The Filing Position

Most of the Americas publishes the same number. Spend 183 days in the country and the tax authority can call you a resident. Panama uses it. Uruguay uses it. Costa Rica uses it, and so do Guatemala, Honduras, Nicaragua and the Dominican Republic. El Salvador does not. Its published test is 200 consecutive days, or the country being the main source of your income. Bolivia asks for 90 days inside a 12-month window. Paraguay removes the day count entirely. Residency there is a status, granted through the immigration process, a cedula and a tax number, and it has nothing to do with a calendar. Then the detail that decides more than the number. Costa Rica's 183 days is rebuttable. A day count is a fact. Rebuttable is a position. That is the whole business. A residency claim is a filing position taken against a published threshold, and every threshold in this piece was written down before anyone arrived to argue about it.

Panama runs pure territorial taxation. 0 per cent on foreign income, 0 to 25 per cent on Panama-source income. Paraguay taxes local income at 8, 9 or 10 per cent and capital at 8 per cent. Costa Rica's territorial rule carries an explicit statutory exemption for its digital-nomad and rentista categories. Uruguay reaches 0 per cent on foreign income through the impatriados regime, an 11-year window with an IRNR option running from 2026. When that window closes, Uruguay offers a 12 per cent flat rate, a five-year phase at 50 per cent of the standard rate, or a fixed fee. The boundary is local-source work. Uruguay taxes it at 10 to 36 per cent, and capital at 12 per cent. Costa Rica runs 0 to 25 per cent. El Salvador reaches 30 per cent. Bolivia applies a flat 13 per cent under RC-IVA. And the Dominican Republic publishes the expiry in the statute. Three years at 0 per cent. Then foreign passive income is taxed like anything else. A rate without the calendar attached to it is marketing.

Every jurisdiction in this comparison is selling something. The price list is public. Panama: USD 200,000 in real estate or a time deposit under the Friendly Nations route, or USD 1,000 a month of pension income under Pensionado. Uruguay: 183 days costs nothing, and the investment route is USD 2.1 million in real estate or USD 100,000 a year into a fund. Its own internal triggers are narrower. USD 560,000 of real estate held for 60 days, or a USD 2.4 million company carrying 15 jobs. Costa Rica: USD 2,500 a month of proven income as a rentista, or a USD 60,000 deposit, or USD 3,000 a month under the digital-nomad visa. Paraguay is the cheapest of the clean list. Minimal requirements, with one advisory source putting the fast-track permanent route from about USD 70,000. At the top of the market the ticket is seven figures. The Bahamas accelerates permanent residency from USD 1 million of real estate. Cayman sits between USD 1 and 2.4 million. Anguilla's high-value route runs at roughly USD 75,000 a year plus property. The question is not which country is fairest. It is which price you can pay, and when.

Money is the entry fee. The list is the filter. Panama has sat in Annex I of the EU's non-cooperative jurisdictions list since 2020, with an announced exit target of October 2026. Anguilla is in Annex I. Turks & Caicos was added on 17 February 2026. The British Virgin Islands sits in Annex II, the grey list. Uruguay, Paraguay, Costa Rica, the Bahamas, Cayman, St Kitts & Nevis, Grenada, Dominica and St Lucia are clean. Antigua & Barbuda came off the grey list in February 2026. That status is not a tax rate. It is a banking variable and a reputational one, and it changes without asking you. A structure built on a listed jurisdiction carries a cost that never appears in the comparison table. It shows up later, at a bank, in a compliance queue, after the money has already moved.

A day count is a fact. Rebuttable is a position.

None of it works if the country you are leaving still has a claim on you. Germany taxes its residents on worldwide income and applies an exit tax under section 6 AStG to shareholdings of 1 per cent or more. Spain's departure provision, Art. 95 bis LIRPF, begins at unrealised gains above EUR 4 million. Both run controlled-foreign-company rules that reach into structures built somewhere else. The published sequence is the same everywhere. End the old residency first, then establish the new one. Done in the other order, the second country hands you a 0 per cent rate on income the first country still taxes. You have bought paperwork rather than a position. Exits are dated events. Treat them that way.

Residency and citizenship are separate products with separate clocks. Permanent residency in Paraguay typically leads to citizenship in about three years on advisory timelines. Panama's path is five years after permanent residency. Uruguay's is three years if you are married to a Uruguayan, and five if you are not. The Caribbean sells the second product directly, from roughly USD 200,000. St Kitts & Nevis and Antigua & Barbuda levy no personal income tax at all. Antigua withholds about 12.5 per cent on local-source passive payments to non-residents. Grenada carries access to the US E-2 treaty. Dominica is the lowest cost of the five. St Lucia structures the investment as refundable. Five programmes, five prices, and one published offer document each.

Every variable in this piece is countable. Days in the country. Local-source income. Real estate held 60 days. A company with 15 jobs. A pension of USD 1,000 a month. A fund contribution of USD 100,000 a year. A gain of EUR 4 million. A shareholding of 1 per cent. The probability that a structure survives on intent rather than on documents is not high. I lost savings in the 2013 Cyprus bail-in, when a deposit guarantee described as absolute was rewritten over a weekend. The lesson was not about Cyprus. It was that the rule you are standing on is a written rule, and written rules carry version numbers. I have restructured a EUR 75 million industrial group and built companies across twelve countries. The residency question is rarely settled by preference. It is settled by a calendar, a bank statement and a filing deadline, in that order. This piece describes published residency and tax thresholds in the Americas, taken from a comparison matrix dated 2026-08-10. It is not advice, and it is not a filing position.