The countries with non-dom tax regimes today are Ireland, Cyprus, Malta, Italy, Greece, and Switzerland, each offering some form of preferential treatment on foreign income for residents whose permanent home is considered to be elsewhere. Territorial systems in Singapore, Hong Kong, and the United Arab Emirates produce a similar effect for foreign-source income without using the domicile concept at all. The United Kingdom, historically the most prominent non-dom jurisdiction, abolished its remittance basis on 6 April 2025 and replaced it with a narrower four-year relief. Portugal closed its Non-Habitual Resident program to new applicants and replaced it with a much tighter successor. The landscape is moving quickly, and several of the remaining programs have raised their charges or tightened their rules within the last two years.
Three Models to Compare
The label “non-dom” covers three quite different mechanisms, and the differences matter more than the name.
A remittance basis taxes foreign income only when the resident brings it into the country. Ireland and Malta still work this way, and the UK did until April 2025. The compliance burden is tracking which funds cross the border and keeping offshore money separated from local spending.
A flat-tax or lump-sum regime charges a fixed annual amount that replaces normal taxation on foreign income, no matter how much is actually earned abroad. Italy, Greece, and Switzerland each run versions of this. The appeal is predictability; the drawback is that the upfront number can be substantial.
A territorial system taxes only income sourced within the country’s own borders, regardless of who is resident. Singapore, Hong Kong, and the UAE work this way, and the benefit is available to everyone, not just those claiming a special status.
Cyprus blends elements of the first two: it exempts certain categories of foreign income from the Special Defence Contribution even when the income is remitted, which goes further than a standard remittance system.
Remittance-Basis Countries
Ireland
Ireland is now the most significant country still running a traditional remittance basis. Under Section 71 of the Taxes Consolidation Act 1997, an individual who is tax resident in Ireland but not domiciled there pays Irish tax on foreign income only to the extent it is actually remitted to the state.1Irish Statute Book. Taxes Consolidation Act 1997 Section 71 Foreign income kept in offshore accounts or spent outside Ireland is not subject to Irish tax.
Money transferred to an Irish bank account, used to pay an Irish mortgage, or applied to any expense inside the state becomes taxable at ordinary rates. Irish-source income is always taxed normally. Non-domiciled individuals report their foreign income through Panel F of the annual Form 11, with a filing deadline of 31 October following the tax year. Ireland has not announced any plans to follow the UK in abolishing its remittance basis.
Malta
Malta taxes non-domiciled residents on income arising in Malta and on foreign income remitted to Malta. Foreign capital gains are outside the charge even if the proceeds are transferred in, which makes Malta particularly attractive for individuals holding investment portfolios that produce gains rather than yield.
A non-domiciled resident whose foreign income exceeds €35,000 in a year and who does not remit the full amount to Malta faces a minimum annual tax of €5,000. Any Maltese tax already paid through withholding counts toward that minimum. Spending more than 183 days per year in Malta automatically satisfies the residency test, and a regular pattern of shorter presence can also qualify.
Cyprus
Cyprus introduced its non-dom regime in July 2015. A non-domiciled tax resident is exempt from the Special Defence Contribution (SDC) on dividends, interest, and rental income. The SDC rates that would otherwise apply are 17% on dividends, 30% on interest, and 3% on 75% of gross rental income, so the exemption is meaningful. It applies whether or not the income is brought into Cyprus.
A person qualifies as non-domiciled if they were not a Cyprus tax resident for at least 20 consecutive years before the regime took effect, or if they have a domicile of origin outside Cyprus and have not been resident there for 17 or more consecutive years. Cyprus also offers a 60-day residency route: 60 days of presence in a tax year is enough to become tax resident if the individual maintains a permanent home in Cyprus, is employed or runs a business there, spends no more than 183 days in any other single country, and is not tax resident elsewhere.
Flat-Tax and Lump-Sum Countries
Italy
Italy’s flat-tax program under Article 24-bis of the Italian Tax Code lets a new resident substitute a single annual payment for standard progressive taxation on all foreign-sourced income. The charge has risen sharply. It was €100,000 at the program’s launch in 2017, rose to €200,000 in August 2024, and increases again to €300,000 from 1 January 2026 under the 2026 Budget Law (Law 199/2025).2Ministry of Enterprises and Made in Italy. Special Tax Regime for New Residents Family members can be added for €50,000 each. The regime runs up to 15 years, and Italian-source income remains subject to ordinary rules.
To qualify, an applicant must not have been an Italian tax resident for at least nine of the ten tax years before the move. The flat tax covers income tax, but Italian inheritance tax still applies to the worldwide assets of Italian tax residents.
Greece
Greece offers a flat tax of €100,000 per year for individuals who transfer their tax residence to the country, covering all foreign-sourced income regardless of the amount. Family members can be added for €20,000 each per year. The regime lasts up to 15 years, one of the longest in Europe.
The applicant must not have been a Greek tax resident for seven of the eight years before relocating, and must invest at least €500,000 in Greek real estate, businesses, or securities within three years of applying. Missing the full lump-sum payment in any year terminates the regime permanently, and the individual reverts to standard worldwide taxation.
Switzerland
Switzerland’s expenditure-based taxation, known locally as the forfait fiscal, calculates tax on the basis of the individual’s total annual living expenses in Switzerland and abroad rather than on actual income. It is available to foreign nationals establishing Swiss tax residence for the first time, or after at least ten years abroad, who do not work in Switzerland. Acquiring Swiss citizenship or taking up employment ends eligibility immediately.3Swiss Federal Department of Finance. Lump-Sum Taxation
Implementation varies by canton. Zurich, Schaffhausen, and Basel have abolished expenditure-based taxation through popular votes, while others including Lucerne and Bern kept it under stricter conditions. The assessed amount cannot fall below the tax that would be owed on specified Swiss-source income at regular rates, which puts a floor under the arrangement. Amounts typically run into six figures per year.
Territorial Systems
Singapore
Singapore does not use a domicile concept, but its territorial approach produces a comparable outcome for foreign income. The Inland Revenue Authority of Singapore states that overseas income received in Singapore by individual residents is generally not taxable and does not need to be declared.4Inland Revenue Authority of Singapore. Income Received From Overseas Exceptions apply where foreign employment is incidental to a Singapore-based role, where a Singapore business has overseas operations that are incidental to the local trade, or where the individual works overseas on behalf of the Singapore government.
Hong Kong
Hong Kong applies a strict territorial source principle: only profits arising in or derived from Hong Kong are subject to Profits Tax.5Inland Revenue Department. A Simple Guide on the Territorial Source Principle of Taxation There is no capital gains tax and no tax on dividends. Salaries tax applies only to income arising in or derived from employment in Hong Kong, or from services rendered in the territory. Work performed entirely outside Hong Kong is not taxable there even if the employer is based in the city. Everyone benefits equally; there is no special status to claim and no annual charge.
United Arab Emirates
The UAE charges no personal income tax at all. Salaries, investment returns, rental income, and capital gains earned by individuals sit outside the system. The 9% corporate tax introduced in 2023 applies to businesses above AED 1 million in turnover and does not touch wages, personal investment income, or real estate gains. From a compliance standpoint this is the simplest option on the list: nothing to file and no regime to claim.
Countries That Have Closed or Narrowed Their Regimes
United Kingdom
The UK’s non-dom remittance basis ended on 6 April 2025 and was replaced by the Foreign Income and Gains (FIG) regime under the Finance Act 2025. For decades, non-domiciled UK residents could avoid tax on foreign income and gains by keeping the money outside Britain, paying annual charges of £30,000 or £60,000 depending on how long they had lived in the country.6GOV.UK. Remittance Basis Changes That system is gone. All UK residents are now taxed on worldwide income unless they qualify for the new relief.
The FIG regime is only open to individuals in their first four tax years of UK residence who had at least ten consecutive years of non-UK residence immediately beforehand. During those four years, qualifying residents can claim full relief on foreign income and gains with no cap, and sheltered funds can be brought into the UK at any time without triggering a charge. Relief must be claimed each year through Self Assessment using form SA109, and unused years cannot be carried forward.7HM Revenue & Customs. HS266 Foreign Income and Gains (FIG) Regime After the fourth year, the resident owes tax on worldwide income. The UK is no longer a long-term non-dom haven.
Portugal
Portugal’s Non-Habitual Resident (NHR) program ran for nearly a decade, offering a flat 20% rate on certain Portuguese-source income and broad exemptions on foreign income for ten years. It has closed to new applicants. Portugal replaced it with the IFICI (Tax Incentive for Scientific Research and Innovation), a narrower regime aimed at qualified professionals in research, investment, and business development rather than wealthy retirees or remote workers. Anyone who benefited from NHR is excluded from IFICI. Existing NHR beneficiaries keep their status until their ten-year period expires, but Portugal is no longer a viable destination for general non-dom tax planning.
Thailand Is Moving the Other Way
Thailand used to operate a remittance-based system in which foreign income was only taxed if brought into the country in the same calendar year it was earned. Residents could sidestep Thai tax by waiting a year before transferring funds.
The Revenue Department closed that route through Departmental Instruction No. Paw. 161/2566, effective 1 January 2024. Foreign-sourced income remitted into Thailand by a tax resident is now subject to personal income tax regardless of when it was originally earned.8Deloitte. Updated Guidance Provided on Treatment of Foreign-Source Income of Individuals A follow-up instruction, Paw. 162/2566, grandfathered income earned before 1 January 2024 under the old rules. Anyone physically present in Thailand for 180 days or more in a calendar year qualifies as a tax resident, regardless of visa type. The combination has made Thailand considerably less attractive for foreign residents with offshore income.
US Citizens and Green Card Holders Cannot Use Any of These
The United States taxes its citizens and permanent residents on worldwide income regardless of where they live. The IRS is explicit that the filing and payment rules “are generally the same whether you are in the United States or abroad.”9Internal Revenue Service. US Citizens and Resident Aliens Abroad Claiming non-dom status in Ireland or moving to the UAE does not eliminate US tax obligations. Foreign tax credits and the Foreign Earned Income Exclusion can reduce the bill, but they do not make it disappear.
US persons with foreign financial accounts whose aggregate value exceeds $10,000 at any point during the year must file an FBAR (FinCEN Form 114) with the Financial Crimes Enforcement Network.10FinCEN. Report Foreign Bank and Financial Accounts Separately, FATCA requires filing Form 8938 with the IRS if foreign financial assets exceed set thresholds. For taxpayers living abroad, those thresholds are $200,000 on the last day of the year or $300,000 at any point during the year for individual filers, and $400,000 or $600,000 respectively for joint filers.11Internal Revenue Service. Do I Need to File Form 8938, Statement of Specified Foreign Financial Assets The IRS has information-sharing agreements with tax authorities in most of the countries on this list.
Watch Inheritance Tax Separately
The income tax break often does not extend to death. The UK’s April 2025 reforms are the clearest illustration: once an individual has been UK resident for ten out of the previous twenty tax years, they become a “long-term resident” and their worldwide assets fall within UK inheritance tax at 40%. Leaving the country does not immediately fix the problem, because an inheritance tax “tail” follows the individual for three to ten years after departure, depending on how long they lived in the UK.12GOV.UK. Reforming the Taxation of Non-UK Domiciled Individuals
Italy applies inheritance tax to the worldwide assets of anyone who was an Italian tax resident at death, regardless of whether they were using the flat-tax regime for income tax. The flat tax covers income, not transfers at death. Cyprus and Malta have no inheritance tax, which is one reason they attract retirees focused on estate planning. Singapore and Hong Kong also have no estate or inheritance tax. Any long-term plan built around non-dom status needs to map the inheritance rules independently, because the two regimes often use different timelines and different definitions of who counts as local.