isolated from one another.
For internationally mobile individuals and families, consistency is becoming more important than ever. Where are you resident? Where are your assets held? Where is the income being reported? And, critically, would the information held by different tax authorities tell the same story?
Uruguay has established itself as an attractive jurisdiction for internationally focused businesses, supported by a stable legal system and a source-based tax framework. Under this approach, only income arising from activities, assets or rights located in Uruguay is generally subject to taxation.
Resolution 51/97 addresses a common cross-border scenario where commercial management and decision-making take place in Uruguay, while the goods or services involved remain entirely outside the country. Rather than treating the full profit as taxable, the regime deems only a small portion of the income to be Uruguayan-source.
The rules apply to international trading operations involving goods bought and sold abroad without entering Uruguay, as well as services provided and consumed entirely outside the country. The key requirement is that the activity is managed from Uruguay, while the underlying transactions take place overseas.
Under the regime, only 3% of the gross margin is treated as taxable income and subject to the standard 25% IRAE corporate tax rate, resulting in an effective corporate tax burden of approximately 0.75% of the gross margin. Including dividend withholding tax, the overall burden is typically around 0.96%.
Many investors compare Resolution 51/97 with Uruguay’s Free Trade Zone regime. While Free Trade Zones offer a full tax exemption, Resolution 51/97 can be attractive because it demonstrates that tax has been paid in Uruguay, which may be valuable where home-country tax authorities require evidence of effective taxation.
With its long-standing legal certainty, predictable tax treatment and straightforward administration, Resolution 51/97 continues to offer businesses a clear and practical framework for managing international trading activities from Uruguay.
For more information, please reach out to Vertex.
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