Non-Dom Tax Regimes Worldwide: Where Foreign Income Stays Untaxed

Non-domiciled tax regimes allow individuals who are tax resident in a country but not domiciled there to receive favourable treatment on their foreign-source income and gains. Historically, the UK's remittance basis was the gold standard. Following its abolition in April 2025, the landscape has shifted, but several jurisdictions continue to offer powerful alternatives.

What Does Non-Domicile Status Mean?

Domicile is a legal concept distinct from residency. While residency is determined by physical presence and factual connections, domicile refers to the jurisdiction an individual considers their permanent home -- typically acquired at birth (domicile of origin) from the father and changed only by positive intention and action (domicile of choice).

Non-dom regimes exploit this distinction: you can be tax resident in a country (because you live there) while being domiciled elsewhere (because your permanent home is in another jurisdiction). The regime then offers favourable tax treatment to non-domiciled residents, typically by exempting foreign-source income that is not brought into the country.

Country-by-Country Comparison

United Kingdom: FIG Regime (Post-April 2025)

The UK abolished the remittance basis in April 2025 and replaced it with the Foreign Income and Gains (FIG) regime.

Key features:

• New arrivals to the UK who have not been UK tax resident in the previous 10 years qualify
• 100% exemption on foreign income and gains for the first 4 years of UK residence
• No requirement to keep income offshore -- the exemption applies regardless of remittance
• No annual charge during the 4-year period
• After 4 years, worldwide income and gains are fully taxable
• Transitional provisions for those who were on the remittance basis before April 2025, including a one-off 12% rate on previously unremitted income brought to the UK before April 2027

The FIG regime is significantly shorter than the old remittance basis (which could last 15+ years) but simpler and more generous during the 4-year window because it does not require segregation of foreign income offshore.

Ireland: Remittance Basis

Ireland continues to operate a remittance basis for non-domiciled residents, making it the closest remaining analogue to the UK's former regime.

Key features:

• Irish-resident non-domiciled individuals are taxed on Irish-source income and foreign income remitted to Ireland
• Foreign income kept outside Ireland is not subject to Irish income tax
• No time limit on the remittance basis -- it applies for as long as the individual remains non-domiciled
• The deemed domicile rule applies after the individual has been Irish resident for 3 consecutive years (but this triggers liability to capital acquisitions tax, not income tax)
• No annual charge for using the remittance basis
• USC (Universal Social Charge) applies to worldwide income regardless of remittance

Ireland's regime is indefinite and does not carry an annual charge, making it one of the most attractive remaining non-dom regimes worldwide.

Malta: Global Residence Programme and Non-Dom Rules

Malta offers a dual framework for non-domiciled residents:

Non-dom status (general):

• Non-domiciled residents are taxed on Maltese-source income and foreign income remitted to Malta
• Foreign income not remitted to Malta is not taxed
• A minimum annual tax of EUR 5,000 applies
• Capital gains arising outside Malta are not taxed even if remitted

Global Residence Programme (for non-EU/EEA/Swiss nationals):

• 15% flat tax on foreign income remitted to Malta
• Minimum annual tax of EUR 15,000
• Qualifying property requirement (purchase EUR 275,000+ or rent EUR 9,600+)
• No tax on foreign capital gains regardless of remittance

Cyprus: Non-Domicile Regime

Cyprus introduced its non-domicile regime in 2015, modelled partly on the UK's former system.

Key features:

• Non-domiciled residents are exempt from Special Defence Contribution (SDC) on dividends, interest, and rental income
• SDC rates that domiciled residents pay: 17% on dividends, 30% on interest, 3% on rent
• The exemption lasts for 17 years from the date of becoming Cyprus tax resident
• An individual who was born in Cyprus and had a Cyprus domicile of origin must have been non-resident for 20 years to requalify
• No minimum tax applies
• Capital gains are only taxed on immovable property in Cyprus

The practical effect for an entrepreneur resident in Cyprus with a non-dom status: 0% tax on dividends, 0% on interest, 0% on foreign rental income, and no wealth tax. Combined with Cyprus's 12.5% corporate tax rate and extensive treaty network, this creates a highly efficient structure.

Italy: Flat Tax Regime for New Residents

Italy's regime is not technically a non-dom regime but achieves a similar result:

• New residents (who have not been Italian tax resident in 9 of the previous 10 years) can opt for a flat substitute tax of EUR 200,000 per year on all foreign-source income and gains (increased from EUR 100,000 in 2024)
• The flat tax replaces IRPEF, addizionale regionale, and addizionale comunale on foreign income
• Family members can join for EUR 25,000 each
• Italian-source income is taxed at normal progressive rates (up to 43%)
• The regime lasts for up to 15 years
• No obligation to disclose foreign financial assets or file RW declarations on covered income

Greece: Special Tax Regimes

Greece offers two distinct programmes:

7% flat tax for retirees:

• Foreign pension and other foreign-source income taxed at 7% for 15 years
• Requires transfer of tax residence from a country with a DTA or TIEA with Greece
• Must not have been Greek tax resident for 5 of the previous 6 years

Non-dom investor regime:

• EUR 100,000 annual flat tax on worldwide income for individuals investing at least EUR 500,000 in Greek real estate, business, or financial assets
• Family members at EUR 20,000 each
• Duration: 15 years

Switzerland: Lump-Sum Taxation (Forfait Fiscal)

Switzerland's lump-sum taxation regime taxes qualifying foreign nationals based on their living expenses rather than actual income. This is not technically a non-dom regime but serves a similar function for wealthy individuals.

Key features:

• Available only to foreign nationals who do not work in Switzerland
• Taxable base is calculated as a multiple of the individual's annual living expenses, with a minimum varying by canton (from CHF 400,000 in some cantons to CHF 1,000,000+ in others)
• Federal minimum base: CHF 421,700 (2024)
• Both federal and cantonal/communal taxes apply to the lump-sum base
• Effective overall rates vary by canton but typically range from 20-30% of the lump-sum base
• DTAs can be claimed against the lump-sum base

Comparing the Regimes

Feature	UK (FIG)	Ireland	Malta	Cyprus	Italy
Duration	4 years	Indefinite	Indefinite	17 years	15 years
Annual charge	None	None	EUR 5,000	None	EUR 200,000
Foreign CGT	Exempt (4 yrs)	Remittance basis	Exempt	SDC exempt	Covered by flat tax
Complexity	Low	Medium	Medium	Low	Low

Key Takeaways

• The UK's FIG regime offers a powerful but short 4-year window of complete foreign income and gains exemption for new arrivals.
• Ireland's remittance basis remains the most generous indefinite non-dom regime in Europe.
• Cyprus offers 17 years of exemption from SDC on dividends, interest, and rental income, making it exceptional for passive income recipients.
• Italy's flat tax is best suited to ultra-high-net-worth individuals for whom EUR 200,000 represents a fraction of actual foreign income.
• Malta's general non-dom status offers remittance-basis treatment with a low EUR 5,000 minimum tax.
• The choice between regimes depends on income type, quantum, intended duration of residence, and lifestyle preferences.