The UK non-dom and the structures are being replaced, as confirmed by the Autumn Budget, effective from 6 April 2025. Although details and more clarity are needed, we can still get a look at the new rules of the UK’s non-dom and see the best alternatives to the UK non-dom regime.
What is Non-Domiciled Status?
People who claim to have permanent residence in another country but live 91ƵAPP are called non-dom (non-domiciles). It has been a status giving an option not to pay taxes on income and capital gains that were earned abroad for up to 15 years. The condition was that there were not any money transfers into the country after arriving in Britain.
If a person has had a non-domiciled status, also called a ‘non-dom’ briefly, it means that this person is living in the United Kingdom and is considered to be domiciled under British law in another country. It is known that, like other UK residents, non-doms also pay UK tax to the UK government.
UK Non-Dom Tax Status Rules
According to the Chancellor’s confirmation, the current remittance basis of taxation will not be available for non-doms as of 6 April 2025. Instead, there will be a new four-year foreign income and gains (FIG) regime for those becoming UK tax residents after a period of ten tax years as non-UK residents pass.
2025 Changes on Non-Domiciled Individuals 91ƵAPP
So, what does this mean for non-domiciled individuals 91ƵAPP?
The previous UK government first announced this change in March 2024. When the Labour government came to power, they announced an approach to the UK non-dom rules, indicating that there would be some changes.
Regarding the remittance basis, a new four-year special status has replaced the previous one. During this time, foreign income and gains are tax-free 91ƵAPP. The government may have confined the four-year exemption to merely foreign income and gains rather than UK investment income.
When it comes to the inheritance taxes (IHT), individuals who have been UK tax residents for ten or more of the last twenty years are considered “Long-Term Residents.” Long-term residents are subject to IHT on their worldwide assets even after they no longer qualify as UK tax residents.
Trusts with living, UK resident settlors may have their income and gains attributed to them and taxed appropriately. Long-Term Residents’ trusts may be subject to IHT.
Remember that the UK non-dom program’s changes have not yet been specified for the final version, and we will provide updates as they become available. However, it is not wrong to mention that the latest announcements do not seem positive for UK non-doms.
Although this option 91ƵAPP will probably lose attention, there are some other alternatives to the UK’s non-dom regime. Let’s discover the top alternative tax programs below.
Top 5 Alternatives to UK’s Non-Dom
A Tax-Friendly Alternative: Switzerland
One of the alternatives to the UK’s non-dom status is Switzerland’s taxation system. It is designed for wealthy foreigners and allows them to be taxed according to their living expenses instead of their total income. However, there are specific criteria to benefit from this taxation system. Excluding Swiss citizens, this tax regime requires a Swiss residency of at least ten years or a first-time residency. The rule also prohibits any gainful activity in Switzerland, making it obligatory for both spouses to meet the same conditions.
Here is how tax is calculated:
- It is based on annual living expenses
- It needs to meet a minimum threshold of CHF 429,100 (USD 497,76)
- Or it may be based on multiples of rent or Swiss-source income
As a taxpayer, you need to submit a declaration, prove your eligibility to apply, and inform authorities of any changes that appear that might affect your tax status. You might benefit from double tax treaties, especially for your foreign withholding tax relief. For these double tax treaties, remember that there are special conditions for countries like Germany, Italy, and the US. Another important detail is that the wealth tax also applies here, and it may vary by canton.
Generally, this system is for high-net-worth individuals who are not working in Switzerland. Those individuals benefit from a competitive, expenditure-based tax structure.
When the Non-Dom 91ƵAPP is abolished, it seems that this program will be interesting for many wealthy citizens who will face a new tax reality 91ƵAPP and are facing the risk of losing their previous benefits.
Caribbean Citizenship by Investment Programs with Tax Benefits
Caribbean citizens don’t pay taxes on wealth, inheritance, capital gains, or exports.
The citizens of the Caribbean do not pay taxes on;
Wealth
Capital Gains
Inheritance
Exports
Besides, the citizens of Antigua and Barbuda and St Kitts and Nevis do not also pay personal income tax. In addition, St Lucia and Grenada citizens are not expected to pay for their worldwide income.
You may explore a lot of benefits to holding a Caribbean passport, including a visa-free regime with Schengen states and the beneficial taxation system.
The taxation rules change from country to country. Let’s take St Kitts and Nevis, for example, where you do not need to pay an income tax. Grenada and St Lucia, on the other hand, do not require a gift tax.
Malta's Permanent Residency
Contrary to the UK’s ending regime, Malta continues to offer a non-dom regime similar to Ireland’s system. Malta’s non-dom regime includes the following tax advantages:
- Profits you generate outside Malta are not subject to tax if they are not brought into Malta.
- Capital gains you obtained outside Malta are not taxed as well, and in this case, it does not matter if they are brought into the country or not.
There are, though, some tax requirements for expats as well, like income Tax in Malta ranging from 0% to 35%.
Greece Non-Dom for Retirees and Investors
When we turn our face to Greece’s Non-Domicile (Non-Dom) Regime, we can discover favorable tax options for foreign pensioners and investors who relocated to Greece.
Here’s what Greece’s Non-Dom status (non-dom for pensioners) offers:
- If you are a qualified foreign pensioner in Greece, you can benefit from a 7% flat tax rate on your foreign pension income for up to 15 years.
- To be eligible, you need to be a non-Greek resident for 5 of the last 6 years.
- You need to have a tax residency in a country with a tax cooperation agreement with Greece.
- You are expected to spend at least 183 days a year in Greece.
Let’s also have a look at the Greece’s Non-Dom status for investors:
- As an investor, you can pay a flat tax of €100,000 annually on your worldwide income for 15 years if you transfer your tax residence to Greece.
- To be a qualified investor for the non-dom status, you need to prove that you have not been a Greek tax resident for 7 of the last 8 years, and you need to make an investment worth a minimum of €500,000 in Greece within 3 years.
- It might be a real estate investment, or you can invest in a Greek business. As an applicant, you may make the investment yourself, your close relatives, or a legal entity holding majority shares.
- If you are a Greece Golden Visa investor, then you are exempt from the investment requirement. The eligibility criteria may change.
Spain's Beckham Law
Beckam Law is a special reduced tax regime that is beneficial for foreign workers in Spain. Non-residents who have an IRPF (Impuesto de Renta Sobre las Personas Físicas) personal income tax of 24%, not the progressive tax rate that is applicable to residents of Spain.
It is a fiscal opportunity if you are working in Spain as a foreigner. The initial goal to develop this tax regime was to attract top talent and investment into Spain. So this regulation, from the beginning until today, offers a substantial tax reduction on the Spanish taxable income of eligible individuals.
Other EU Non-Dom Tax Options
Ireland Non-Dom Tax and Remittance Program
A tax resident but non-domiciled individual in Ireland is taxed on any Irish source income or gains. However, they can use the remittance basis of taxes on any foreign income.
The benefits of this include the following:
- Foreign income or gains not brought into Ireland (while an Irish tax resident) can accrue tax-free.
- Cash earned prior to attaining Irish tax residency can be brought into Ireland without paying additional Irish taxes.
- The remittance basis of taxation incurs neither one-time nor annual fees (unlike in other countries where a levy is placed on non-domiciled individuals).
- When it comes to remitting overseas income or gains, Ireland has a large Double Tax Agreement network that lowers the possibility of double taxation or tax-related cash flow concerns.
The Tax Programs of Italy
Non-residents are liable to withholding tax, which is withheld from their gross income at the time of payment. The rate of withholding tax varies according to the type of income, ranging from 12.5% to 30%.
Italy’s optional “non-dom” tax scheme, which was implemented in 2017, intends to attract overseas taxpayers by providing a flat substitute tax on foreign income.
Non-residents are liable to withholding tax, which is withheld from their gross income at the time of payment. The rate of withholding tax varies according to the type of income, ranging from 12.5% to 30%.
Italy’s optional “non-dom” tax scheme, which was implemented in 2017, intends to attract overseas taxpayers by providing a flat substitute tax on foreign income.
The regime includes all foreign income, with the exception of capital gains on the sale of eligible shares within the first five years.
Beneficiaries can exclude income from certain countries, which will be taxed under the usual IRPEF framework, with tax credits available.
The regime is valid for up to 15 years, but beneficiaries can terminate it in any tax year following the first. It also terminates if they fail to pay the tax or lose their Italian tax residency.
Participants are excluded from paying taxes on foreign property, financial products, and bank accounts while the regime is in effect.
This regime cannot be paired with other Italian tax breaks, such as the 7% flat rate for retirees or the inbound worker scheme.
For persons in the non-dom regime, inheritance, and gift taxes apply only to assets held in Italy.
This tax system aims to make Italy a more appealing destination for international high-net-worth persons by simplifying and cutting tax requirements on foreign income.
The Wrap Up
The UK’s non-dom regime is undergoing significant changes, and the taxation remittance basis ends in 2025. It seems that the shift has increased the interest in alternative tax programs and residency programs in other countries. Switzerland, Malta, and Greece are among those that offer attractive alternative tax options instead of the UK’s non-dom.
Some of the countries offer favorable tax treatment, tax benefits, and tax efficiency on either inheritance tax or global income.
Frequently Asked Questions
Does the US have an alternative to the UK non-dom regime?
The US does not really offer an equivalent of the UK’s non-dom regime. The US taxation system is mainly based on citizenship, green card status, and physical presence.
Here are some of the tax systems of the US:
- US Federal Income Tax
- US Federal Transfer Taxes
- State and Local Taxes