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Non-Dom Regimes: Who Do They Still Suit?

The old "non-domNon-domEen fiscale status waarbij sommige inwoners alleen belasting betaalden over buitenlands inkomen dat ze naar het land overmaakten. De Britse regeling is vanaf april 2025 vervangen." pitch was simple: move abroad, keep your foreign income and gains mostly out of the local tax net, and pay a fixed or reduced charge instead. Several countries have since tightened, restructured or replaced those regimes. They haven't vanished, but they're much pickier about who they suit, and a comparison written a few years ago is probably out of date.

The UK: What changed, and who it suits

The UK no longer lets you keep non-dom status indefinitely. The old system (called the remittance basisRemittance basisBuitenlands inkomen wordt pas belast zodra u het naar het land overmaakt, niet op het moment dat u het verdient.) let you shelter foreign income and gains for as long as you stayed "non-domiciled", which is roughly the country you don't treat as your permanent home. It has been replaced by a regime based on residence. You get relief on foreign income and gains only for a limited number of years after becoming UK tax resident. After that, your worldwide income and gains come into the UK tax net, whatever your domicile.

That favours people planning a defined stay. If you're coming for a fixed multi-year assignment or business project, you can still get meaningful relief during that window. If you hoped to settle in the UK for good while keeping foreign wealth permanently shielded, that option is gone.

Inheritance tax has shifted too. It now leans on a residence-based test for what's in scope, rather than the domicile-based test. Under the old test, long-term UK residents with a non-UK domicile could keep foreign assets outside the UK erfbelastingErfbelasting (IHT)Belasting over wat u nalaat als u overlijdt. In het Verenigd Koninkrijk hangt die nu af van hoe lang u er woont, niet meer van uw domicilie. net far longer than the new rules generally allow.

Italy: still live, but pricier

Italy's flat tax for new residents still works, but it now costs new arrivals more. You pay one fixed yearly charge on your foreign-source income instead of ordinary progressive tax. That charge has gone up for new entrants compared with the original scheme. People who locked in the original terms years ago have the better deal.

It still works well if you have substantial foreign passive income or gains compared with what it costs you to live in Italy. Even the higher flat charge is then materially lower than ordinary Italian progressive rates on the same income.

It works less well if your foreign income is modest. The flat charge is fixed however much foreign income you actually have. With limited foreign income, ordinary taxation may be cheaper than opting in at all.

Waar zitten de grijze gebieden?

The article doesn't flag any one arrangement as risky or challengeable. These regimes don't suit everyone, though, and the points below are where a poor fit could cost you.

Greece and Cyprus: still generous, but narrower than their reputation

Greece and Cyprus have kept their reliefs closer to their original form. Neither has moved to a hard time limit on its core relief the way the UK has, which makes both more favourable than the post-reform UK regime for long-term movers. Both have their own conditions around genuine residence and prior non-residence, so check them against your own facts.

Greece has a flat annual tax on foreign income for a defined number of years, but eligibility depends on a minimum investment in Greece. So it's a package tied to putting capital into the country, with the tax relief as one part of it.

Cyprus exempts qualifying individuals from tax on dividends and interest for a defined period after they become Cyprus tax resident, and it has stayed largely intact. That makes it comparatively attractive if your income is mostly passive investment returns rather than a mix of employment and business income.

Who does the post-reform picture favour?

Different regimes now suit different people. Here's how the article lines them up.

Time-limited movers are better served by the UK's new set-up than they'd have been under the old one. The relief is explicitly built around a defined window, whereas the old system left you with a harder-to-predict exit from non-dom status.

Passive-income-heavy people do better with Italy's flat tax or Cyprus's exemption, because the benefit grows with the income being sheltered instead of stopping when a fixed relief period ends.

If you want a genuinely long-term base and have capital to deploy, Greece's mix of tax relief and investment-linked residence may still appeal. The catch: the required investment should fit your broader plans, so don't make it only to qualify for the tax treatment.

The comparison that actually matters now

Choosing a country by its general reputation for low tax no longer works, because the regimes have drifted too far apart in how they're built. Three questions do the job instead:

1. How long do you actually plan to stay?
2. What's your income mix between active sources (like a job or business) and passive ones (like dividends, interest and gains)?
3. Does the country's remaining relief match that profile, or was it designed around a type of mover the reforms have since left behind?

Answer those honestly and the shortlist usually shrinks fast.