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Guidance for UK Non-Doms Considering a Move Abroad

Essential Insights for UK Non-Doms Planning International Relocation

Until 2025, the UK has been an attractive destination for non-UK domiciled individuals (non-doms) due to its favourable remittance basis tax regime. This regime allowed non-doms to only pay UK tax on their UK income and on foreign income and gains that were remitted to the UK, making it an appealing option for many. However, the landscape is shifting.

 

Essential Insights for UK Non-Doms Planning International Relocation

Guidance for UK Non-Doms Considering a Move Abroad

Until 2025, the UK has been an attractive destination for non-UK domiciled individuals (non-doms) due to its favourable remittance basis tax regime. This regime allowed non-doms to only pay UK tax on their UK income and on foreign income and gains that were remitted to the UK, making it an appealing option for many. However, the landscape is shifting.

 

Where We Are Now

On 30th October 2024, Chancellor of the Exchequer, Rachel Reeves, delivered the Autumn Budget which announced several changes that impact the advantages previously enjoyed by non-doms. From 6th April 2025, the existing non-dom regime ended and the concept of domicile as a relevant connecting factor in the current tax system was replaced by a system based on tax residence.

However, since the changes were announced, the Chancellor went on to prepare an amendment to the Finance Bill after a mass exodus of millionaires from the UK. The review will make it easier for non-doms to bring money to the UK, without paying heavy taxes. These changes will be made to the Temporary Repatriation Facility, a 3-year scheme to help ex non-doms bring their assets to the UK at a discounted tax rate. There are also plans to ensure that any tax changes do not affect countries with double taxation agreements with the UK, designed to stop HNWIs from paying tax in both countries at the same time.

An Overview of the Changes

The 4-year foreign income and gains regime will come into effect for anyone who has not been resident in the UK in the previous 10 tax years. The transitional provision reducing foreign income by 50% will not be introduced.

Transitional provisions reducing the tax rates on previously unremitted income and gains will be introduced. Details on which can be found here.

There will be a reform of the inheritance tax regime with changes to be made from the 6th April 2025 to include:

  • A 10-year residence test, after which global assets will be subject to UK inheritance tax;
  • Excluded property trusts within the UK IHT net, so that everyone who is in scope of UK IHT will have their assets subject to UK IHT.

The freeze on inheritance tax thresholds will be extended for a further two years, until 2030. This means that the first £325,000 of any estate can be inherited tax-free, rising to £500,000 if the estate includes a residence that has been passed to direct descendants, and £1 million when a tax-free allowance is passed to a surviving spouse or civil partner.

Exploring Residency Abroad

At Dixcart, we excel in simplifying the complexities and challenges of relocating to a new country. Our cohesive network of offices around the world ensures a seamless experience, providing you with comprehensive support every step of the way. From your initial decision to move from your current home, through to settling into your new home, Dixcart’s expert team collaborates across our multiple jurisdictions to offer you a unified and smooth transition.

Each Dixcart office location provides unique benefits tailored to your needs. Below, you will find a summary of these advantages. Click on the country below to discover the specific services and support we offer, ensuring your move is as effortless and efficient as possible.

To learn more on what to consider when exit planning in the UK, read our articleCeasing to be UK Tax Resident – Don’t Get it Wrong!

 

Cyprus

There are two routes to tax residency in Cyprus. The 183-day rule and the 60-day rule.

The 183-day rule is the simplest of the two. And has only one requirement; you must legally reside in the republic of Cyprus for 183 days in a tax year. After which you are considered a tax resident.

To be considered a tax resident after 60 days you are required to:

  • Legally reside in Cyprus for at least 60 days
  • Operate/run a business in Cyprus and/or are employed in Cyprus and/or are a director of a company which is tax resident in Cyprus
  • Have a residential property in Cyprus which they own or rent
  • Are not tax resident in any other country
  • Do not reside in any other single country for a period exceeding 183 days in aggregate

 

Cyprus tax residents are taxed on their worldwide income.

A special taxation regime is available for Non-Domicile individuals. This Non-Domicile regime is available for 17 years from the first tax year you become tax resident.

Individuals who qualify under the Non-Domicile regime are exempt from taxation from the following sources of income:

  • Interest
  • Dividends
  • Capital gains (apart from Immovable Property in Cyprus – subject to a partial exemption on newly acquired property)
  • Capital sums received from pension, provident and insurance funds.

The above are subject to 2.65% contribution to the General Healthcare System (GHS). The contributions to GHS are capped at €180,000 of total annual income – e.g. a max annual contribution of €4,770.

Non-Doms are also entitled to an income tax exemption equal to 50% on their salary provided their job is their first form of employment in Cyprus and they earn over €55,000 a year.

 

Yes, a tax residency certificate is attainable and can be issued after the specific requested amount of days spent in Cyprus. Days in and out of Cyprus must be justified by airway tickets and proof of local spending.

The certificate usually can be issued in 5-10 working days after the application is filed. Provided that all the required documentation is in order.

 

Yes, there is a sliding scale for regular income ranging from 20% to 35%, with the first €19,500 of income being tax-free. However as mentioned earlier it is often the case that your income will fall within one of the exempt income categories under the Non-Domicile regime.

 

As a Non-Domicile you will not be taxed on capital gains unless they are on gains arising from the sale of a Cyprus property. This is taxed at the rate of 20%, and is imposed on gains arising from the disposal of immovable property situated in Cyprus, or the disposal of shares in companies that directly own Cyprus-situated immovable property.

 

There is no inheritance tax, wealth tax or gift tax in Cyprus.

 

 

 

 

 

Non-EU citizens must seek the approval of the Council of Ministers before they can own any type of immovable property. Furthermore, unless there are exceptional circumstances, their ownership will be limited to:

  • An apartment
  • A house
  • A building plot or land up to approximately 4,014 sq.m.

It is unusual for the Council of Ministers to refuse permission to bona fide foreign nationals.

EU Citizens, including those of the European Economic Area (EEA), have the same property ownership rights as Cypriot citizens. They can freely buy and own property in Cyprus without the above restrictions.

 

 

 

Cyprus is located in the east of the Mediterranean Sea and as a result enjoys all the benefits of the 320+ sunny days a year that comes with its global location as well as being perfectly situated for international travel. We sit at the crossroads of three continents and have 2 international airports with daily flights to Europe, the Middle East, Africa and Asia. With Hubs such as Dubai, Doha and Abu Dhabi only 4 hours away.

Recently the local government has invested in developing its National Healthcare System and as a result healthcare in Cyprus is of a very high standard. It is recognised by the World Health Organisation as being of the same level as developed countries such as the UK and Canada.

Cyprus has great options for education. There is a large population of expats that make up roughly 22% of the total population and as a result there are a number of private international schools that teach in English. In addition to the state run schools that teach in Greek.

Cyprus is the 3rd largest of the Mediterranean islands at over 9,000 km², and the 3rd most populated with a population of over 1.2 million. Nicosia is the centrally located capital, but Limassol is the growing financial hub that has been referred to as “little Dubai” with is modern tower blocks overlooking the crystal waters of the bay. In addition to its cities Cyprus boasts some beautiful wild areas with 10 national parks, including the stunning Trodos mountains.

Because of this wide variety of urban and rural areas Cyprus has fantastic options when deciding where you want to live. Whether it be a modern sea view apartment, a house with a pool in a gated community or a beautiful cottage in a village, Cyprus has every option under the sun and more.

 

Guernsey

An individual will be treated as “resident” if they are in Guernsey for 91 days or more in a calendar year, or if they are in the island for 35 days or more and they have been in Guernsey for at least 365 days in the previous 4 years.

They will be treated as “solely resident” so long as they are resident as shown above and they are not resident anywhere else in that year (and for this purpose they will be treated as being resident somewhere else if they spend 91 days or more in that place).

Finally they will be treated as “principally resident” if they are:

  • In Guernsey for 182 days or more
  • In Guernsey for 91 days or more and have been in the island for 730 days in the previous 4 years

Additionally they will also be treated a “principally resident” if they move to the island to take up permanent residence and they are resident in Guernsey (as shown above) and they are solely or principally resident (as shown above) in the year after they arrive and they were not resident in Guernsey in the year before they arrive to take up permanent residence in the island.

 

If you are resident, but not solely or principally resident, in Guernsey, you will pay tax on your total income, wherever that income may come from, unless you elect to pay the standard charge (or if you are in Guernsey just for work *). If you don’t elect to pay the standard charge, you will be entitled to a proportion of the personal allowances based on the number of days you spend in the island.

*If the sole or main purpose for you being in Guernsey is to work and (other than bank interest) all your income is from this employment, you will only have to pay tax on your Guernsey income and any other income brought into the island. You will get a proportion of the personal allowance based on the number of weeks you are in Guernsey.

If you elect to pay the standard charge (£40,000 from 2021, previously £30,000) you won’t have to pay further tax on your non-Guernsey source income, but you will need to pay tax on your Guernsey income (other than bank deposit interest). The standard charge paid can be set-off against the tax due on your Guernsey income, as shown in the examples below. If you elect to pay the standard charge you will not be due any allowances, reliefs or deductions.

 

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Good standard of education and health services.

Connectivity through UK.

 

Isle of Man

 

There is no remittance basis of taxation in the Isle of Man. Individuals are taxed on their worldwide income. However, the primary direct taxes for new residents are income tax and national insurance. There are no capital taxes, meaning chargeable gains can be realised without Isle of Man tax, and there are no gift or inheritance taxes.

Individuals who are resident in the Isle of Man for income tax purposes are able to cap their income tax liability at £220,000 per year (£440,00 for a jointly assessed couple) for five (or ten) consecutive years if their income is substantial, which effectively lowers the overall tax rate. This tax cap election needs to be made before the beginning of the first applicable tax year.

The Tax Cap amount is due and payable on 6 January in each tax year for which an election applies. Alternatively, for those who are looking for flexibility without a five or ten year cap election, the standard and higher personal tax rates are some of the lowest in Europe.

 

 

 

 

 

 

 

 

 

 

Infrastructure and Services
The Isle of Man offers individuals and businesses a range of attractive features, including:

Public Services and Infrastructure

  • Regular travel links to 11 destinations, including Birmingham, Bristol, Dublin, Edinburgh, London, Liverpool, and Manchester.
  • A wide range of well-funded public services available on Island, including healthcare and public transport.
  • A comprehensive range of private healthcare services are available on Isle of Man.
  • The Isle of Man has a well-regarded education system with a large number pre-schools, 32 state run primary schools and 5 secondary schools. In addition, the island has a private primary and secondary school provider. The curriculum content is largely drawn from the English national curriculum. There are also options for higher education on the Island at the University College Isle of Man and support available for university study off-island.

Professional Services

  • All big 4 UK banks have a presence on the Island, including Barclays,  HSBC, Lloyds and NatWest Group.
  • All big 4 accounting firms have a presence on the Island and a wide range of independent Tax Advisers on hand.
  • A large number of legal services providers, offering Isle of Man Advocates that are often dual Isle of Man / UK qualified.
  • Over 70 licensed and regulated Trust & Corporate Service Providers.
  • A selection of local telecoms providers, IT services and data centres.
  • Investment Managers, Pension Administrators, Insurance companies and more.

Culture and Quality of Life

  • The Isle of Man is an outward looking and progressive society with a multicultural population of approximately 85k and a rich and unique cultural heritage.
  • The 572 km2 Island can boast of being the world’s only ‘Entire Nation’ UNESCO Biosphere, owing to its culture, natural environment and approach to conservation.
  • Safety and quality of life are at the centre of the Isle of Man proposition.
  • The Isle of Man offers plenty of open space and diversity of landscape, with windswept uplands, lush managed woodlands and sandy beaches.
  • Home of the world-famous TT Races, taking place on a approx. 37-mile circuit over public roads. The fastest average speed of over the course is 135.452mph and reaches top speeds of over 200mph. It is a time when the whole island comes to life and is a must see for motorsports fans.

 

Malta

 

Malta offers remittance basis of taxation to all Residents that are not deemed to be domiciled in Malta.
a. Income NOT remitted to Malta is not taxed,
b. Capital Remitted or NOT remitted to Malta is not taxed
c. Income remitted to Malta is taxed

Rates vary depending if the individual is Ordinarily Resident in Malta (sliding scale 0%-35%) or not (sliding scale ramping up to 35% quickly)

 

 

 

 

 

 

 

Malta has 6 Residence Routes for third-country nationals
The top 3 routes:
– Malta Permanent Residence,
– The Global Residence Programme, and
– The Retirement Programme

Dixcart Management Malta Limited Licence Number: AKM-DIXC

 

Citizenship by Naturalisation for Exceptional Services by Direct Investment is the most popular route to obtaining Maltese Citizenship. Naturalisation by residing in Malta is usually only granted after 20 years on the island. Please contact advice.malta@dixcart.com for more information.

Dixcart Management Malta Limited Licence Number: AKM-DIXC

 

 

 

 

  1. English is an official language
  2. There are several types of schools (Church, Public and Private)
  3. Malta has one of the oldest universities in the world – founded in 1592.
  4. Malta has an excellent health care system – Statista.com rated Malta #19 worldwide.
  5. Malta hosts a big international community, with a mix of different nationalities and cultures.
  6. Ease of travel:
    • Malta has a National Carrier (KM Malta Airlines) that flies directly to several destinations
    • Turkish Airlines, Emirates, British Airways, EasyJet, RyanAir, Lufthansa and several others fly in most cases daily flights to and from Malta

 

Portugal

 

The Non-Habitual Resident (NHR) programme is a source-based tax regime (rather than remittance based). Despite various changes, following the budget released in December 2024, individuals may register under the revised programme (IFICI (Incentive for Scientific Research and Innovation), or informally known as NHR 2.0), for individuals who became tax resident on or after 1 January 2024.

The key benefits, available for 10 calendar years from the time of tax residency in Portugal, is summarised as follows:

  • 20% flat tax rate on qualifying Portuguese income.
  • Exclusion from tax for foreign-sourced business profits, employment, royalties, dividends, interest, rents, and capital gains.
  • Only foreign pensions and income from blacklisted jurisdictions remain taxable

Please refer to the following link for more details.

 

 

 

 

 

 

 

Various visa options exist in Portugal to cater for every personal need. Below provides a comparative summary of the more popular routes:

  • Golden Visa
  • D2 Visa
  • D7 Visa
  • Digital Nomad Visa

Read here for more information.

 

Portugal offers several paths to citizenship, including:

  • Residency: Living legally in Portugal for at least 5 years can qualify you for citizenship.
  • Descent: If you have at least 1 Portuguese grandparent or are a descent of Sephardic Jews.
  • Other routes: Marriage to a Portuguese citizen (usually 3 years) or investment through the Golden Visa programme can also be paths to citizenship.

 

 

 

 

Portugal offers a wealth of lifestyle benefits that complement its tax advantages:

  • Cost of Living: Compared to many Western European countries, Portugal offers a lower cost of living, allowing you to stretch your budget further.
  • Climate: The country enjoys a warm Mediterranean climate, perfect for outdoor enthusiasts and those seeking sunshine year-round.
  • Safety: Portugal is renowned for its safety, boasting low crime rates and a peaceful atmosphere.
  • Rich Culture and History: Steeped in history and vibrant culture, Portugal offers a unique blend of tradition and modernity.
  • Proximity to Europe: Portugal’s location allows for easy travel to other European destinations. Additionally, the country has a well-developed internal transportation network of buses and trains, making it easy to get around. International travel is also facilitated by several airports with connections to many global destinations.
  • Education: Portugal has a public education system with private schools also available (including various international schools, including English, German and French).
  • Healthcare: Portugal offers both public and private healthcare options. Public healthcare is generally good, however, private healthcare is also widely available.

 

Switzerland

 

The lump sum taxation ruling agreed with the cantonal tax authority. Instead of paying taxes on actual inc and assets, the basis of taxation is calculated according to the living expense. Negotiated with the tax authority.

  • Non Swiss national first time in the country or after an absence of 10 years
  • Non gainful activity in Sw. (but member of BOD accepted and managing his/her own investment portfolio are both accepted). Gainful activity outside of Sw. accepted.
  • Ad eternam as long as the conditions are fulfilled.
  • Each canton has a min. threshold of basis of taxation. To be checked.

 

 

 

 

 

 

 

Two routes:

– Working: the Swiss residence permit is linked to a work permit. The work permit is requested by the employer to the Swiss administration for the employee. The employer has to demonstrate the need for the “non Swiss resident employee” to be hired. If the employee is an EU/EFTA/Schengen it is easy. If the employee is not, the employer has to demonstrate that they were not able to find an employee based in Schengen with similar level of competence. Through the establishment of a Swiss Co or a Swiss branch it can provide an opportunity to show that a specific potential employee has a greater knowledge and skill for the business and the Swiss entity can more “easily” justify the need to hire this specific employee. In appropriate circumstances Dixcart can provide a director of the Swiss Co/branch until the permit is granted.

– Not working: If a foreigner wants to move to Switzerland and not work, they must show they have sufficient funds to live in Switzerland and take out Swiss health and accident insurance. Non-EU/EFTA nationals who want to move to Switzerland, but not to work, are divided into two age categories. Depending on which category the individual falls into (over 55 or under 55), certain criteria must be met.