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. Unlike the old remittance basis, they can bring that money into 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 comes at a price. Make a foreign income claim, a foreign gain claim, or an Overseas Workday Relief election for a tax year, and you forfeit the income tax personal allowance and the CGT annual exempt amount for that year. 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 disappear too. And you cannot claim foreign income or capital losses for that year.
• The Temporary Repatriation Facility, or TRF, is a three-year amnesty on the old stock of unremitted foreign income and gains. It does not touch 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. Compare that to the up to 45% that would otherwise apply on remittance. The funds do not need to 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 counts as a long-term UK resident, or LTR, and so falls within IHT on worldwide assets, if UK-resident for at least 10 of the previous 20 tax years. The tail after departure follows 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 gives 4, 15 gives 5, 16 gives 6, 17 gives 7, 18 gives 8, 19 gives 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. Decree-Law 113/2024 raised it to EUR 200,000 for those transferring residence after August 2024. The 2026 Budget Law (Legge 30 dicembre 2025, n. 199) raised it again, to EUR 300,000, 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 it still excludes foreign assets from Italian inheritance and gift tax.
• Cyprus survived its own 2026 overhaul, and came out better for it. The reform passed on 22 December 2025, was gazetted 31 December 2025, and took effect 1 January 2026. It 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. That is a maximum of 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 charges a EUR 100,000 annual flat tax on all foreign-source income, for up to 15 years. To qualify, the applicant must not have been Greek tax resident for 7 of the 8 years before transfer, and must invest at least EUR 500,000 in Greek real estate, businesses or securities within three years. Family members cost EUR 20,000 each per year. One trap worth knowing: foreign tax paid on income inside the regime is not creditable in Greece. That matters a great deal for anyone with foreign income that is withheld at source.
• Ireland and Malta are the quiet survivors. Ireland offers resident non-domiciled individuals the remittance basis, and there is no statutory time limit on how long they can use it. Foreign income and gains stay outside the Irish tax net as long as they stay outside Ireland. Irish-source income is fully taxable. Malta's remittance basis goes further. Foreign capital gains are exempt entirely, even if brought into the country, and foreign income is taxed only when it is remitted. There is a catch. Ordinarily-resident non-domiciled individuals with foreign income of at least EUR 35,000 owe a minimum annual tax of EUR 5,000, a rule introduced by Act VII of 2018 and in force from year of assessment 2019. The exception is anyone holding special tax status under a programme such as the Global Residence Programme, which charges 15% on remitted foreign income instead, with a EUR 15,000 minimum.

Jurisdiction by jurisdiction

United Kingdom high

The non-dom regime was abolished on 6 April 2025. It has been replaced by the 4-year FIG regime, which requires 10 prior consecutive non-resident years and costs the personal allowance and the CGT annual exempt amount in any year it is claimed. The TRF rate is 12% for 2025/26 and 2026/27, rising to 15% for 2027/28, before closing on 5 April 2028. Inheritance tax is now residence-based, with long-term residence status triggered at 10 of 20 years, and a 3-to-10-year tail on departure that scales with how long someone lived in the UK.

Italy medium

Under Art. 24-bis TUIR, anyone transferring residence from 1 January 2026 pays an annual substitute tax of EUR 300,000 on foreign income, up from EUR 200,000 and originally EUR 100,000, under Legge 199/2025. Family members pay EUR 50,000 each, up from EUR 25,000. The regime runs for 15 years at most, and foreign assets stay outside Italian inheritance and gift tax. Anyone who entered before 2026 is grandfathered in at their original entry rate.

Cyprus low

Non-dom status brings an exemption from SDC on dividends and interest for 17 of the last 20 years of residence. From 1 January 2026, that exemption can be extended for up to two further 5-year periods at EUR 250,000 per period, for a maximum of 27 years. Rental income falls outside SDC from 2026, and SDC on dividends for domiciled residents drops from 17% to 5%. There is also a 60-day residency route. To use it, you need to keep a home, hold a Cypriot office, employment or business, and spend under 183 days in any other single country.

Greece medium

Under Art. 5A, foreign income is taxed at a flat EUR 100,000 for up to 15 years. To qualify, you must have been non-resident for 7 of the prior 8 years and invest EUR 500,000 in Greece within 3 years. Each additional family member adds EUR 20,000. One point matters more than most: foreign tax already paid on income inside the regime cannot be credited against the flat charge.

Malta low

Resident non-doms are taxed on the remittance basis. Foreign income is taxed only if it is remitted, and foreign capital gains are exempt even if remitted. There is a EUR 5,000 minimum annual tax where foreign income is at least EUR 35,000 (Act VII of 2018, from YA 2019), unless you are under a special programme. There is also a Global Residence Programme alternative. It taxes remitted foreign income at 15%, with a EUR 15,000 minimum tax.

Ireland low

Resident non-domiciled individuals get the remittance basis with no time limit. It is the most durable non-dom regime in the EU by duration. Irish-source income is fully taxable, while foreign income and gains are taxed only when remitted. Because Ireland's headline rates run high, the discipline of managing what you remit matters more here than almost anywhere else.