Rules
Non-dom regimes in Europe in 2026: after the UK abolished non-dom, what Cyprus, Malta, Greece and Portugal offer
The United Kingdom abolished the remittance basis on 6 April 2025 and replaced it with a four-year relief for new arrivals; domicile no longer matters for UK income tax. Four European countries this site reads at source still tax a newcomer differently from a native. Cyprus exempts a resident without Cypriot domicile from its defence contribution on dividends and interest, for up to seventeen years. Malta taxes a non-domiciled resident on foreign income only when it is brought into Malta. Greece offers a flat €100,000 a year on all foreign income for fifteen years against a €500,000 investment. Portugal replaced its old regime with IFICI, which taxes qualifying work, not wealth.
Checked against CyprusMaltaGreecePortugal
Jurisdictions cy · mt · gr · pt
Contents
- What the UK did to non-dom status in April 2025
- Cyprus non-dom: no defence contribution on dividends and interest for up to 17 years
- Malta non-dom: the remittance basis, with a €5,000 minimum
- Greece non-dom: a flat €100,000 a year on all foreign income
- Portugal after NHR: IFICI taxes qualifying work, not wealth
- Non-dom regimes in Europe compared
- Low tax countries in Europe: which of the four suits whom
- Frequently asked questions
- Where this sits in the rest of the site
- If tax is why you are moving
- Sources: where each figure comes from
"Non-dom" used to mean one thing: the British remittance basis, under which a UK resident whose permanent home was elsewhere paid tax on foreign income only when he brought it into the country. That regime ended on 6 April 2025. People who used it, and people who wanted to, now search for where something like it survives.
Four of the countries this site reads at source have an answer, and each is built differently. This page sets them side by side with the instrument for each: the UK's own guidance on what replaced non-dom; Cyprus's Special Contribution for the Defence of the Republic Law; Malta's tax administration on the remittance basis; article 5A of Greece's Income Tax Code; and Portugal's IFICI regime. All were read between September and 26 October 2026.
What the UK did to non-dom status in April 2025
HMRC's helpsheet HS266, updated 18 May 2026, puts it in one sentence: "From 6 April 2025, the remittance basis of taxation has been abolished." Every UK resident is now taxed on worldwide income and gains as they arise, and domicile is no longer a connecting factor for UK tax; residence is.
What replaced it is the four-year foreign income and gains regime. A person in one of his first four years of UK residence, after at least ten consecutive tax years of non-residence, can claim that qualifying foreign income and gains are not taxed, and can bring them into the UK without a charge. The claim has a price: in any year it is made, the personal allowance and the capital gains annual exemption are lost.
So the UK still offers something to a new arrival, for four years. It no longer offers anything to someone who has lived there long enough to call it home.
Cyprus non-dom: no defence contribution on dividends and interest for up to 17 years
Cyprus taxes residents on income under its Income Tax Law and separately charges a special defence contribution on dividends and interest. Article 2 of the Special Contribution for the Defence of the Republic Law, Law 117(I)/2002, defines a "resident" for that contribution as a Cyprus tax resident who is also domiciled in Cyprus. A tax resident without Cypriot domicile is outside it, and pays no defence contribution on dividends or interest.
The status is not permanent. A person resident in Cyprus for seventeen of the last twenty years is treated as domiciled, and remains so until he has been non-resident for twenty years.
From 2026, Law 245(I)/2025 added article 3D for those who have crossed that line: a person treated as domiciled can elect a fixed defence contribution of €50,000 a year for five years, paid in one sum of €250,000.
Becoming resident in the first place is a separate test under the Income Tax Law: more than 183 days in Cyprus, or the 60-day rule, which also requires a home in Cyprus and a business, employment or office there. How that applies to a retiree is in retiring in Cyprus.
Malta non-dom: the remittance basis, with a €5,000 minimum
Malta is the closest thing left in Europe to the old British regime. The Malta Tax and Customs Administration states the rule plainly: those ordinarily resident and domiciled in Malta are taxed on a worldwide basis, "whilst those who are either not domiciled or not ordinarily resident in Malta are only taxable on a remittance basis".
Under the remittance basis, foreign income is taxed only when it is brought into Malta, and foreign capital gains are not taxed even when they are. Where the remittance basis applies, there is a minimum tax of €5,000 a year once unremitted foreign income reaches €35,000.
Two things narrow it. The status comes from not being domiciled in Malta, not from any permit, so no residence programme grants it and none takes it away. And it is not the same as Malta's special tax programmes — the Global Residence Programme and the retirement programme, which charge 15% on remitted income with a minimum tax and are being replaced on 1 January 2027 by rules with a €35,000 minimum for non-EU global residents. Those are in retiring in Malta and the Malta residence guide. A British resident of Malta should also read article 23 of the UK–Malta treaty before relying on income left abroad, set out in living in Malta from the UK. The Maltese scale, the non-resident rates and the tax on selling property are in Malta tax for individuals.
Greece non-dom: a flat €100,000 a year on all foreign income
Greece's version is a lump sum, not a basis of taxation. Article 5A of the Income Tax Code, Law 4172/2013, lets a person who moves his tax residence to Greece pay €100,000 a year in tax on all income arising abroad, "regardless of the amount", on two conditions:
- he was not a Greek tax resident for seven of the previous eight years; and
- he, a relative or a company he controls invests at least €500,000 in Greek property, businesses, securities or shares in Greek companies, completed within three years of the application.
The investment condition does not apply to someone who holds a Greek investor residence permit — the golden visa. Relatives can be added for €20,000 a year each. The tax is paid in one instalment by the last working day of December, foreign tax already paid on the same income is not credited, and the regime lasts fifteen tax years and cannot be extended. Income arising in Greece is taxed under the general rules, and missing a year's payment ends the regime.
The regime makes sense only where ordinary Greek tax on the same foreign income would exceed €100,000 a year; below that point, ordinary residence costs less, and the fifteen years of payments are owed whatever the income turns out to be. The other two Greek regimes — 7% on foreign pensions and the 50% relief for people who move to work for a Greek employer — are in retiring in Greece and the Greece digital nomad visa.
Portugal after NHR: IFICI taxes qualifying work, not wealth
Portugal's old non-habitual resident regime is closed to new entrants. Its replacement, IFICI, is in article 58-A of the Tax Benefits Statute, introduced by Lei 82/2023, with the procedure in Portaria 352/2024/1 of 23 December 2024. It charges 20% on Portuguese employment and business income from qualifying activities, for ten years, with registration by 15 January of the year after residence begins. Pensions are excluded, as is income from blacklisted jurisdictions, which is taxed at 35%.
IFICI is a regime for people who come to Portugal to do qualifying work. It is not a remittance basis and not a lump sum, and a person living on investments or a pension gets nothing from it.
Non-dom regimes in Europe compared
| Country | What a newcomer gets | Who qualifies | How long |
|---|---|---|---|
| United Kingdom | Foreign income and gains relieved, at the cost of the personal allowance | First four years of residence after ten years away | Four years |
| Cyprus | No defence contribution on dividends and interest | Tax resident, not domiciled in Cyprus | Until 17 of 20 years' residence; then €50,000 a year for five years by election |
| Malta | Foreign income taxed only when remitted; foreign gains untaxed | Resident, not domiciled or not ordinarily resident | While the status lasts; €5,000 minimum above €35,000 unremitted |
| Greece | €100,000 a year flat on all foreign income | Not resident 7 of 8 years; €500,000 invested or a golden visa | Fifteen years |
| Portugal | 20% on qualifying work income | People taking up qualifying activities | Ten years |
Low tax countries in Europe: which of the four suits whom
- Living on dividends and interest: Cyprus, where a non-domiciled resident pays no defence contribution on either.
- Large foreign income or gains, left mostly abroad: Malta's remittance basis, with foreign capital gains untaxed even when brought in.
- Very large foreign income, and a wish for certainty: Greece's €100,000 a year, which does not rise with the income.
- Moving to work in a qualifying role: Portugal's IFICI.
None of these is automatic with a residence permit, and all of them depend on first becoming tax resident under that country's own day-count rules.
Frequently asked questions
Is the UK non-dom regime abolished?
Yes. HMRC states that from 6 April 2025 the remittance basis was abolished and domicile is no longer a connecting factor for UK tax. New arrivals after ten years away can claim a four-year relief on foreign income and gains instead.
Which European countries still have a non-dom regime?
Of those this site reads at source: Cyprus, where a resident without Cypriot domicile pays no defence contribution on dividends and interest, and Malta, which taxes a non-domiciled resident on foreign income only when remitted. Greece offers a €100,000 flat tax on foreign income instead.
How long does Cyprus non-dom status last?
Until the person has been resident in Cyprus for seventeen of the last twenty years, when he is treated as domiciled. From 2026 he can then elect a fixed defence contribution of €50,000 a year for five years.
What is the Greek non-dom €100,000 tax?
Article 5A of Law 4172/2013: a flat €100,000 a year on all foreign income, regardless of the amount, for fifteen years, for a person not Greek-resident in seven of the previous eight years who invests €500,000 in Greece or holds a golden visa. Relatives can be added for €20,000 each.
Does Malta tax foreign capital gains of non-doms?
No. Under the remittance basis, foreign capital gains are not taxed in Malta even when they are brought in. Foreign income is taxed when remitted, with a minimum tax of €5,000 once unremitted foreign income reaches €35,000.
Did Portugal replace NHR?
With IFICI, under article 58-A of the Tax Benefits Statute: 20% on Portuguese employment and business income from qualifying activities for ten years. Pensions are excluded.
Does a residence permit make me non-dom?
No. Residence permits decide where you may live; tax residence is decided by days and ties under each country's tax law, and non-dom status by domicile. The three are separate tests.
Where this sits in the rest of the site
The Maltese routes and the remittance basis in context are in the Malta residence guide. The Greek income regimes for retirees and remote workers are in retiring in Greece and the Greece digital nomad visa. Retirement visas, with how each country taxes a foreign pension, are compared in countries with a retirement visa. Every figure here is traced on the sources page.
If tax is why you are moving
We do not give tax advice. What we do is put a person who knows what they are asking in front of a licensed adviser in the country they are considering. The questions that decide this are rarely the headline rate. They are whether you will actually become tax resident there, whether your home country agrees that you have left, and what a treaty between the two does with the income you keep abroad. Send them through the enquiry form. We take no part in the fee.
Sources: where each figure comes from
- United Kingdom: HMRC, HS266 Foreign income and gains (FIG) regime (2026), updated 18 May 2026, read 26 October 2026.
- Cyprus: Law 117(I)/2002, article 2, and Law 245(I)/2025, article 3D; Law 118(I)/2002, article 2; as recorded in our Cyprus verification file of 22 October 2026 and read again on 25 October 2026.
- Malta: Malta Tax and Customs Administration, tax residence and remittance guidance; as recorded on our Malta residence page, September 2026.
- Greece: Law 4172/2013, article 5A, consolidated to Law 5327/2026, read 26 October 2026.
- Portugal: Estatuto dos Benefícios Fiscais, article 58-A, and Portaria 352/2024/1; as recorded on our sources page.
- Not published here: Italy's and Switzerland's flat-tax regimes, whose law we have not read; and how any particular treaty treats income left abroad.
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