Non-dom regimes after the UK: where the concept still lives

What is actually true

• The UK abolished the remittance basis and removed domicile from the tax code with effect from 6 April 2025. The replacement is the 4-year Foreign Income and Gains (FIG) regime: a qualifying new arrival pays no UK tax on foreign income and gains arising in their first four years of UK residence, and — unlike the old remittance basis — can bring the money to the UK freely. Eligibility requires 10 consecutive tax years of non-UK residence immediately before arrival. The four years run from the start of UK residence and cannot be extended or paused.
• The FIG regime's price is the loss of allowances. Making a foreign income claim, a foreign gain claim, or an Overseas Workday Relief election for a tax year forfeits the income tax personal allowance and the CGT annual exempt amount for that year — and the forfeiture is total even if you claim for only one of the three. Married Couple's Allowance, Marriage Allowance and Blind Person's Allowance go too, and foreign income and capital losses cannot be claimed for that year.
• The Temporary Repatriation Facility (TRF) is a three-year amnesty on the old stock of unremitted foreign income and gains, not the new flow. Former remittance-basis users designate pre-6 April 2025 FIG on their return and pay 12% for 2025/26 and 2026/27, rising to 15% for 2027/28, against the up to 45% that would otherwise apply on remittance. The funds need not physically move during the window. The facility closes permanently on 5 April 2028 — as at July 2026, roughly twenty months of the 12% rate remain.
• UK inheritance tax became residence-based on 6 April 2025. An individual is a long-term UK resident (LTR) — and therefore within IHT on worldwide assets — if UK-resident for at least 10 of the previous 20 tax years. The tail after departure is a sliding scale set out in HMRC's IHT manual: 13 years or fewer of prior residence gives a 3-year tail; then 14 years → 4, 15 → 5, 16 → 6, 17 → 7, 18 → 8, 19 → 9, and 20 years of residence gives the full 10-year tail. Status resets after 10 consecutive years of non-residence.
• Italy has repriced twice. The art. 24-bis TUIR neo-residenti substitute tax on foreign income was EUR 100,000 from 2017, raised to EUR 200,000 by Decree-Law 113/2024 for those transferring residence after August 2024, and raised again to EUR 300,000 by the 2026 Budget Law (Legge 30 dicembre 2025, n. 199) for those transferring residence from 1 January 2026. The family-member add-on went from EUR 25,000 to EUR 50,000. Earlier entrants are grandfathered at the rate in force when they entered. The regime still runs a maximum of 15 years and still excludes foreign assets from Italian inheritance and gift tax.
• Cyprus survived its own 2026 overhaul and improved. The reform passed on 22 December 2025, gazetted 31 December 2025, in force 1 January 2026, left the non-dom regime intact: a resident who is not domiciled in Cyprus is exempt from Special Defence Contribution on dividends and interest until they have been Cyprus-resident for 17 of the last 20 years. New from 2026: a deemed-domiciled individual whose domicile of origin is outside Cyprus can extend the SDC exemption for up to two further 5-year periods by paying EUR 250,000 upfront per period — a maximum 27 years. Also from 1 January 2026, rental income is out of SDC, and the SDC rate on dividends for domiciled residents fell from 17% to 5%.
• Greece's art. 5A regime is a EUR 100,000 annual flat tax on all foreign-source income, for up to 15 years, requiring that the applicant was not Greek tax resident for 7 of the 8 years before transfer and invests at least EUR 500,000 in Greek real estate, businesses or securities within three years. Family members are EUR 20,000 each per year. Foreign tax paid on income inside the regime is not creditable in Greece — a material trap for anyone with withheld-at-source foreign income.
• Ireland and Malta are the quiet survivors. Ireland applies the remittance basis to resident non-domiciled individuals with no statutory time limit — foreign income and gains left outside Ireland are outside the Irish charge, Irish-source income is fully taxable. Malta's remittance basis exempts foreign capital gains entirely even if remitted, and taxes foreign income only on remittance; but a minimum annual tax of EUR 5,000 applies to ordinarily-resident non-domiciled individuals with foreign income of at least EUR 35,000 (introduced by Act VII of 2018, from year of assessment 2019), unless they hold special tax status under a programme such as the Global Residence Programme, which instead charges 15% on remitted foreign income with a EUR 15,000 minimum.

Jurisdiction by jurisdiction

United Kingdom high

Non-dom abolished 6 April 2025. Replaced by the 4-year FIG regime (requires 10 prior consecutive non-resident years; costs the personal allowance and CGT annual exempt amount in any year claimed). TRF at 12% for 2025/26 and 2026/27, 15% for 2027/28, closing 5 April 2028. IHT now residence-based: LTR at 10 of 20 years, with a 3-to-10-year tail on departure scaled by prior residence.

Italy medium

Art. 24-bis TUIR: EUR 300,000 annual substitute tax on foreign income for those transferring residence from 1 January 2026 (up from EUR 200,000; originally EUR 100,000), per Legge 199/2025. Family members EUR 50,000 each (up from EUR 25,000). 15 years maximum; foreign assets outside Italian inheritance and gift tax. Pre-2026 entrants grandfathered at their entry rate.

Cyprus low

Non-dom SDC exemption on dividends and interest for 17 of the last 20 years of residence. From 1 January 2026 the exemption can be extended for up to two further 5-year periods at EUR 250,000 per period (maximum 27 years). Rental income out of SDC from 2026; SDC on dividends for domiciled residents cut from 17% to 5%. 60-day residency route available if you keep a home, hold a Cypriot office/employment/business and spend under 183 days in any other single country.

Greece medium

Art. 5A: EUR 100,000 flat on all foreign income, up to 15 years; requires non-residence for 7 of the prior 8 years and EUR 500,000 invested in Greece within 3 years. EUR 20,000 per family member. Critically, foreign tax on income within the regime is NOT creditable against the flat charge.

Malta low

Remittance basis for resident non-doms: foreign income taxed only if remitted, foreign capital gains exempt even if remitted. EUR 5,000 minimum annual tax where foreign income is at least EUR 35,000 (Act VII of 2018, from YA 2019), unless under a special programme. Global Residence Programme alternative: 15% on remitted foreign income, EUR 15,000 minimum tax.

Ireland low

Remittance basis for resident non-domiciled individuals with no time limit — the most durable non-dom regime in the EU by duration. Irish-source income fully taxable; foreign income and gains taxed only when remitted. Ireland's high headline rates make the remittance discipline unusually consequential.