Relocating to Malta: Your Solution to the End of the UK Non-Dom Regime

Understanding the Current UK Non-Dom Regime

The United Kingdom’s current UK Non-Dom Regime currently provides a favourable tax regime for individuals resident but not domiciled in the UK (UK Non-Doms). Under this system, UK Non-Doms are only required to pay UK tax on (i) income arising in the UK and (ii) foreign income and capital gains which are remitted to the UK.

The End of an Era: Abolishment of the Non-Dom Regime

On 30 October 2024, the UK’s Autumn Budget announced that the Non-Dom Regime will be abolished, effective 6 April 2025. On the same day, the HM Treasury and HM Revenue and Customs issued a policy paper outlining the upcoming changes.

What’s Changing? The Key Reforms

As from 6th April 2025, domicile will no longer be used as a connecting factor in the UK tax system. Instead, taxation will be based solely on tax residence. Consequently, all UK tax resident, including former Non-Doms, will become taxable on their worldwide income and capital gains, regardless of whether these are remitted to the UK.

The reform introduces a temporary Four-Year Foreign Income and Gains (FIG) Regime. Under this regime, new UK tax residents—who have not been UK tax residents for at least 10 years prior—can benefit from tax relief on foreign income and capital gains not remitted to the UK during their first four years of residence.

The Solution: Relocation to Malta

In light of the upcoming reforms, many UK Non-Doms are seeking alternative jurisdictions to establish their tax residence. Malta, renowned for its idyllic landscapes and rich cultural heritage, has emerged as a leading contender.

Malta’s tax system offers even greater benefits than the pre-reform UK Non-Dom Regime. Maltese Non-Doms are taxed only on (i) income and capital gains sourced in Malta and (ii) foreign sourced income remitted to Malta. This means that any foreign capital gains, whether remitted to Malta or not, are not taxable in Malta.

This attractive remittance-based tax system is further enhanced by Malta’s extensive network of Double Taxation Treaties. Additionally, Malta imposes no inheritance or wealth taxes, making it an excellent choice for individuals aiming to preserve their wealth for future generations.

Malta: Tailored Residency Options for Every Need

Malta offers diverse residency routes for EU/EEA citizens and non-EU/EEA nationals, accommodating a variety of personal and professional needs.

EU Ordinary Residence

EU Citizens enjoy the right to leave their home state and freely reside within the territory of another Member State, including Malta. However, where an EU citizen intends to reside in Malta for a period exceeding 3 months, they must obtain a Maltese temporary residence card under one of the following categories: (i) employment in Malta; (ii) self-employment in Malta; (iii) student in Malta; (iv) self-sufficiency, or (v) family.

Once any EU national who has obtained temporary residence in Malta has lawfully resided in Malta for an uninterrupted period exceeding five years, they may apply for permanent residency. Temporary absences of up to six months per year do not interrupt the five-year period.

The Single Permit

Third-Country Nationals (TCNs) require a residence permit to remain in Malta following the expiry of their Schengen Visa (or 90-day period in the case of Schengen-exempt countries). Persons looking to be employed in Malta must obtain a Single Permit, which entitles them to reside and work in Malta.

Other Residence Options

Malta also offers a wide-range of alternative residency routes, with some conferring favourable tax regimes too:

(i) The Malta Retirement Programme

The Malta Retirement Programme is available to all EU, EEA and Third-Country Nationals. Under the Malta Retirement Programme, beneficiaries enjoy a favourable tax rate of 15% on all income arising in Malta (subject to an annual minimum tax of €7500).

(ii) The Malta Residence Programme and the Global Residence Programme

The Malta Residence Programme and Global Residence Programme are essentially identical programmes, with the Malta Residence Programme being available to EU/EEA nationals and the Global Residence Programme being available to TCNs. Under either of these programmes, beneficiaries enjoy a favourable tax rate of 15% on all income arising in Malta (subject to an annual minimum tax of €15,000).

(iii) The Malta Digital Nomad Visa

The Malta Digital Nomad Visa is available to TCNs only. Under the Malta Digital Nomad Visa, residents enjoy a favourable tax rate of 10% on authorised work.

(iv) The Malta Permanent Residence Programme

Under the Malta Permanent Residence Programme, successful applications obtain the right to reside permanently in Malta, provided they continue to meet the requirements for the first five years of residence.

Why Choose Zeta? Your Trust Partner in Relocation

At Zeta, our experienced professionals specialize in assisting individuals and families with relocation and residency applications. From navigating the application process to identifying the most suitable residency programme for your needs, we ensure a seamless transition to life in Malta.

Contact us today to learn how we can help you take advantage of Malta’s exceptional tax and lifestyle opportunities.