Residency regimes for wealthy families compared: Malta, Italy, Portugal, Switzerland, UAE, Singapore, UK, Ireland and Cyprus

Figures are for tax year 2026. This Guide compares the special residence regimes that internationally mobile families most often weigh: Malta's remittance basis and Global Residence Programme, Italy's flat tax for new residents, Portugal's IFICI, Swiss expenditure-based taxation (federal tax only), the UAE residence rules, Singapore's treatment of overseas income, the UK's four-year foreign income and gains regime, Ireland's remittance basis and domicile levy, and Cyprus's non-dom rules. Every figure comes from the country's own official page, linked beside it. Where an allowed page does not print a figure, the cell says so. The UK tax year is 6 April 2026 to 5 April 2027; the other countries use the calendar year. Sources were read on 4 October 2026.

This Guide compares regimes. It does not replace the country Guides. For the detail, use mt-non-dom and moving-to-malta-tax-residence (Malta), uk-to-italy-flat-tax-relocation (Italy), uk-to-uae-relocation-tax and ae-income-tax (UAE), uk-non-dom (UK), ie-non-dom (Ireland) and cy-non-dom (Cyprus). Malta's residence programmes are set out in full in mt-residence-programmes-for-wealthy-families. What happens when the family leaves its current country is in exit-taxes-when-a-family-moves. Inheritance, gift and forced-heirship rules are in succession-and-forced-heirship-compared.

The comparison at a glance

Every amount in this table also sits in the country's own source table further down, with a verbatim quote. "Not printed on an allowed page" means the official pages this Guide may cite do not carry that figure.

Country	Regime	Who qualifies	Annual cost or rate	Duration	What is taxed / not taxed	Source
Malta	Remittance basis for non-domiciled residents, with a minimum tax	A person resident in Malta who is not ordinarily resident or not domiciled in Malta, other than a long-term resident, a holder of a permanent residence certificate or card, or a person whose spouse is ordinarily resident and domiciled in Malta. The minimum tax applies to an ordinarily resident non-dom who meets the article 56(27) foreign-income test of EUR 35,000; whether that test counts all foreign income derived or only the part not received in Malta is unsettled (see the Malta section)	Minimum tax EUR 5,000 a year (only where the EUR 35,000 test is met)	No end date in the law; lasts while the person is not ordinarily resident or not domiciled	Foreign income taxed only when received in Malta; foreign capital gains not taxed	Income Tax Act, Cap. 123
Malta	Global Residence Programme	Third-country nationals only (not Maltese, EEA or Swiss), not long-term residents, holding a qualifying owned or rented property as their main home; EU/EEA/Swiss nationals: Residence Programme, S.L. 123.160	15% on foreign income received in Malta, minimum EUR 15,000 a year; other income EUR 0.35 per euro	No fixed term; the status ends on the events in rule 6	Foreign income received in Malta at the flat rate; see the Malta section for gains	Global Residence Programme Rules, S.L. 123.148
Italy	Flat tax on foreign income, article 24-bis TUIR	A person who moves tax residence to Italy and was not Italian resident for at least nine of the ten tax periods before the option starts; needs a favourable ruling (interpello) first	EUR 300,000 a year; EUR 50,000 a year for each family member included (for moves from 1 January 2026)	Ends after 15 years at most; revocable	Foreign income covered by the flat amount; gains on qualifying shareholdings in the first five years taxed normally	TUIR art. 24-bis
Portugal	IFICI (incentive for scientific research and innovation)	A person who becomes Portuguese resident, was not resident in any of the previous five years, works in a listed qualifying activity, never had the non-habitual resident regime and never opted for the Regressar regime	20% on net employment and self-employment income from the qualifying activity; foreign income generally exempt, 35% if paid from a blacklisted territory	10 consecutive years from registration as resident	Only qualifying work income at the special rate; not a regime for passive wealth	EBF article 58.º-A
Switzerland	Taxation on expenditure (federal direct tax)	A person without Swiss citizenship, fully taxable in Switzerland for the first time or after a break of at least ten years, with no gainful activity in Switzerland; both spouses must qualify	Federal tax base at least CHF 435,000 (or a higher figure under the other limbs); cantonal amounts not printed on an allowed page	No end date in the federal law	Federal tax on living expenditure instead of income; cantonal tax out of scope	Federal Direct Tax Act, art. 14
UAE	No special regime; tax residence under Cabinet Decision No. 85 of 2022	A natural person who meets one of the residence tests (see the UAE section)	Corporate Tax reaches an individual only through business turnover above AED 1 million; a personal income tax rate is not printed on an allowed page	Year by year (each relevant 12 months)	Wages, personal investment income and real estate investment income are not subject to Corporate Tax	Cabinet Decision No. 85 of 2022
Singapore	Overseas income received in Singapore	Individuals	No charge; no rate printed for overseas income	No time limit on the page	Overseas income received in Singapore generally not taxable; five exceptions listed in the Singapore section	IRAS, income received from overseas
UK	Four-year foreign income and gains regime (replaced the remittance basis on 6 April 2025)	A UK resident in the first four tax years of UK residence after at least ten consecutive tax years of non-residence	No charge for the regime; old remittance-basis users can designate pre-6 April 2025 foreign income and gains at 12% in 2025 to 2026 and 2026 to 2027, and 15% in 2027 to 2028	At most four consecutive tax years	Claimed foreign income and gains relieved; foreign employment income excluded; allowances lost	HMRC, 4-year FIG regime
Ireland	Remittance basis for non-domiciled residents	An Irish resident who is not domiciled in Ireland	No charge; the domicile levy of EUR 200,000 applies to Irish-domiciled people who meet all its tests	No end date while not domiciled	Foreign income and foreign gains taxed when remitted; Irish source income taxed in full; pay for duties done in Ireland excluded	Revenue, domicile and the domicile levy
Cyprus	Non-dom exemption from Special Defence Contribution, and the optional lump sum from 2026	A Cyprus tax resident who is not domiciled in Cyprus; the lump sum is for people without a Cypriot domicile of origin who become deemed domiciled	No SDC on dividends or interest while non-domiciled; after deemed domicile, optional EUR 250,000 for each 5-year period (EUR 50,000 a year), up to two periods	Non-dom status until resident 17 of the last 20 years; lump sum up to two 5-year periods	SDC only; income tax is a separate question (see cy-non-dom)	Tax Department, tax residency and domicile

The method, step by step

1. Fix the family's current position first: where each member is tax resident and domiciled today, and what the old country charges on departure. Use exit-taxes-when-a-family-moves before choosing a destination.
2. Test each person, not the family, against each regime's entry conditions in the country sections below. Each regime has its own look-back: nine of ten years non-resident for Italy (TUIR art. 24-bis), five years for Portugal (EBF article 58.º-A), ten years for Switzerland (Federal Direct Tax Act, art. 14) and ten consecutive tax years for the UK (HMRC, 4-year FIG regime).
3. Map the family's income by type and by source country: work income, dividends, interest, rent, gains on shares, gains on property. A regime that relieves foreign investment income may still tax local work income in full, and Portugal's IFICI covers qualifying work income only (EBF article 58.º-A).
4. For each candidate regime, read the cost line in the country's source table and the duration. Where a regime has an annual minimum (Malta, Italy, Switzerland), a family with modest foreign income can pay more than under ordinary rules. Compare like with like; this Guide does not compute any family's total.
5. Check what the regime does NOT cover: inheritance and gift tax, wealth tax, property taxes and social security sit outside these income-tax regimes. Use succession-and-forced-heirship-compared.
6. Diary the conditions that end each regime (days spent elsewhere, property kept, payment made on time, years counted) and the filing or application deadline in the first year. Record the evidence for each year.

Malta

Malta has two routes for a wealthy family. Both are set out in more detail in mt-non-dom, moving-to-malta-tax-residence and mt-residence-programmes-for-wealthy-families.

Remittance basis. A person who is not ordinarily resident in Malta or not domiciled in Malta pays Malta tax on foreign income only on the amount received in Malta. Foreign capital gains of such a person are not taxed in Malta, even if brought in. Neither rule is available to everyone. From year of assessment 2019 they do "not apply to an individual who is a long-term resident, or who holds a permanent residence certificate or a permanent residence card, in respect of any income derived by such individual in the year of being granted long-term resident status or the right of permanent residence and in subsequent years". They also "shall not apply to an individual whose spouse is ordinarily resident and domiciled in Malta". The full test is in mt-non-dom. (Income Tax Act, Cap. 123, article 4(1), provisos (i) and (ii))

Minimum tax. From year of assessment 2019, article 56(27) applies to an individual who is ordinarily resident but not domiciled in Malta, to whom provisos (i) and (ii) of article 4(1) apply, who is not taxable under a scheme that already sets a minimum tax, AND who "derives income (including, in the case of a married couple whose income is chargeable to tax in terms of article 49 of the Act, the income derived by both spouses) amounting to not less than" the threshold in the table below, "arising outside Malta and referred to in proviso (i) to sub-article (1) of article 4 of the Act, but which is not received or not fully received in Malta". Such a person pays at least the minimum tax in the table each year. The text can be read two ways. Reading one: the threshold counts all foreign income derived, which may be partly received in Malta. Reading two: it counts only the foreign income not received in Malta. The official guidance that might settle this could not be read. Refer any person whose foreign income derived meets the threshold but whose unremitted part does not. If the person proves that tax on a full worldwide basis would be lower, the minimum tax is capped at that lower amount. (Income Tax Act, Cap. 123, article 56(27))

Item	Value	Note
Source	all figures below	https://legislation.mt/eli/cap/123/eng/pdf
Foreign-income threshold for the minimum tax, article 56(27) (at least; what it counts is unsettled, see above)	EUR 35,000	"amounting to not less than thirty five thousand euro (€35,000)"
Minimum tax per year	EUR 5,000	"not less than five thousand euro (€5,000) per annum (hereinafter "the minimum tax")"

Global Residence Programme (GRP). Open only to third-country nationals: a Maltese, EEA or Swiss national cannot apply, and nor can a long-term resident or anyone already under another Malta tax scheme listed in rule 4. The applicant applies through an authorised registered mandatary and must, among other conditions, hold a qualifying owned or rented property as the main home, have stable and regular resources, sickness insurance covering the EU, and be a fit and proper person (S.L. 123.148, rules 3 and 4).

EU, EEA and Swiss nationals (not Maltese nationals) cannot use the GRP but have a parallel scheme, the Residence Programme Rules, with the same flat rate on foreign income received in Malta and the annual minimum in the table below (Residence Programme Rules, S.L. 123.160, rules 4 and 5). See mt-residence-programmes-for-wealthy-families.

Item	Value	Note
Source	all figures below	https://legislation.mt/eli/sl/123.160/eng/pdf
Minimum tax per year of assessment, Residence Programme	EUR 15,000	"shall be fifteen thousand euro (€15,000) for any year of assessment"

Under GRP rule 5 (S.L. 123.148), foreign income received in Malta by the beneficiary, the spouse and the qualifying children is taxed at the flat rate in the table below, subject to the annual minimum. The minimum is payable in full both in the year the status is granted and in the year it ends, by 30 April of the year before the year of assessment, and it is not refundable. Other income of those persons is taxed at the higher rate in the table. The status ends if the person becomes a Maltese, EEA or Swiss national, stops holding (or lets out) the qualifying property, becomes a long-term resident, loses the sickness insurance, the stay is not in the public interest, or stays in any other jurisdiction for more than 183 days in a calendar year (S.L. 123.148, rule 6). The status also ends from the year of assessment in which the person breaches the Income Tax Acts, and the Ministers may condone a failure caused by unforeseen circumstances beyond the person's control (rule 6(4) and (5)).

Item	Value	Note
Source	all figures below	https://legislation.mt/eli/sl/123.148/eng/pdf
Rate on foreign income received in Malta	15%	"the rate of fifteen cents (0.15) on every 15% rate. euro shall apply on any income arising outside Malta"
Minimum tax per year of assessment	EUR 15,000	"shall be fifteen thousand euro (€15,000) for any year of assessment"
Rate on other income of the beneficiary and family	EUR 0.35 per euro	"charged as separate income at the rate of thirty-five cents (0.35) on every euro"
Qualifying owned property, Malta other than Gozo and the south of Malta (purchase price at least)	EUR 275,000	"two hundred and seventy-five thousand euro (€275,000) for a property situated in Malta"
Qualifying owned property, Gozo or the south of Malta (at least)	EUR 220,000	"two hundred and twenty thousand euro (€220,000) for a property situated in Gozo or in the south of Malta"
Qualifying rented property, Malta other than Gozo and the south of Malta (rent per year, at least)	EUR 9,600	"nine thousand and six hundred euro (€9,600) per annum for a property situated in Malta"
Qualifying rented property, Gozo or the south of Malta (rent per year, at least)	EUR 8,750	"eight thousand and seven hundred and fifty euro (€8,750) per annum for a property situated in Gozo"
Application fee, non-refundable	EUR 6,000	"non-refundable administrative fee of six thousand euro (€6,000) upon application"
Application fee where the property is owned and in the south of Malta	EUR 5,500	"five thousand and five hundred euro (€5,500) to be paid upon application"

Malta traps. The GRP is lost by a calendar year of more than 183 days in any other country, so a family that splits time across several homes must count the beneficiary's days in each other country. The minimum tax is due in full in the first and last year, however short. The GRP rules speak of foreign income received in Malta; foreign capital gains are free of Malta tax under article 4(1) proviso (ii) only if the person is not ordinarily resident or not domiciled in Malta; the GRP rules do not exempt gains themselves. Record residence and domicile evidence. Succession questions are not part of either regime; see succession-and-forced-heirship-compared.

Italy

Under article 24-bis of the TUIR, a person who moves tax residence to Italy may opt to pay a fixed substitute tax on foreign income instead of IRPEF on that income, if they were not Italian tax resident for at least nine of the ten tax periods before the option starts. The option is made only after a favourable answer to a ruling request (interpello) to the Agenzia delle Entrate, by the deadline for the tax return for the year of the move, and it then runs from that year. The person must name the country or countries of last tax residence (TUIR art. 24-bis, commi 1 and 3).

The fixed amount is due for each tax period, whatever the income, in one payment by the balance date for income tax. It can be extended to family members within article 433 of the civil code who themselves meet the nine-of-ten test, at a lower amount for each. Gains on qualifying shareholdings (article 67(1)(c)) realised in the first five tax periods of the option are NOT covered and are taxed under the ordinary rules. The person may exclude one or more foreign countries: income from those countries is then taxed normally, with a foreign tax credit (TUIR art. 24-bis, commi 1, 2, 5 and 6).

The option can be revoked and in any case ends after fifteen years from the first tax period of the option. It also ends if the substitute tax is not paid, or paid only in part, on time. Revocation or loss bars a new option. Revocation or loss for the main person also ends the regime for the family members; a family member's own non-payment does not end it for the main person (TUIR art. 24-bis, commi 4 and 6).

Item	Value	Note
Source	all figures below	https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:decreto.del.presidente.della.repubblica:1986-12-22;917~art24bis!vig=
Substitute tax per tax period, main person (moves from 1 January 2026)	EUR 300,000	"nella misura di ((euro 300.000)) per ciascun periodo d'imposta in cui è valida la predetta opzione"
Substitute tax per tax period, each family member included (moves from 1 January 2026)	EUR 50,000	"Tale importo è ridotto a ((euro 50.000)) per ciascun periodo d'imposta per ciascuno dei familiari"

Which amount applies. Legge 199/2025 replaced the earlier amounts in the table below with the amounts above, but only for people who move residence to Italy (article 43 of the civil code) from the date the law entered into force, 1 January 2026 (Legge 199/2025, art. 1, commi 25 and 26). A family that moved before that date is on the amount in force when it moved. The pages read for this Guide do not print the amount for each earlier arrival date, so confirm it from the person's own ruling and payment records.

Item	Value	Note
Source	all figures below	https://www.normattiva.it/uri-res/N2Ls?urn:nir:stato:legge:2025-12-30;199
Amount replaced for the main person	EUR 200,000	"le parole: «euro 200.000» sono sostituite dalle seguenti"
Amount replaced for each family member	EUR 25,000	"le parole: «euro 25.000» sono sostituite dalle seguenti"

Italy traps. People under the option, and the family members included, are exempt from the foreign-asset reporting (quadro RW) and from the taxes on foreign property and foreign financial assets (IVIE and IVAFE) for the years of the option (Legge 232/2016, art. 1, comma 153, quoted in the notes to TUIR art. 24-bis). Inheritance and gift tax are not covered by the pages read here; see succession-and-forced-heirship-compared. The regime cannot be combined with the impatriate regimes named in the same note. Italian-source income stays taxable under the ordinary rules.

Portugal

The pages on the Portal das Finanças describe IFICI, the incentive for scientific research and innovation in article 58.º-A of the Estatuto dos Benefícios Fiscais. The allowed pages read for this Guide bar anyone who benefits or has benefited from the non-habitual resident (NHR) regime, and anyone who opted for the "Regressar" regime in article 12.º-A of the IRS Code. They do not state, in words, that IFICI replaced NHR. (EBF article 58.º-A, n.º 10)

IFICI covers a person who becomes Portuguese tax resident, was not resident in Portugal in any of the previous five years, AND carries on one of the listed activities: higher-education teaching and scientific research, qualified jobs under contractual investment benefits, highly qualified professions in qualifying companies, other qualified jobs in entities recognised by AICEP or IAPMEI, R&D staff, jobs in certified startups, or jobs in the Azores and Madeira. The special rate applies to net employment and self-employment income (categories A and B) from those activities, for 10 consecutive years from the year of registration as a resident, and only in years in which the person is resident and still earns income from a qualifying activity. It can be used only once. (EBF article 58.º-A, n.os 1 to 3 and 12)

Item	Value	Note
Source	all figures below	https://info.portaldasfinancas.gov.pt/pt/informacao_fiscal/codigos_tributarios/bf_rep/Pages/EBF58A.aspx
Special IRS rate on net category A and B income from the qualifying activity	20%	"à taxa especial de 20 % sobre os rendimentos líquidos das categorias A e B"

The Tax Authority's IFICI leaflet adds that foreign employment, self-employment, investment, rental and capital-gain income (categories A, B, E, F and G) of IFICI beneficiaries is, as a rule, exempt. Foreign income of any category paid by an entity in a territory with a clearly more favourable tax regime is taxed at the rate in the table below. (AT leaflet, IFICI)

Item	Value	Note
Source	all figures below	https://info.portaldasfinancas.gov.pt/pt/apoio_contribuinte/Folhetos_informativos/Documents/incentivos_investigacao.pdf
Rate on foreign income paid from a blacklisted territory	35%	"são tributados a uma taxa de 35% (que pode ser uma taxa liberatória ou autónoma"

Portugal traps. IFICI needs a qualifying job or activity. A family living on investment income, with no member in a listed activity, does not qualify on the pages read here. The leaflet's list of generally exempt foreign categories (A, B, E, F and G) does not include pensions (category H); confirm the treatment of a foreign pension before relying on IFICI for it.

Switzerland

Under article 14 of the Federal Direct Tax Act (DBG), a natural person may pay a tax on expenditure instead of income tax if the person does NOT hold Swiss citizenship, AND is fully taxable in Switzerland for the first time or after a break of at least ten years, AND carries on no gainful activity in Switzerland. Spouses living together must both meet these conditions. The tax base is the person's annual worldwide living costs and those of the people they support, but at least the HIGHEST of: the fixed amount in the table below; for a person with their own household, seven times the annual rent or rental value; for others, three times the annual board and lodging price; and the gross income from Swiss sources and from income for which a Swiss treaty is used to obtain foreign tax relief. The ordinary federal rate is then applied. (Federal Direct Tax Act, art. 14)

Item	Value	Note
Source	all figures below	https://www.fedlex.admin.ch/filestore/fedlex.data.admin.ch/eli/cc/1991/1184_1184_1184/20260101/de/pdf-a/fedlex-data-admin-ch-eli-cc-1991-1184_1184_1184-20260101-de-pdf-a.pdf
Minimum federal tax base, from 1 January 2026 (indexed by the Finance Department)	CHF 435,000	"435 000 Franken; b. für Steuerpflichtige mit eigenem Haushalt"

Switzerland traps. The figure above is the FEDERAL minimum base only. Cantonal and communal tax on expenditure, cantonal wealth tax and cantonal inheritance and gift taxes are set by each canton and are not printed on an allowed page; they are outside this Guide. Some treaty countries grant relief only if Switzerland taxes the income at the rate for total income; then the base also includes all income from that country (article 14(5)). Any gainful activity in Switzerland breaks the conditions.

UAE

A natural person is a UAE tax resident if ANY of these applies: (1) the usual or primary place of residence AND the centre of financial and personal interests are in the UAE; (2) physical presence in the UAE of 183 days or more within the relevant 12 consecutive months; or (3) physical presence of 90 days or more within the relevant 12 consecutive months by a UAE national, a holder of a valid UAE residence permit or a GCC national, who also has a permanent place of residence in the UAE OR carries on employment or business there. A tax resident may apply to the Federal Tax Authority for a tax residency certificate. (Cabinet Decision No. 85 of 2022, articles 4 and 5)

A natural person falls within Corporate Tax only where turnover from business activities in the UAE exceeds the threshold in the table below in a calendar year. Wages, personal investment income and real estate investment income are disregarded and are not subject to Corporate Tax, whatever the amount. (FTA, Taxation of natural persons under the Corporate Tax Law)

Item	Value	Note
Source	all figures below	https://tax.gov.ae/Datafolder/Files/Guides/CT/Taxation%20of%20natural%20persons%20-%2025%2011%202023.pdf
Business turnover in the UAE above which an individual is within Corporate Tax (per calendar year)	AED 1 million	"Where the Turnover from Business or Business Activities conducted in the UAE exceeds AED 1 million within a Gregorian calendar year"

UAE traps. UAE residence under these tests does not by itself end residence in the old country; the old country's own rules and any treaty decide that. See uk-to-uae-relocation-tax and exit-taxes-when-a-family-moves.

Singapore

IRAS states that, generally, overseas income received in Singapore, including overseas income paid into a Singapore bank account, is not taxable, and need not be declared. Overseas income IS taxable if: it is received through a partnership based in Singapore; overseas employment is incidental to a Singapore employment; an overseas trade or business is incidental to a Singapore trade; the person works in Singapore for a foreign employer; or the person is employed overseas on behalf of the Singapore Government. (IRAS, income received from overseas)

Singapore traps. The page covers individuals' overseas income. Singapore-source income, Singapore work and Singapore partnership income follow the ordinary rules. Residence conditions, immigration status and any family-office incentive are not on the page read here; refer them.

UK

On 6 April 2025 the four-year foreign income and gains (FIG) regime replaced the remittance basis. A UK resident under the statutory residence test can claim it only within their first 4 years of UK residence that follow at least 10 consecutive tax years of non-UK residence. Those whose 4 years began before 6 April 2025 can use the years left from 2025 to 2026. Years spent non-resident inside the window cannot be claimed or rolled forward. The claim is made on the Self Assessment return, source by source. Eligible items include profits of a trade carried on wholly outside the UK, overseas property profits, dividends from non-UK companies and foreign interest. Foreign employment income is NOT eligible (Overseas Workday Relief may apply instead). A claim removes the income tax and capital gains tax allowances. (HMRC, 4-year FIG regime)

Former remittance-basis users can designate foreign income and gains from before 6 April 2025 under the Temporary Repatriation Facility at the rate in the table below. No foreign tax credit is given against that charge. (HMRC, HS264)

Item	Value	Note
Source	all figures below	https://www.gov.uk/government/publications/remittance-basis-hs264-self-assessment-helpsheet/hs264-remittance-of-pre-6-april-2025-foreign-income-and-gains-and-the-temporary-repatriation-facility-trf
Temporary Repatriation Facility rate, designations in tax years 2025 to 2026 and 2026 to 2027	12%	"For the 2025 to 2026 and 2026 to 2027 tax years that rate is 12%."
Temporary Repatriation Facility rate, designations in tax year 2027 to 2028	15%	"For the 2027 to 2028 tax year that rate is 15%."

UK traps. From 6 April 2025 inheritance tax follows long-term UK residence, not domicile. A person is long-term UK resident in a tax year if UK resident for the previous 10 consecutive years or for a total of 10 years or more within the previous 20 years. Long-term residence can continue for up to 10 tax years after leaving, less for shorter stays (3 years after leaving for 10 to 13 years of residence). Inheritance tax is charged on overseas assets in a trust the person set up or added to, even when the person was not long-term UK resident. HMRC lists trust assets on which there is no inheritance tax on the person's death: assets placed in the trust while the person was non-UK domiciled, overseas on 30 October 2024, and overseas on the date of death or when the person's rights in the trust ended. Separate trust charges may still apply (HMRC, Inheritance Tax if you're a long-term UK resident). A family leaving the UK should read this with exit-taxes-when-a-family-moves; one arriving should note that the FIG window is short and fixed. Details are in uk-non-dom.

Ireland

An individual resident in Ireland but not domiciled there pays Irish tax on Irish source income in full and on foreign income only to the extent remitted into Ireland (Revenue, domicile and the domicile levy). The remittance basis rests on domicile: since tax year 2010 an Irish citizen who is not ordinarily resident no longer gets it. It also applies to foreign chargeable gains of non-domiciled individuals. Pay for duties performed in Ireland, even under a foreign employment, is taxed in full and is NOT on the remittance basis. (Revenue, Tax and Duty Manual Part 05-01-21, the remittance basis of assessment as regards UK source income and gains; Tax and Duty Manual Part 05-01-21A)

Domicile levy. The levy is the opposite case: it is charged on an individual who IS domiciled in Ireland, whatever their tax residence, if ALL of these apply in the tax year: worldwide income above the income test, Irish income tax below the tax test, AND Irish property on 31 December worth more than the property test, with no deduction for debts. Irish income tax paid for the year can be set against the levy; USC cannot. The levy is paid and filed by 31 October of the following year. (Revenue, Tax and Duty Manual Part 18C-00-01; Revenue, domicile and the domicile levy)

Item	Value	Note
Source	all figures below	https://www.revenue.ie/en/tax-professionals/tdm/income-tax-capital-gains-tax-corporation-tax/part-18c/18c-00-01.pdf
Domicile levy, per year	EUR 200,000	"The amount of the levy is €200,000."
Income test: worldwide income more than	EUR 1,000,000	"an individual must have “world-wide income” in excess of €1,000,000 for a tax year"
Tax test: Irish income tax for the year less than	EUR 200,000	"whose liability to Irish income tax in the tax year is less than €200,000; and"
Property test: Irish property on 31 December more than	EUR 5,000,000	"Irish property to which the individual is beneficially entitled in possession on 31 December in the tax year must exceed €5,000,000"

Ireland traps. An Irish-domiciled family that moves abroad but keeps Irish property can still owe the levy, because residence does not matter for it. The pages above describe the remittance basis for income tax and capital gains tax only; gift and inheritance tax (CAT) has its own scope rules, set out in ie-non-dom.

Cyprus

An individual is Cyprus tax resident by spending more than 183 days in Cyprus in the tax year, or under the 60-day rule, which needs ALL of: at least 60 days in Cyprus, not more than 183 days resident in any other country, a business or employment (or office) in Cyprus, and a permanent home in Cyprus owned or rented. An individual who is NOT domiciled in Cyprus (or not resident) pays no Special Defence Contribution (SDC) on dividends and interest; rental income was within SDC only up to and including tax year 2025. Whatever the domicile of origin, a person resident for at least 17 out of the last 20 years before the tax year is deemed domiciled, and stays so until completing 20 years of non-residence. (Tax Department, tax residency and domicile)

The 2026 reform keeps the non-dom status and adds an option (new article 3D of the SDC Law) for people who do NOT have a Cypriot domicile of origin and become deemed domiciled: they may pay a lump-sum SDC instead, for two 5-year periods. The election is irrevocable, is not automatic, needs an application approved by the Commissioner for each 5-year period, and must be filed by 30 June of the first year of that period. The lump sum for the whole period is paid by the end of the month after approval; it is not refundable and covers all SDC for those five years. If the application or payment is late, SDC for that year is charged on actual income as a domiciled resident. (Tax Department, SDC presentation 2026; Application form, article 3D)

Item	Value	Note
Source	all figures below	https://www.gov.cy/media/sites/167/2026/03/EEA-%CE%A6%CE%9A%CE%9A-%CE%9C%CE%95%CE%A4%CE%91%CE%A1%CE%A1%CE%A5%CE%98%CE%9C%CE%99%CE%A3%CE%97-06032026.pdf
Lump-sum SDC, per year, article 3D	EUR 50,000	"κατ’ αποκοπή ετήσιο ποσό ΕΕΑ ύψους €50.000"
SDC on dividends for a resident domiciled individual, profits of 2026 onward (what the non-dom does not pay)	5%	"Άτομα σε ποσοστό 5% (μείωση από το 17%)"
SDC on interest for a resident domiciled individual (what the non-dom does not pay)	17%	"αναφορικά με τόκο που λαμβάνει ή πιστώνεται, σε 17%"

Item	Value	Note
Source	all figures below	https://www.gov.cy/media/sites/167/2026/06/Application-Extension-of-Non-Dom.pdf
Lump-sum SDC for each whole 5-year period, paid in one go	EUR 250,000	"The Special Defence Contribution for the entire 5‑year period (€250,000)"

Cyprus traps. Non-dom status is an SDC rule, not an income tax exemption; income tax for residents is covered in cy-non-dom and cyprus-income-tax. The 17-of-20-year clock runs for every family member separately. Someone with a Cypriot domicile of origin cannot use the lump sum.

Decision checklist for a family choosing a base

1. Does each adult meet the look-back test for the regime (years of non-residence before arrival)? Write the years down for each person.
2. Is the family's wealth producing investment income, or does a member work? Portugal's IFICI and Switzerland's expenditure tax turn on work in opposite ways: IFICI needs a qualifying activity, while the Swiss route forbids gainful activity in Switzerland.
3. Is the annual minimum (Malta GRP, Italy, Switzerland) higher than the tax the family would pay anyway? Compare the minimum in each source table with a normal-rules computation done by the adviser for that country.
4. How long does the family plan to stay? Compare with the regime's end: four years in the UK, ten in Portugal, fifteen at most in Italy, the 17-of-20 deemed-domicile clock in Cyprus, no fixed term in Malta and Switzerland.
5. Where will the family actually spend its days? Malta's GRP ends at more than 183 days in another country; UAE and Cyprus residence are day-count tests.
6. Malta's GRP excludes Maltese, EEA and Swiss nationals; EEA and Swiss nationals (not Maltese) can use the Residence Programme instead; Switzerland's expenditure tax excludes Swiss citizens.
7. What does the old country charge on leaving, and what inheritance, gift and wealth taxes follow the family? Use exit-taxes-when-a-family-moves and succession-and-forced-heirship-compared.
8. Who files what in the first year? The Italian ruling and option, the Cyprus article 3D application, the Malta GRP minimum tax by 30 April, and the UK FIG claim each have their own deadline.

Ask the client first

• For each family member: nationality, current tax residence, domicile (and domicile of origin), and the tax years of residence in each country over the last 20 years.
• What income does the family have, by type and by source country, and which member owns each asset? Does any member work, and where?
• Where will each member live and spend days, year by year, and will the family buy or rent the main home?
• Has any member already used a special regime (for example NHR in Portugal, Italy's flat tax or a UK remittance-basis claim)?
• Which country does the family leave, and does it hold property, trusts or companies there?
• How long does the family intend to stay, and do they want the children to inherit under a particular law?

When to refuse or refer

• Refer any computation of total tax under a regime: this Guide compares rules and costs; it does not compute a family's bill.
• Refer Swiss cantonal amounts, cantonal wealth and inheritance tax, and the cantonal negotiation of the expenditure base to a Swiss adviser.
• Refer Italian residence for anyone who moved before 1 January 2026, because the amount depends on the move date and the ruling.
• Refer any family with trusts, foundations or companies abroad: the anti-avoidance and attribution rules of each country are outside this Guide.
• Refer double residence and treaty tie-breaker questions; each regime assumes residence is settled.
• Refuse to state that a family "pays no tax" in a country. Each regime still taxes local-source income, and the UAE and Singapore pages describe specific exceptions.
• Refer a Malta non-dom whose foreign income derived meets the article 56(27) threshold but whose unremitted foreign income is below it, until the reading of article 56(27) is confirmed.

Sources

• Malta: Income Tax Act, Cap. 123; Global Residence Programme Rules, S.L. 123.148; Residence Programme Rules, S.L. 123.160
• Italy: TUIR art. 24-bis; Legge 30 dicembre 2025 n. 199
• Portugal: EBF article 58.º-A; AT leaflet, IFICI
• Switzerland: Federal Direct Tax Act (DBG), as at 1 January 2026
• UAE: Cabinet Decision No. 85 of 2022; FTA, Taxation of natural persons under the Corporate Tax Law
• Singapore: IRAS, income received from overseas
• UK: HMRC, 4-year FIG regime; HMRC, HS264; HMRC policy paper, reforming the taxation of non-UK domiciled individuals; HMRC, Inheritance Tax if you're a long-term UK resident
• Ireland: Revenue, domicile and the domicile levy; Tax and Duty Manual Part 05-01-21; Tax and Duty Manual Part 18C-00-01; Tax and Duty Manual Part 05-01-21A
• Cyprus: Tax Department, tax residency and domicile; Tax Department, SDC presentation 2026; Application form, article 3D

This Guide is a reference for professional advisers. It is not advice for any particular family. Tax law changes; check each source before acting.