What it actually means
Two mechanisms produce the same practical effect under different names:
Remittance basis
Foreign income and gains are only taxed if they are physically brought, or "remitted," into the country. Keep the money offshore, spend it abroad, and it is never taxed locally.
Domicile-based exemption
A resident who is not domiciled in the country (domicile being a stickier, longer-term legal concept than residency, often tied to origin or intent to settle permanently) is exempted from tax on specific categories of foreign income, dividends and interest in particular, for a defined number of years.
Both mechanisms are time-limited or condition-dependent by design. Governments have increasingly moved to cap or restrict them, most dramatically in the UK, which is why this system requires more active monitoring than the other four.
Where it still exists
United Kingdom
4-year FIG regime, new arrivals onlyThe UK's non-dom regime, in place for over two centuries, was abolished on 6 April 2025. It has been replaced by the Foreign Income and Gains (FIG) regime: individuals who move to the UK after having been non-resident for the prior ten years get a strict four-year exemption on foreign income and gains, even if remitted. After four years, or for anyone who does not qualify, worldwide income and gains are taxed as they arise. HMRC estimates roughly 14,800 people qualify for the new regime, against 73,700 who claimed non-dom status the year before it ended. For existing UK non-doms who no longer qualify, this is the single biggest reason Cyprus and Malta have seen a wave of relocation enquiries.
Malta
Remittance basis, indefiniteMalta runs a straightforward remittance-based system with no deemed-domicile rule and no expiry: a tax resident who is not domiciled in Malta pays tax only on Malta-source income and on foreign income actually remitted. A minimum annual charge, starting around €5,000 for an individual, applies under some residence programs. The main limitation is Malta's Controlled Foreign Company rules, which can attribute the profits of a low-taxed foreign company back to the Malta-resident owner if they control it and it is largely passive.
Cyprus
17-year exemption on dividends & interestCyprus does not use a classic remittance system; residents are taxed on worldwide income in principle. But a non-domiciled tax resident, generally someone who has not been Cyprus tax resident for 17 of the prior 20 years, is exempt from the Special Defence Contribution on dividends and most passive interest, an effective 0% on those specific income types, for up to 17 years. Capital gains on securities are exempt outright; Cyprus real estate gains are not. After 17 years, deemed domicile applies and the exemption ends.
Ireland
Remittance basis, no fixed durationIreland taxes residents who are not Irish-domiciled on a remittance basis: foreign income and gains are taxed only when brought into Ireland, with no expiry date on the arrangement itself, though Irish rates on what is taxed are comparatively high.
What this means for a Plan B
Non-dom and remittance systems suit clients with substantial foreign investment income who want EU residency without immediately entering worldwide taxation, but the window is not indefinite everywhere, and the UK's abolition is a clear signal that these regimes are politically exposed. Cyprus's 17-year runway and Malta's indefinite structure currently offer more durability than most alternatives.
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Cyprus non-dom: the 17-year exemption
How Cyprus non-dom status actually works
Cyprus taxes residents on worldwide income in principle, same as most residency-based systems. The non-dom exemption applies specifically to the Special Defence Contribution (SDC), a separate tax that would otherwise apply to dividends, most interest, and rental income for tax residents. A non-domiciled resident, generally someone who has not been Cyprus tax resident for 17 of the previous 20 years, is exempt from SDC entirely.
In practice, this means dividends and interest income are taxed at 0% for a qualifying non-dom, for up to 17 years from the point residency is established. Capital gains on securities (shares, bonds) are exempt outright for all Cyprus tax residents, domiciled or not. Cyprus real estate gains are a separate category and remain taxable.
What is and is not exempt
| Income type | Non-dom treatment |
|---|---|
| Dividends (worldwide) | 0% for up to 17 years |
| Interest (worldwide) | 0% for up to 17 years |
| Capital gains on securities | Exempt (all residents) |
| Salary, business, and other employment income | Taxed as normal income |
| Cyprus real estate gains | Taxable |
After the 17 years: deemed domicile
Once someone has been Cyprus tax resident for 17 of the prior 20 years, deemed domicile applies automatically and the SDC exemption on dividends and interest ends. This is one of the longer runways among non-dom-style regimes in Europe, and considerably more durable than the UK's replacement FIG regime, which offers only four years.
United Kingdom: non-dom abolished, the FIG regime
What actually changed on 6 April 2025
Before the reform, a UK resident who was not UK-domiciled could elect the remittance basis: foreign income and gains were only taxed if brought into the UK, for as long as non-dom status was maintained, in some cases for decades. That regime ended entirely on 6 April 2025, along with the domicile-based approach to UK inheritance tax.
In its place, the Foreign Income and Gains (FIG) regime offers a four-year exemption on foreign income and gains, available only to individuals who have not been UK tax resident for the prior ten years. After four years, or for anyone who does not qualify, worldwide income and gains are taxed as they arise, with no shelter for money kept offshore.
Who qualifies for the FIG regime
Qualification depends on UK tax non-residence for the ten years immediately before arrival. HMRC estimates roughly 14,800 people qualify for the new regime, compared with 73,700 who claimed non-dom status the year before it ended, a substantial narrowing of who benefits.
UK inheritance tax has also moved from a domicile basis to a residence basis: a worldwide estate becomes exposed to UK inheritance tax once someone has been UK resident for 10 years, regardless of domicile.
What this means for existing non-doms
Existing non-doms who no longer qualify for the FIG regime's four-year window face full worldwide taxation going forward. This has been the single largest driver of relocation enquiries into Cyprus and Malta, both of which retain longer-running non-dom-style exemptions. See our Cyprus non-dom page for the most durable current alternative.
Malta non-dom: the remittance basis
How Malta's remittance basis works
A Malta tax resident who is not domiciled in Malta pays tax only on Malta-source income and on foreign income actually remitted into Malta. Foreign income and capital kept outside Malta, never brought in, is not taxed, and unlike the UK's old regime, there is no deemed-domicile rule that eventually forces worldwide taxation after a set number of years.
A minimum annual tax charge applies under some Malta residence programs, commonly starting around €5,000 for an individual, regardless of how much is actually remitted.
The main limitation: CFC rules
Malta's Controlled Foreign Company rules can attribute the profits of a low-taxed foreign company back to the Malta-resident owner if they control it and its income is largely passive. This matters more for holding-company structures than for straightforward personal income, but it should be reviewed before assuming a foreign company's profits are automatically outside Malta's reach.
Ireland non-dom: the remittance basis
How Ireland's remittance basis works
An Irish tax resident who is not domiciled in Ireland, generally someone whose permanent home and long-term intent lie elsewhere, is taxed on Irish-source income as normal, but on foreign income and gains only when they are remitted into Ireland. Money kept offshore indefinitely is never taxed in Ireland under this basis, and there is no deemed-domicile rule ending the arrangement after a fixed period.
The trade-off is Ireland's rates on what is taxed: income tax reaches 40% at a relatively modest threshold, plus USC (Universal Social Charge) and PRSI, making Ireland's system best suited to residents who can genuinely keep the bulk of their foreign income and gains outside the country.
Frequently asked questions
How is Cyprus non-dom different from the UK's old non-dom regime?
The UK's old regime used a remittance basis: foreign income was untaxed only if kept offshore. Cyprus non-dom instead exempts specific income categories (mainly dividends and interest) from a specific tax (the SDC), regardless of whether the money is brought into Cyprus or not.
Does Cyprus non-dom status cover salary income?
No. Salary and other employment or business income is taxed under Cyprus's normal progressive income tax scale regardless of domicile status. The non-dom exemption is specific to the Special Defence Contribution on dividends, interest, and rental income.
What happens to my exemption after 17 years?
Deemed domicile applies automatically once you have been Cyprus tax resident for 17 of the prior 20 years, and the SDC exemption on dividends and interest ends from that point.
Is UK non-dom status completely gone?
Yes, the historic non-dom regime and its remittance basis ended on 6 April 2025. It has been replaced by the narrower, time-limited FIG regime.
How long does the new FIG exemption last?
Four years from the point someone becomes UK tax resident, provided they were not UK tax resident for the prior ten years.
What are the alternatives if I no longer qualify?
Cyprus (17-year exemption on dividends and interest) and Malta (indefinite remittance basis) are the two most commonly considered EU alternatives for clients affected by the UK change.
Did UK inheritance tax rules change too?
Yes. UK inheritance tax moved from a domicile basis to a residence basis, reaching a worldwide estate once someone has been UK resident for 10 years.
Does Malta's non-dom status expire?
No. Unlike the UK's former regime and Cyprus's 17-year rule, Malta's non-dom remittance basis has no deemed-domicile rule and no fixed expiry.
Is there a minimum tax I have to pay regardless?
Under some Malta residence programs, yes, a minimum annual charge (commonly from around €5,000) applies regardless of how much foreign income is actually remitted.
How does Malta compare to Cyprus for non-dom status?
Malta's remittance basis has no expiry but requires funds to stay offshore to remain untaxed. Cyprus exempts dividends and interest outright for up to 17 years regardless of remittance, but that exemption ends at deemed domicile. Which is better depends on whether you plan to bring the income into your country of residence.
Does Ireland's non-dom status expire like the UK's used to?
No. Ireland has no deemed-domicile rule forcing a shift to worldwide taxation after a set number of years, unlike the UK's old regime.
Are Ireland's tax rates high even under the remittance basis?
Yes, relative to Malta and Cyprus. Ireland's income tax reaches 40% at a comparatively modest threshold, so the remittance basis matters more if a meaningful share of income is genuinely kept outside Ireland.
Last reviewed 15 September 2026.
This guide is general information, not legal, tax or immigration advice. Programme terms are set by the relevant government and can change; confirm any figure with the authority, or with us, before acting on it.
