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Non-Dom Regimes Explained: UK, Ireland, Italy, and Beyond · IMI Podcasts

• 0:00
  SPEAKER_00: If you earn income from outside the country where you live, a non-domicile or non-dom tax regime could shield that foreign income from local taxation.
• 0:09
  SPEAKER_00: For decades, the United Kingdom offered one of the world's most generous versions of this arrangement.
• 0:14
  SPEAKER_00: That era ended on April 6, 2025.
• 0:18
  SPEAKER_00: The UK's abolition of its historic non-DOM system has reshaped the tax planning options available to internationally mobile individuals.
• 0:26
  SPEAKER_00: But the concept itself has not disappeared.
• 0:28
  SPEAKER_00: Several European countries still offer non-Dom or non-Dom style regimes, each with distinct rules, costs, and trade-offs.
• 0:36
  SPEAKER_00: Understanding how they work can help you decide whether relocating your tax residence makes sense for your situation.
• 0:43
  SPEAKER_00: Non-domiciled status separates where you live from where your permanent home is considered to be.
• 0:49
  SPEAKER_00: Your domicile is typically your country of origin or the place you intend to return to permanently.
• 0:55
  SPEAKER_00: If you reside in a country but maintain domicile elsewhere, you may qualify for non-dom treatment.
• 1:01
  SPEAKER_00: You pay tax only on income generated within your country of residence.
• 1:05
  SPEAKER_00: Foreign income stays outside the local tax net, either entirely or until you bring it into the country.
• 1:12
  SPEAKER_00: This distinction matters if you hold investments abroad, receive foreign dividends, or run businesses outside your country of residence.
• 1:21
  SPEAKER_00: Under ordinary tax rules, most countries would tax all of this.
• 1:26
  SPEAKER_00: Non-DOM regimes create an exception.
• 1:28
  SPEAKER_00: Two main approaches exist.
• 1:30
  SPEAKER_00: Remittance-based systems tax foreign income only when you transfer it into the country.
• 1:36
  SPEAKER_00: Territorial systems exempt foreign income, regardless of whether you bring it in.
• 1:41
  SPEAKER_00: The former UK model followed the remittance basis.
• 1:44
  SPEAKER_00: Countries like Singapore and Panama operate territorial systems.
• 1:49
  SPEAKER_00: The United Kingdom operated its non-DOM regime for over 200 years.
• 1:53
  SPEAKER_00: Wealthy expatriates could avoid UK taxes on overseas income and capital gains for up to 15 years, provided they did not bring those funds into the country.
• 2:03
  SPEAKER_00: That system no longer exists for new arrivals.
• 2:06
  SPEAKER_00: The UK replaced it with the foreign income and gains, also known as FIG regime, which took effect in April 2025.
• 2:15
  SPEAKER_00: Under the new rules, individuals who have not been UK tax residents for at least 10 years, immediately before applying, can claim a four-year exemption on foreign income and gains.
• 2:28
  SPEAKER_00: After that window closes, the UK taxes your worldwide income at standard rates.
• 2:34
  SPEAKER_00: The shift triggered a mass departure.
• 2:37
  SPEAKER_00: According to data from the Henley Wealth Migration Dashboard, the UK lost 10,800 millionaires in 2024 alone.
• 2:44
  SPEAKER_00: Between October 2024 and July 2025, nearly 3,800 company directors moved their official residence abroad, representing a 40% increase from the same period the previous year.
• 2:57
  SPEAKER_00: Jimmy Sexton, founder and CEO of Esquire Group, believes the UK is making every wrong financial decision possible.
• 3:06
  SPEAKER_00: He argues the changes have weakened the country's ability to attract global capital.
• 3:11
  SPEAKER_00: If you already established UK tax residence under the old rules before April 2025, transitional provisions may apply.
• 3:18
  SPEAKER_00: New arrivals face stricter conditions.
• 3:21
  SPEAKER_00: Ireland operates a non-DOM regime that closely resembles what the UK once offered.
• 3:27
  SPEAKER_00: If you are tax resident in Ireland but maintain domicile elsewhere, foreign income faces taxation only when you remit it to Ireland.
• 3:36
  SPEAKER_00: Several features make Ireland's version more attractive than the former UK system.
• 3:42
  SPEAKER_00: There is no time limit.
• 3:44
  SPEAKER_00: The UK imposed deemed domicile rules after 15 years, forcing long-term residents onto worldwide taxation.
• 3:52
  SPEAKER_00: Ireland has no such cutoff.
• 3:54
  SPEAKER_00: You can use the remittance basis indefinitely, as long as you do not acquire Irish domicile.
• 4:01
  SPEAKER_00: There is no annual fee.
• 4:03
  SPEAKER_00: The UK charged£30,000 or£60,000 per year for non-DOMs who had been resident for seven or more years.
• 4:10
  SPEAKER_00: Ireland imposes no equivalent charge.
• 4:13
  SPEAKER_00: There is no formal application process.
• 4:15
  SPEAKER_00: You qualify based on your circumstances, not through an approval procedure.
• 4:20
  SPEAKER_00: The rules governing what constitutes a remittance are extensive and technical.
• 4:24
  SPEAKER_00: Using a foreign credit card for purchases in Ireland, withdrawing cash from foreign accounts at Irish ATMs, or transferring funds to Irish bank accounts can all trigger tax liability.
• 4:35
  SPEAKER_00: Planning ahead is essential.
• 4:37
  SPEAKER_00: For those who structure their affairs carefully, Ireland offers the possibility of near zero taxation on foreign income while maintaining full EU residency.
• 4:48
  SPEAKER_00: Italy takes a different approach.
• 4:50
  SPEAKER_00: Rather than exempting foreign income entirely, the country offers a lump sum tax that replaces ordinary taxation on non-Italian earnings.
• 5:00
  SPEAKER_00: On December 30, 2025, Italy officially raised this flat tax to€300,000 per year.
• 5:08
  SPEAKER_00: Family members can be included for an additional 50,000 euros each.
• 5:12
  SPEAKER_00: The regime lasts up to 15 years.
• 5:15
  SPEAKER_00: This marks the second increase in two years.
• 5:18
  SPEAKER_00: The government set the original rate at 100,000 euros when the program launched in 2017, then doubled it to 200,000 euros in 2024.
• 5:29
  SPEAKER_00: The higher threshold filters for ultra high net worth individuals.
• 5:33
  SPEAKER_00: If you earn 1.5 million euros or more annually from foreign sources, the math still works in your favor.
• 5:40
  SPEAKER_00: Top marginal rates in most European countries exceed 45%, often combined with wealth taxes, inheritance taxes, and extensive reporting obligations.
• 5:51
  SPEAKER_00: Italy's flat tax eliminates all of that for qualifying for an income.
• 5:56
  SPEAKER_00: You also gain exemption from Italian gift and inheritance tax on foreign assets.
• 6:02
  SPEAKER_00: This benefit appeals to families engaged in intergenerational wealth planning.
• 6:07
  SPEAKER_00: Italy also offers additional special tax regimes for specific situations.
• 6:12
  SPEAKER_00: To qualify, you must not have been an Italian tax resident for at least nine of the previous ten years.
• 6:19
  SPEAKER_00: The regime applies only to foreign sourced income.
• 6:22
  SPEAKER_00: Any money you earn within Italy faces standard Italian rates.
• 6:27
  SPEAKER_00: Timing matters.
• 6:28
  SPEAKER_00: Italy has respected grandfathering principles in both rate increases.
• 6:33
  SPEAKER_00: If you established residence before December 30th, 2025, you can continue paying the€200,000 rate for the full 15-year period.
• 6:43
  SPEAKER_00: Greece introduced its own non-DOM programs in 2019 and 2020, targeting different profiles.
• 6:49
  SPEAKER_00: The investor regime requires a minimum 500,000 euro investment in Greek assets.
• 6:55
  SPEAKER_00: In return, you pay a flat 100,000 euro per year on all foreign income, regardless of the amount.
• 7:02
  SPEAKER_00: The program runs for up to 15 years.
• 7:05
  SPEAKER_00: Family members can be added for 20,000 euros each.
• 7:09
  SPEAKER_00: Foreign income under this arrangement is entirely exempt from Greek taxation.
• 7:14
  SPEAKER_00: You are not required to declare it.
• 7:16
  SPEAKER_00: Assets held abroad face no Greek wealth taxes.
• 7:21
  SPEAKER_00: Income generated within Greece, by contrast, falls under standard rates.
• 7:25
  SPEAKER_00: Malta operates a remittance-based system similar to Ireland's.
• 7:29
  SPEAKER_00: If you are tax resident but not domiciled in Malta, foreign income kept abroad remains untaxed.
• 7:35
  SPEAKER_00: The minimum annual charge is 5,000 euros, well below what the UK used to require.
• 7:42
  SPEAKER_00: There is no deemed domicile rule.
• 7:45
  SPEAKER_00: You can maintain non-dom status indefinitely without being forced onto worldwide taxation after a set number of years.
• 7:54
  SPEAKER_00: Cyprus doesn't use a remittance system.
• 7:56
  SPEAKER_00: Instead, it taxes individuals on worldwide income once you're tax resident there.
• 8:02
  SPEAKER_00: However, if you're tax resident but not domiciled in Cyprus, you can be exempt from the special defense contribution, SDC, on dividends and most passive interest for up to 17 years.
• 8:16
  SPEAKER_00: This means these types of income aren't subject to SDC, whether they're earned abroad or in Cyprus.
• 8:23
  SPEAKER_00: The exemption isn't based on remitting funds into the country.
• 8:26
  SPEAKER_00: High earners in Cyprus also enjoy a 50% tax exemption on employment income above 55,000 euros annually.
• 8:35
  SPEAKER_00: Each non-DOM option involves trade-offs.
• 8:38
  SPEAKER_00: Ireland offers the most generous terms, but requires careful planning around remittance rules.
• 8:44
  SPEAKER_00: Italy provides certainty through its flat tax, but at a higher cost.
• 8:49
  SPEAKER_00: Greece combines investment requirements with straightforward exemptions.
• 8:53
  SPEAKER_00: Malta and Cyprus balance EU access with favorable tax treatment.
• 8:59
  SPEAKER_00: Your decision depends on factors, including the size and sources of your foreign income, how long you plan to stay, whether you need EU residency, and your tolerance for complexity.
• 9:10
  SPEAKER_00: The UK's exit from the non-DOM market has not eliminated opportunities.
• 9:16
  SPEAKER_00: It has simply shifted them to countries willing to compete for internationally mobile wealth.
• 9:21
  SPEAKER_00: For those prepared to relocate, the options remain substantial.
• 9:27
  SPEAKER_00: This episode first appeared as an article by Nagy Sabolts on IMIDAily.com.
• 9:34
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• 9:41
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