Non-dom tax regimes in Europe: how the UK, Ireland, Italy and other options work

If you earn income outside the country where you live, a non-domiciled (non-dom) regime may help protect foreign receipts from tax in your country of tax residence. For decades, one of the most attractive non-dom approaches was offered by the United Kingdom—but from 6 April 2025, that model has been discontinued for new applicants.

That said, the underlying idea has not disappeared: several European countries still use non-dom or similar, logic-based systems. Each option has its own eligibility conditions, cost, and “pitfalls.” Understanding the differences matters if you want to assess whether changing your tax residence is worth it.

What does Non-Dom status mean?

The essence of the non-dom approach is to separate your actual place of living from your domicile—the country considered to be your permanent home. Domicile is typically linked to your country of origin or your intended “return” destination.

If you live in one country but your domicile remains in another, you may qualify for a regime where taxes apply not to all income, but only to income treated as arising in the country of tax residence.

In practice, this means that foreign income can remain outside the tax base either fully or until you “bring it in” to the country (for example, via remittances and certain transactions).

This is especially important if you have foreign investments, overseas dividends, or a business operated outside your country of residence. Under a typical tax model, most countries tax such receipts. A non-dom regime creates an exception.

Globally, two approaches are more common:

• Remittance-based: foreign income is taxed when you actually transfer it into the country.

• Territorial: foreign income is exempt regardless of whether you remit it to the country.

Before the reforms, the UK model operated on the remittance basis. Similar territorial-style regimes are known elsewhere—for instance, in Singapore and Panama.

The new reality for the UK

The UK used its own non-dom regime for more than 200 years. For wealthy expatriates, it allowed them to avoid UK taxation on foreign income and capital gains for up to 15 years—provided the funds were not brought into the country.

From 6 April 2025, the system is removed for new cases. In its place, the Foreign Income and Gains (FIG) regime is introduced.

Under FIG, individuals who have not been UK tax residents for at least 10 years prior to filing may qualify for a 4-year exemption on foreign income and capital gains. After that window expires, the UK taxes worldwide income under standard rates.

The reform triggered a noticeable shift: according to the Henley Wealth Migration Dashboard, in 2024 the UK lost 10,800 millionaires. Between October 2024 and July 2025, almost 3,800 company directors moved their official tax residence abroad—40% more than in the comparable period a year earlier.

Jimmy Sexton, Head of Esquire Group, believes the country is “making the worst possible financial decisions,” thereby weakening its appeal to internationally mobile capital.

If you were able to establish UK tax residence under the old rules before April 2025, transitional provisions may apply. For new entrants, the conditions are substantially stricter.

Ireland keeps the “classic” approach

Ireland applies a non-dom regime with mechanics close to what the UK used to offer. If you are an Irish tax resident but your domicile remains in another country, then foreign income is taxed only when remitted (i.e., brought into Ireland).

Key advantages of the Irish version:

1) No time limit. In the UK, rules effectively moved long-term residents toward worldwide taxation over time (deemed-domicile). In Ireland, there is no such cut-off: remittance basis can be applied for the long term until you acquire Irish domicile.

2) No annual fee. In the UK, many non-dom taxpayers faced annual charges (for example, £30,000 or £60,000 after 7+ years of residence). Ireland does not have an equivalent payment.

3) No formal approval procedure. Eligibility is based on circumstances rather than a separate “application” for approval.

At the same time, the rules on what counts as a remittance are detailed and technically complex. Spending abroad on an Irish card, withdrawing cash from ATMs, transferring funds to Irish accounts—any of these can trigger tax consequences. That’s why planning must be done in advance.

For those who build their structure carefully, Ireland can provide a path to near-zero taxation on foreign income while staying within an EU-compliant status framework.

Italy: a flat tax up to €300,000

Italy works differently: instead of fully exempting foreign income, it uses a fixed (lump-sum) tax that replaces ordinary taxation on income sourced outside Italy.

From 30 December 2025, the flat-tax threshold is officially increased to €300,000 per year. For a family, an additional €50,000 can be added for each included family member. The regime lasts up to 15 years.

The increase is the second in two years: the starting amount was €100,000 in 2017, then raised to €200,000 in 2024.

A higher threshold is designed for ultra-high earners. If your foreign income is €1.5 million per year or more, the economics may still be favorable.

In most European countries, top tax rates often exceed 45% and may be supplemented by taxes on capital/wealth, inheritance, and expanded reporting obligations. Italy’s flat tax, for qualifying foreign income, essentially removes those complexities.

In addition, there is an exemption from Italian gift and inheritance taxes on foreign assets—particularly relevant for families planning intergenerational wealth transfers. Italy also offers other special tax regimes for specific scenarios.

To qualify, it’s crucial that you have not been an Italian tax resident for at least 9 out of the last 10 years. The regime applies only to income from foreign sources. Income earned within Italy is taxed under standard Italian rules.

Timing matters as well. Italy applies a “grandfathering” approach when increasing rates: if you established tax residence before 30 December 2025, you can continue paying the €200,000 rate for the full 15-year period.

Greece offers two paths

Greece launched its own non-dom programs in 2019 and 2020—each aimed at different taxpayer profiles.

The investor regime requires minimum investments in Greek assets of at least €500,000. In return, you pay a fixed €100,000 per year on all foreign income outside Greece, regardless of its size. The term can last up to 15 years. For a family, you can add €20,000 per included member.

Under this model, foreign income is fully exempt from Greek taxation, and you do not need to declare such income. Foreign assets are also not subject to Greek wealth-related taxes. However, income generated in Greece is taxed under standard rates.

Malta and Cyprus: different mechanics

Malta uses a remittance-based system similar to Ireland’s. If you are a Malta tax resident but do not have domicile in Malta, then foreign income that remains outside Malta is not taxed. The minimum annual payment is €5,000, which is significantly lower than what was required in the UK previously.

There is also no “deemed domicile” rule: you can typically maintain non-dom status for a long time, without an automatic switch to worldwide taxation after a fixed period.

Cyprus does not operate on a remittance model. After obtaining Cyprus tax residency, Cyprus generally taxes worldwide income. However, if you are Cyprus tax resident but do not have Cyprus domicile, you may be exempt from Special Defence Contribution (SDC) on dividends and most passive interest for up to 17 years. In that case, these types of income are not subject to SDC whether they are received abroad or earned within Cyprus—the exemption is not tied to remittance.

Additionally, for higher earners in Cyprus, there is a 50% exemption on employment income above €55,000 per year.

How to choose the right regime

Every non-dom option comes with trade-offs. Ireland often looks the most flexible and advantageous, but it requires discipline and strict compliance with remittance rules. Italy offers more certainty through a fixed tax, though the regime’s cost is usually higher.

Greece combines investment requirements with relatively straightforward exemptions. Malta and Cyprus provide access to a European jurisdiction while offering attractive tax conditions—but through different mechanisms.

The best choice depends on the size and sources of your foreign income, how long you plan to stay, whether you need to preserve EU-compliant status, and how comfortable you are with tax complexity and transaction documentation.

The end of the UK non-dom market does not mean there are no options—it simply shifted competition toward countries that are willing to attract internationally mobile capital. For those ready to relocate and plan properly, there are still plenty of alternatives across Europe.

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