Territorial taxation · Edition 2026.09
Territorial tax countries: 17 jurisdictions, what happens to your LLC in each one, and the statute that says so.
Lists of "tax-free countries" mix territorial systems, remittance systems and countries with no income tax as if they were the same thing. They are not, and the difference decides whether your dividends are taxed. Here each jurisdiction carries its statute, its date and the four answers that matter to a founder with an LLC: active income earned abroad, foreign dividends, work done from the country, and the residence test.
Isaac Cubero · Checked on 14 September 2026
Before you read the table
A territorial system taxes only income produced inside the country. That applies to your LLC if the work is done elsewhere: in all 17 countries in the table, working from the territory turns the income into local income, even when the client and the payment are abroad. The second question is passive income: some territorial countries still tax the dividends and interest you receive from abroad. And two on the list are not territorial at all but remittance-based. If the concept is new, start with what territorial taxation is or with the tax systems of the world.
The table
17 jurisdictions, sorted by name.
Find your country or filter by scope and region. Open each row for the four answers, the note, the source and, where it exists, the link to the calculator that shows what an LLC would pay from there.
| Country | System | Scope | Foreign dividends | Residence |
|---|---|---|---|---|
BoliviaLatin AmericaBolivia: territorial system. Not taxed if the service is performed outside Bolivia. Not taxed: the RC-IVA reaches only Bolivian-source income (Law 843, arts. 20-21 and 42). Checked on 14 September 2026.
| Territorial | Strict | Not taxed: the RC-IVA reaches only Bolivian-source income (Law 843, arts. 20-21 and 42). | The law taxes by source, not by residence: there is no day threshold that widens the base. |
Costa RicaLatin AmericaCosta Rica: territorial system. Not taxed if the service is performed outside Costa Rica. Not taxed for individuals. Law 10,381 (2023) taxes foreign passive income only for entities in multinational groups without substance. Checked on 14 September 2026.
| Territorial | Strict | Not taxed for individuals. Law 10,381 (2023) taxes foreign passive income only for entities in multinational groups without substance. | More than 183 days in the tax year. |
Dominican RepublicLatin AmericaDominican Republic: territorial system. Not taxed if the service is performed outside the Dominican Republic. Taxed: residents pay on foreign income 'from investments and financial gains' (art. 269), from the third year of residence (art. 271), with a credit for tax paid abroad (art. 316). Checked on 14 September 2026.
| Territorial | With exceptions | Taxed: residents pay on foreign income 'from investments and financial gains' (art. 269), from the third year of residence (art. 271), with a credit for tax paid abroad (art. 316). | More than 182 days in the year (Tax Code, art. 12). |
El SalvadorLatin AmericaEl Salvador: territorial system. Not taxed if the service is performed outside El Salvador. Not taxed since Decree 969 (12 March 2024): art. 3.4 of the income tax law excludes all foreign-source values from the concept of income, securities and deposits included. Checked on 14 September 2026.
| Territorial | Strict | Not taxed since Decree 969 (12 March 2024): art. 3.4 of the income tax law excludes all foreign-source values from the concept of income, securities and deposits included. | Tax domicile: more than 200 days in the calendar year (Tax Code, art. 53). |
GeorgiaEuropeGeorgia: territorial system. Not taxed if the service is performed outside Georgia. Not taxed: foreign-source income of resident individuals is exempt (Tax Code, art. 82). Checked on 14 September 2026.
| Territorial | Strict | Not taxed: foreign-source income of resident individuals is exempt (Tax Code, art. 82). | 183 days in any 12-month period, or the high-net-worth programme. |
GuatemalaLatin AmericaGuatemala: territorial system. Not taxed if the service is performed outside Guatemala. Not taxed: Guatemalan-source capital income is that from assets in Guatemala or paid by residents (art. 4.3). Checked on 14 September 2026.
| Territorial | Strict | Not taxed: Guatemalan-source capital income is that from assets in Guatemala or paid by residents (art. 4.3). | More than 183 days in the calendar year or centre of economic interests (art. 6). |
HondurasLatin AmericaHonduras: territorial system. Not taxed if the service is performed outside Honduras. Not taxed: 'Honduras follows the territorial income principle' (Decree 170-2016, art. 1.2). Checked on 14 September 2026.
| Territorial | Strict | Not taxed: 'Honduras follows the territorial income principle' (Decree 170-2016, art. 1.2). | Domicile or residence under the Tax Code (Decree 170-2016). |
Hong KongAsiaHong Kong: territorial system. Not taxed: Profits Tax is charged only on profits 'arising in or derived from Hong Kong' (IRO, s. 14). Not taxed: Hong Kong does not tax foreign-source dividends or interest of individuals. Checked on 14 September 2026.
| Territorial | Strict | Not taxed: Hong Kong does not tax foreign-source dividends or interest of individuals. | Tax is by source, not by residence. The residence certificate requires 180 days in the year or 300 over two years. |
MalaysiaAsiaMalaysia: territorial system. Foreign-source income received in Malaysia by resident individuals is exempt from 1 Jan 2022 to 31 Dec 2036, subject to conditions. Exempt under the same condition: the income must have been subject to tax 'of a similar character' in the country of origin. A transparent LLC with no US tax may fail it. Checked on 14 September 2026.
| Territorial | With exceptions | Exempt under the same condition: the income must have been subject to tax 'of a similar character' in the country of origin. A transparent LLC with no US tax may fail it. | 182 days in the basis year (ITA 1967, s. 7). |
MaltaEuropeMalta: remittance basis system. Resident non-domiciled: foreign income is taxed only if remitted to Malta (0-35%). Taxed only if remitted to Malta; foreign capital gains are not taxed even if remitted. Checked on 14 September 2026.
| Remittance basis | Remitted only | Taxed only if remitted to Malta; foreign capital gains are not taxed even if remitted. | 183 days or ordinary residence. Minimum tax of EUR 5,000 a year if unremitted foreign income reaches EUR 35,000 (ITA, art. 56(27)). |
NicaraguaLatin AmericaNicaragua: territorial system. Not taxed if the service is performed outside Nicaragua. Not taxed: Nicaraguan-source capital income is that paid by residents or from assets in Nicaragua (art. 16); dividends from a foreign company are not. Checked on 14 September 2026.
| Territorial | Strict | Not taxed: Nicaraguan-source capital income is that paid by residents or from assets in Nicaragua (art. 16); dividends from a foreign company are not. | More than 180 days in the year (Law 822, art. 7). |
PanamaLatin AmericaPanama: territorial system. Not taxed if the service is performed outside Panama. Not taxed: foreign-source dividends and interest are outside the tax. Checked on 14 September 2026.
| Territorial | Strict | Not taxed: foreign-source dividends and interest are outside the tax. | More than 183 days in the tax year or centre of vital interests; immigration residency alone is not enough. |
ParaguayLatin AmericaParaguay: territorial system. Not taxed if the work is performed outside Paraguay. Dividends from foreign companies are outside the scope of personal income tax (art. 57 Law 6380). Checked on 14 September 2026.
| Territorial | Strict | Dividends from foreign companies are outside the scope of personal income tax (art. 57 Law 6380). | Effective residence with a valid cédula and the DNIT certificate (GR 65/2020); no legal minimum day count. |
SingaporeAsiaSingapore: territorial system. Not taxed: overseas income received in Singapore by individuals is not taxable, except through a Singapore partnership. Not taxed: foreign dividends and interest received by individuals are exempt (ITA, s. 13(7A)). Checked on 14 September 2026.
| Territorial | Strict | Not taxed: foreign dividends and interest received by individuals are exempt (ITA, s. 13(7A)). | 183 days in the calendar year. |
ThailandAsiaThailand: remittance basis system. Since 1 Jan 2024 a resident's foreign income is taxed when brought into Thailand, whatever the year it was earned (Por. 161/2566). Taxed on remittance, in brackets 0-35%. Income earned before 1 Jan 2024 stays out (Por. 162/2566). Checked on 14 September 2026.
| Remittance basis | Remitted only | Taxed on remittance, in brackets 0-35%. Income earned before 1 Jan 2024 stays out (Por. 162/2566). | 180 days or more in the calendar year (Revenue Code, s. 41). |
United Arab EmiratesMiddle EastUnited Arab Emirates: no income tax system. There is no personal income tax. There is no personal income tax. Checked on 14 September 2026.
| No income tax | No tax | There is no personal income tax. | 183 days; or 90 days with a visa, home or employment; or centre of interests (Cabinet Decision 85/2022). |
UruguayLatin AmericaUruguay: territorial system. Not taxed if the service is performed outside Uruguay. Taxed: foreign dividends and interest pay 12% personal income tax, unless the new-resident tax holiday applies (up to 11 years at 0%) or the permanent 7% option. Checked on 14 September 2026.
| Territorial | With exceptions | Taxed: foreign dividends and interest pay 12% personal income tax, unless the new-resident tax holiday applies (up to 11 years at 0%) or the permanent 7% option. | 183 days, base of activities or centre of interests; from 2026 the tax holiday without 183 days requires an investment (Law 20,446). |
Strict: neither active nor passive foreign income is taxed. With exceptions: active income stays out, passive income (dividends, interest) comes in with conditions. Remittance basis: foreign income is taxed when it enters the country. No tax: no personal income tax at all.
What the table says
Six readings you can quote as they are.
Only 11 of the 17 are strictly territorial
Panama, Paraguay, Costa Rica, Guatemala, El Salvador, Honduras, Nicaragua, Bolivia, Georgia, Hong Kong, Singapore. In these, neither the LLC profit earned abroad nor its dividends are taxed if you genuinely live there.
3 tax foreign passive income despite being territorial
Uruguay, Dominican Republic, Malaysia. Active profit stays out, but foreign dividends and interest come in, with nuances: the tax holiday in Uruguay, the third year in the Dominican Republic, the 'subject to tax' condition in Malaysia.
2 are not territorial: they are remittance-based
Malta, Thailand. Foreign income is taxed when you bring it into the country. They get mistaken for territorial systems and they are not: 0% requires not remitting.
1 has no income tax at all
United Arab Emirates. Not territorial: there is no personal tax to territorialise. The cost sits in the visa, the substance and the 9% corporate tax if you manage the LLC from there.
All of them tax work done from the territory
All 17 treat a service performed from the country as local income, even when the client and the payment are abroad. Guatemala writes it into the law ("export of services from Guatemala"). The LLC's 0% does not come from the system: it comes from where the work is done.
Residence is proven by facts, not paperwork
Each country has its threshold (120 days in Paraguay, 180 in Nicaragua and Thailand, 182 in Malaysia and the Dominican Republic, 183 elsewhere, 200 in El Salvador). And none of them erases residence in your previous country if you keep a home, family or business there.
Criteria and sources
Four questions per country, one statute per answer.
The four questions: what happens to the active income the LLC earns from work done outside the country; what happens to the dividends and interest you receive from abroad; what happens if the work is done from the country; and what proves tax residence. All four are answered from the statute cited in the row, not from what a residency provider says.
Classification: "Strict" when neither active nor passive foreign income is taxed. "With exceptions" when active income stays out but passive income comes in (with or without conditions). "Remittance basis" when foreign income is taxed on entering the country. "No tax" when there is no personal income tax at all.
What was done: each jurisdiction's statute (act, code or administrative instruction) was read on 14 September 2026 and each answer was written with the article in front. Eleven were checked that day against the legal text; the remaining six inherit the tax calculator's verification, done the same week against official sources.
What it is not: it is not advice and not a list of recommended destinations. It does not include the cost of obtaining residency, special regimes for new residents, or banking. Nor is it a world list: these are the jurisdictions the founders we work with ask about.
Maintenance: statutes change, sometimes abruptly (El Salvador and Thailand in 2024). Each edition carries its date and changes are logged below. If you spot a difference with the source, write to us and it gets fixed in the next edition.
Frequently asked questions
What people ask after finding their row.
What is territorial taxation?
A system where the country taxes only income produced inside its territory. Its residents' foreign-source income is not taxed. The opposite is the worldwide system (Spain, Mexico, Argentina, most countries), where a resident is taxed on all income wherever it is earned.
If I live in a territorial country, does my LLC pay 0%?
Only if the work that produces the profit is performed outside that country and the country does not tax foreign passive income. If you work from there, the income is local-source in all 17 countries in the table. And in Uruguay, the Dominican Republic or Malaysia foreign dividends can be taxed even when the active profit is not.
What is the difference between territorial and remittance basis?
Under a territorial system foreign income is never taxed, whether you bring it in or not. Under a remittance system (Malta, Thailand since 2024) foreign income is taxed the moment it enters the country. The second is often sold as territorial and it is not.
Why is the UAE on the list if it is not territorial?
Because it is the destination people compare against most, and it is worth saying it is not the same thing: the UAE has no personal income tax, so there is nothing to territorialise. What it does have is a 9% corporate tax, which reaches an LLC effectively managed from there.
Is immigration residency enough?
No. Tax residence is proven by presence (each country's day count) or by centre of interests, and your previous country can keep treating you as resident if you keep a home, family or business there. The new country's tax residence certificate is the proof the old one demands.
How often is this table updated?
Laws change, sometimes without notice, as El Salvador and Thailand did in 2024. This edition (2026.09) was checked against the cited statutes on 14 September 2026. Every change is logged in the edition history and the CSV carries the date on every row.
Cite and reuse
The data, with its date and source, as CSV and JSON.
No sign-up. Cite the edition and the check date; every CSV row carries it.
- CSV · Español17 jurisdictions, system, scope, the four answers, note, source and date.
- CSV · EnglishThe same edition in English.
- JSON · Bilingual data, sources and changelogIncludes the URL of every statute cited.
Data licensed under CC BY 4.0.
Suggested citation
Cubero, Isaac. Territorial tax countries. Cheq Capital. Edition 2026.09, checked 2026-09-14. https://cheqcapital.com/en/territorial-tax-countries/ CC BY 4.0.
Editions
What changed and which date you are citing.
- 2026-09-14
- Initial edition: 17 jurisdictions, each with an official source and date. Eleven checked today against the statute (Singapore, Hong Kong, Malaysia, Malta, Thailand, Dominican Republic, Guatemala, El Salvador, Honduras, Nicaragua, Bolivia); the rest inherit the simulator verification of 14 Sep.
Your country shows "strict". Now what?
The system opens the door. Residence and where you work walk through it.
What your LLC would pay from each residence, with figures, is in the LLC tax calculator. How residence is genuinely changed, and why your previous country may not let go, in tax residency for founders. The rest of international taxation, in order, in the hub.