NewCountries with no income tax in 2026 — read the guide →Countries with 0% income tax →

Tax & offshore

Non-dom and special-regime countries in 2026

The UK closed the world's oldest non-dom regime in 2025. Here is where mobile capital is going instead, and what each replacement actually costs.

By 2026-09-159 min read
Non-dom and special-regime countries in 2026
Photograph — Marc Zimmer / Unsplash
The short answer

In 2026 the main non-dom and special-regime countries are Malta, Cyprus and Ireland (remittance-basis systems), plus Italy and Greece (flat-tax regimes for new residents). The UK abolished its non-dom regime in April 2025, replacing it with a four-year foreign income and gains (FIG) exemption for new arrivals.

The non-dom map has been redrawn

For two centuries the United Kingdom ran the world's best-known non-dom regime: UK residents who were domiciled elsewhere could keep foreign income and gains outside the UK tax net unless they brought the money in. That system ended on 6 April 2025. In its place sits a residence-based rule with a four-year shelf life, which pushed a wave of internationally mobile capital toward the remaining European regimes.

Two families of regime survive. Remittance-basis systems (Malta, Cyprus, Ireland) tax foreign income only when you bring it into the country. Flat-tax regimes (Italy, Greece) charge a fixed annual sum that covers all foreign income regardless of amount. Both hinge on you being genuinely tax-resident somewhere, so read our guide on how to establish tax residency abroad before you act. The table below sets out the live options as of 2026; verify every figure before you move, because these regimes change with each budget.

RegimeTypeCost / rate on foreign incomeDurationPrior non-residence
Italy (flat tax, Art. 24-bis)Flat tax€300,000/yr (arrivals from 1 Jan 2026); €50,000 per family memberUp to 15 years9 of last 10 years
Italy (7% pensioners, South)Flat tax7% on all foreign income10 years5 years
Greece (non-dom HNWI)Flat tax€100,000/yr; €20,000 per family memberUp to 15 years7 of last 8 years
Greece (7% pensioners)Flat tax7% on all foreign incomeUp to 15 years5 of last 6 years
Malta (resident non-dom)Remittance basisTax only on remitted income; min. €5,000/yr if foreign income over €35,000No time limitNot required
Cyprus (non-dom)Remittance + SDC exemption0% SDC on dividends & interest; standard PIT on the rest17 yearsNot tax-resident 17 of last 20 years
Ireland (non-dom)Remittance basisTax only on remitted foreign income; no access chargeDomicile levy risk after 15 yearsNot required
UK (FIG regime)4-year exemption0% on foreign income & gains for 4 years, then worldwide tax4 years10 consecutive years
Portugal (IFICI / NHR 2.0)Targeted incentive20% flat on eligible PT income; foreign-income exemptions10 years5 years + qualifying job
Non-dom is not the same as no-tax. Every regime here still taxes local-source income at normal rates, and most still expect you to spend real time in the country. The saving is on foreign income, not on your life.

The UK wind-down: what replaced non-dom

From 6 April 2025 the remittance basis and the concept of domicile were removed from UK tax. New arrivals who have been non-UK resident for at least 10 consecutive tax years now get the four-year foreign income and gains (FIG) regime: full relief on foreign income and gains for their first four years of UK residence, with no access charge. After year four, they are taxed on worldwide income like any other resident. HMRC also opened a Temporary Repatriation Facility running to 2027 that lets former remittance-basis users bring in pre-April-2025 wealth at 12% (rising to 15% in the final year) rather than at full rates.

The practical effect: the UK went from an indefinite, wealth-friendly regime to a short runway. That is why advisers spent 2025 fielding calls about Italy, Greece, Cyprus and the UAE. If the UK is your starting point, the remittance basis and 183-day rule glossary entries explain the mechanics you are leaving behind.

Flat-tax regimes: Italy and Greece

Italy's Article 24-bis flat tax is the premium option. A single substitute tax covers all foreign-source income for up to 15 years, and Italy raised the headline figure to €300,000 a year for anyone becoming resident from 1 January 2026 (it was €200,000 before, and €100,000 at launch in 2017). Existing beneficiaries are grandfathered at their entry rate. Family members can be added for €50,000 each. It only makes sense above roughly €3–5m of annual offshore income, but for that cohort the certainty is the product. See our Italy tax residency guide for the residence mechanics.

Greece's non-dom regime undercuts Italy at €100,000 a year for foreign income, plus €20,000 per family member, for up to 15 years, but it demands a €500,000 qualifying investment within three years. Both countries also run a 7% flat tax for foreign pensioners: Italy's version applies in southern towns (the population ceiling rose to 30,000 in 2026, opening 74 new municipalities) for 10 years; Greece's applies nationwide for up to 15 years. For retirees on a foreign pension, 7% on everything is often the single cheapest legal outcome in the EU. Compare the residence side in our Greece tax residency guide.

Remittance-basis regimes: Malta, Cyprus, Ireland

Malta taxes resident non-doms only on Maltese income and on foreign income actually remitted to Malta; foreign capital gains stay untaxed even if brought in. The catch is a minimum tax of €5,000 a year once foreign income exceeds €35,000. Crucially, Malta imposes no deemed-domicile time limit, so the regime can run indefinitely. Our Malta tax residency guide and Malta banking guide cover the setup.

Cyprus pairs non-dom status with a 17-year exemption from the Special Defence Contribution, meaning 0% tax on dividends and interest for that whole window. You can qualify as tax-resident on either the 183-day test or the more flexible 60-day rule, which Cyprus simplified from 2026. It is the strongest regime in Europe for someone living off an investment portfolio. See our Cyprus tax residency guide.

Ireland offers the plainest version: non-domiciled residents pay Irish tax on Irish income and on foreign income only when remitted, with no access charge at all. The limiting factor is the domicile levy — long-term non-doms resident 15 years or more can face a deemed charge on very high worldwide income. For most people it is a clean, treaty-rich base. Our Ireland tax residency guide has the detail.

Portugal is no longer a non-dom play. The old NHR regime closed to new entrants at the end of 2023 and was replaced by IFICI ("NHR 2.0"), a narrow 20% incentive aimed at scientific-research and high-skill roles — not a general shelter for passive foreign income.

How this fits a borderless plan

A non-dom regime is one leg of a wider structure, not the whole thing. It only works if your tax residency is real and defensible, so start with how to establish tax residency abroad and understand the centre of vital interests test that decides ties in disputes. If your home country runs CFC rules or an exit tax, model those before you leave — they can erase the saving.

Second, decide whether you want tax certainty (a flat fee) or tax efficiency (a remittance basis you actively manage). High earners with large, lumpy offshore income lean toward Italy or Greece; portfolio investors and entrepreneurs lean toward Cyprus or Malta. If you also want the freedom of movement that a strong passport brings, pair the tax move with a look at golden visas in 2026 and, for the fully mobile, our countries with no income tax analysis. Whatever you choose, get country-specific advice: YMYL rules like these turn on residence dates, treaty wording and remittance timing that a listicle cannot capture.

How Expectat helps you use a non-dom regime properly

Reading a ranking is the easy part — turning it into a move is where most people stall. Here’s how we close that gap with you:

  • We start from your numbers, not a brochure. A first session maps your income, assets, citizenship and family against the shortlist above — and tells you honestly which options fit you, and which only look good on paper.
  • We check whether you actually qualify — and keep it clean. What's genuinely exempt, the remittance rules, and the reporting that stops a good regime becoming a liability.
  • We execute on the ground. We sequence the filings, introduce the vetted local lawyers, tax advisors and banks who’ve done it before, and stay with you until it’s actually done.

You don’t need to become a tax expert or trust a forum thread — that’s our job. Book a strategy call and we’ll turn this into a concrete, personal plan.

Frequently asked questions

Did the UK really abolish non-dom status?

Yes. From 6 April 2025 the remittance basis and the concept of domicile were removed from UK tax. New arrivals who were non-resident for the prior 10 years instead get the four-year FIG regime — full relief on foreign income and gains for four years, then worldwide taxation like any other UK resident.

Which non-dom country is cheapest?

It depends on your income. Malta (min. €5,000/yr) and Ireland (no access charge) are cheapest for moderate foreign income. Cyprus gives 0% on dividends and interest for 17 years. Greece's flat €100,000 or Italy's €300,000 only pay off once your offshore income is very large, because the fee is fixed regardless of amount.

What is the difference between non-dom and a flat-tax regime?

A non-dom (remittance) regime taxes foreign income only when you bring it into the country, so the saving depends on you leaving money offshore. A flat-tax regime charges a fixed annual sum that covers all foreign income whether or not you remit it, trading a higher entry price for total certainty.

Do I have to live in the country to use a non-dom regime?

Usually yes — you must be genuinely tax-resident. That normally means the 183-day rule, though Cyprus offers a 60-day route and some regimes are looser on presence. Local-source income is still taxed at normal rates everywhere, and weak residence ties are the first thing your former home country will challenge.

Is Portugal's NHR still available in 2026?

No. The original Non-Habitual Resident regime closed to new entrants at the end of 2023. Its replacement, IFICI or "NHR 2.0", is a narrow incentive offering a 20% flat rate for scientific-research and high-skill roles — it is not a general shelter for passive foreign income.

Can these regimes change after I move?

Yes, which is why entry timing matters. Italy raised its flat tax from €200,000 to €300,000 for 2026 arrivals but grandfathered existing beneficiaries at their entry rate. Most regimes protect people already inside them, but future budgets can alter rates, durations and eligibility. Verify current terms before you commit.

Sources

Rules change — always confirm the current position with the primary authority:

Work with Expectat

Ready to build your borderless plan?

Book a private strategy session — we'll map your residency, capital and Bitcoin setup, and the fastest legal path to it.

Book a strategy call