What "Non-Dom" Actually Means
In tax law, domicile and residence are different concepts. Residence is where you live. Domicile is where you consider your permanent home — typically the country your father was domiciled in at your birth, or the country you have adopted as your permanent home with the intention of remaining indefinitely.
A non-dom regime applies to people who are resident in a country but not domiciled there. Under these regimes, you are taxed on local-source income plus any foreign income you bring into ("remit to") the country. Foreign income that stays outside the country is not taxed. This is called remittance-basis taxation, and for individuals with significant foreign income, it can represent substantial tax savings compared to worldwide taxation.
Key Non-Dom Regimes
United Kingdom — Abolished April 2025
The UK non-dom regime was the most well-known globally, used by an estimated 68,000 individuals. It was abolished in April 2025 and replaced with a new system.
What replaced it — the 4-Year FIG Regime:
- New arrivals who have not been UK tax resident in the previous 10 years can claim the Foreign Income and Gains (FIG) regime
- Under FIG, qualifying foreign income and gains are exempt from UK tax for 4 years — regardless of whether the funds are remitted to the UK
- After 4 years, all income becomes subject to standard UK taxation
- This is more generous than the old non-dom regime for the first 4 years (no remittance restriction) but far less generous long-term (the old regime could last 15+ years)
- Existing non-doms who were using the remittance basis lost that benefit and transitioned to the standard tax regime, subject to transitional provisions
The UK FIG regime is useful for executives on short-term UK assignments or entrepreneurs establishing a UK presence before moving on. It is not a long-term tax planning tool.
Ireland — Still Available
Ireland continues to offer a remittance-basis regime for individuals who are Irish tax resident but not Irish domiciled:
- Foreign income and gains are taxed only if remitted to Ireland
- No time limit — the regime continues as long as you remain non-domiciled
- No annual charge (unlike the old UK regime, which charged GBP 30,000-60,000 per year after extended use)
- Irish-source income is taxed normally
- Employment income for duties performed in Ireland is taxed even if paid abroad
Ireland is one of the last common-law jurisdictions to maintain a full remittance-basis regime without a time limit. It is particularly relevant for individuals with significant foreign passive income (dividends, capital gains, rental income) who want to live in an English-speaking EU country.
Malta — EUR 15,000 Flat Rate
Malta offers a non-dom regime where resident non-domiciled individuals are taxed on:
- Maltese-source income: at standard rates (up to 35%)
- Foreign income remitted to Malta: at standard rates
- Foreign income not remitted: not taxed
- Foreign capital gains: not taxed, even if remitted
A minimum annual tax of EUR 15,000 applies if the non-dom individual claims the remittance basis. This is a flat floor — not a rate. For individuals with substantial foreign income that they keep outside Malta, the effective tax burden can be minimal. Malta also has no inheritance tax, no wealth tax, and no property tax (only stamp duty on purchase).
Cyprus — 17-Year Exemption
Cyprus non-dom status is granted to individuals who become Cyprus tax resident but were not born in Cyprus or were not previously Cyprus tax resident for at least 17 of the 20 years before establishing residency. The benefits:
- Dividends: Exempt from Special Defence Contribution (SDC) tax for 17 years
- Interest income: Exempt from SDC for 17 years
- Rental income from foreign properties: Exempt from SDC for 17 years
- No worldwide capital gains tax (Cyprus only taxes gains on Cyprus real estate)
The 17-year window makes Cyprus attractive for individuals planning a long-term relocation. Combined with the 12.5% corporate tax rate and extensive double-tax treaty network, it has become a serious alternative to the UK for holding company and IP structures.
Italy — EUR 200,000 Flat Tax
Italy's regime impatriati for new residents offers a flat annual tax of EUR 200,000 on all worldwide income (except Italian-source income, which is taxed normally). Key details:
- Available to individuals who have not been Italian tax resident in 9 of the previous 10 years
- Duration: 15 years
- Additional EUR 25,000 per qualifying family member
- No requirement to declare or detail foreign income — simply pay the flat amount
- Italian-source income (employment, Italian real estate, Italian business) taxed at normal progressive rates
At EUR 200,000 per year, this regime only makes economic sense for individuals with worldwide income exceeding approximately EUR 500,000-600,000. Below that threshold, standard Italian tax rates may actually be lower.
Greece — EUR 100,000 Flat Tax
Greece introduced a similar regime offering a flat EUR 100,000 annual tax on foreign-source income for new tax residents:
- Available to individuals who have not been Greek tax resident in 7 of the previous 8 years
- Duration: 15 years
- Must transfer at least EUR 500,000 to Greece within 3 years (financial assets or real estate)
- Greek-source income taxed normally
- No additional obligations to declare foreign income details
At half the cost of Italy's regime, Greece is the more accessible option. It pairs well with the Golden Visa program — an individual can hold Greek residency through a EUR 250,000 property purchase and separately opt into the flat tax regime upon becoming a tax resident.
Portugal — IFICI / NHR 2.0
Portugal's original Non-Habitual Resident (NHR) regime was one of the most popular non-dom alternatives in Europe. It was replaced in 2024 by the IFICI regime (Incentive for Scientific Research and Innovation), sometimes called NHR 2.0:
- 20% flat tax on qualifying Portuguese-source employment and self-employment income
- Available to individuals who qualify under specific professional categories (scientific research, highly qualified activities, startups, and certain eligible professions)
- Duration: 10 years
- Foreign-source income treatment depends on applicable double-tax treaties and the type of income
- More restrictive than the original NHR — not available to retirees or passive income recipients
The original NHR was a broad-based regime that attracted retirees with tax-free foreign pension income. IFICI is narrower — it targets working professionals and entrepreneurs. Retirees who already hold NHR status retain their benefits until expiry, but new retiree applicants cannot access the regime.
Comparison Table
| Country | Regime Type | Annual Cost / Rate | Duration | Key Benefit |
|---|---|---|---|---|
| UK (post-2025) | FIG exemption | Standard rates after 4 years | 4 years | Full foreign income exemption (4 yrs) |
| Ireland | Remittance basis | No annual charge | Unlimited | Ongoing remittance basis, no time limit |
| Malta | Remittance basis + minimum | EUR 15,000/year minimum | Unlimited | Low floor, no capital gains on foreign assets |
| Cyprus | SDC exemption | No additional charge | 17 years | Dividend and interest exemption |
| Italy | Flat tax on foreign income | EUR 200,000/year | 15 years | No disclosure of foreign income |
| Greece | Flat tax on foreign income | EUR 100,000/year | 15 years | Half the cost of Italy |
| Portugal (IFICI) | Flat rate on qualifying income | 20% on qualifying income | 10 years | Reduced rate for qualified professionals |
Planning Considerations
CFC Rules
If you control a company in a low-tax jurisdiction, your new country of residence may attribute that company's profits to you under Controlled Foreign Corporation (CFC) rules. Italy, the UK, and France have aggressive CFC regimes. Malta and Cyprus have narrower CFC provisions. Non-dom status does not override CFC rules in most cases — you need specific structuring advice.
Substance Requirements
Post-BEPS (Base Erosion and Profit Shifting reforms), tax authorities worldwide require that entities have genuine substance — employees, offices, decision-making — in the jurisdictions where they claim to be based. Setting up a company in Malta but running it from London will not survive scrutiny. Your corporate structure must have real operational substance wherever it is domiciled.
Exit Planning
Non-dom regimes have expiry dates (except Ireland and Malta). Before the regime expires, you need a plan: do you stay and pay full local taxes? Move to another favorable jurisdiction? Return to your home country? This decision should be planned years in advance, not reacted to when the regime ends.
Why Non-Dom Regimes Are Disappearing
The trend is clear. The UK abolished its regime in 2025. Portugal narrowed NHR significantly. Greece and Italy may face EU pressure to limit their flat-tax offerings. The OECD's Global Minimum Tax framework (Pillar Two) adds further pressure on preferential tax regimes. Individuals relying on non-dom status should plan for a world where these regimes become scarcer — either by building permanent structures in jurisdictions with inherently favorable systems (territorial tax countries, zero-tax countries) or by accelerating timelines while current regimes remain available.
Next Steps
Non-dom planning requires coordination between your current country's exit provisions, the target country's regime rules, and your business and asset structure. Start a free assessment on TOTOZ.io to get personalized guidance on which regime fits your income profile and long-term plans.