UK's New FIG Regime: The End of the Non-Dom Era and the Search for Europe's Best Alternative in 2026

The UK's new Foreign Income and Gains (FIG) regime applies to individuals becoming UK tax resident after at least ten consecutive tax years of non-UK residence.

Unlike the former non-dom regime, eligibility is determined by tax residence rather than domicile. Qualifying individuals may benefit from relief from UK tax on qualifying foreign income and gains during their first four UK tax years, irrespective of whether those funds are remitted to the United Kingdom.

For internationally mobile executives, entrepreneurs relocating for a business exit, or professionals undertaking a defined UK assignment, the FIG regime may provide valuable short-term tax advantages.

However, the reforms also signal a fundamental policy change. The former non-dom regime allowed many internationally mobile families to structure their long-term affairs around the remittance basis. The new FIG regime is intentionally temporary. Once the four-year period expires, UK tax generally applies to worldwide income and gains, while parallel reforms to inheritance tax and trust taxation have further altered the UK's attractiveness as a long-term wealth planning jurisdiction.

For many successful families, the question has therefore shifted from whether the UK remains attractive, to whether another European jurisdiction now offers greater long-term certainty.

Today's internationally mobile families rarely select a jurisdiction based solely on tax.

Residence rights, succession planning, family governance, education, political stability, access to European markets and long-term legal certainty increasingly influence relocation decisions alongside taxation.

This reflects a broader global trend. According to the UBS Billionaire Ambitions Report, more than one-third of surveyed billionaires have already relocated internationally, while almost one in ten are actively considering doing so. Likewise, UBS reports that the overwhelming majority of family offices now maintain assets across multiple jurisdictions, demonstrating that geographical diversification has become a core wealth preservation strategy rather than simply a tax planning exercise.

Against that background, several European jurisdictions have emerged as leading alternatives.

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Italy continues to attract wealthy individuals through its special tax regime for new residents.

The regime combines an attractive lifestyle with a relatively straightforward substitute tax for qualifying foreign income, making it particularly appealing to individuals intending to establish genuine long-term residence in Italy.

Nevertheless, it differs fundamentally from the former UK non-dom regime. It is not based on a remittance system, has become more expensive following recent legislative changes and should always be assessed alongside immigration requirements, succession planning and long-term tax residence objectives.

For internationally mobile families considering Italy, the jurisdiction may represent an excellent lifestyle destination, but not necessarily the most flexible platform for wider European mobility.

Switzerland remains one of the world's premier private wealth jurisdictions.

Its expenditure-based lump-sum taxation continues to attract ultra-high-net-worth individuals seeking political stability, legal certainty and access to one of the world's most sophisticated private banking sectors.

However, Swiss lump-sum taxation is selective, negotiated at cantonal level and generally intended for individuals who are not economically active in Switzerland.

Accordingly, while Switzerland remains an outstanding specialist jurisdiction, it is not necessarily the most suitable solution for internationally mobile entrepreneurs or families seeking broader European residence and mobility rights.

Among European jurisdictions, Malta increasingly offers one of the closest strategic alternatives to the former UK non-dom model.

Rather than relying upon a temporary tax incentive, Malta combines a long-established remittance basis of taxation for qualifying non-domiciled residents with European Union membership, Schengen participation, English as an official language and a mature legal and professional services ecosystem.

Clients seeking special tax status should first consider Malta's Global Residence Programme, which explains how Malta's remittance-basis tax framework operates for qualifying non-EU nationals.

Families whose primary objective is obtaining indefinite European residence may instead wish to explore the Malta Permanent Residence Programme, one of Europe's leading permanent residence solutions for internationally mobile private clients.

British nationals reassessing their European strategy after the UK's reforms may also find our guide to Malta residence, tax and citizenship options for British nationals particularly useful when comparing post-Brexit residence pathways.

Those considering longer-term integration should also understand the distinction between residence and Malta Citizenship by Merit. Legal Residence, Tax Residence and Citizenship serve different legal purposes and should never be regarded as interchangeable planning tools.

Unlike jurisdictions offering only a tax regime or only an immigration programme, Malta allows internationally mobile families to coordinate tax residence, property ownership, succession planning, European mobility and long-term wealth preservation within one coherent legal framework.

For qualifying non-domiciled residents, foreign-source income is generally taxable only if remitted to Malta, while foreign-source capital gains generally remain outside the scope of Maltese taxation. Combined with the absence of wealth and inheritance taxes, this continues to position Malta among Europe's most attractive jurisdictions for internationally mobile private clients when properly structured.

No single jurisdiction has replicated the former UK non-dom regime.

The UK's FIG regime is primarily designed as a temporary incentive for new arrivals. Italy provides an attractive lifestyle-led tax regime, while Switzerland continues to appeal to exceptionally wealthy individuals seeking maximum political and legal stability.

For internationally mobile families looking beyond a short-term tax incentive, Malta increasingly distinguishes itself through its combination of long-term tax efficiency, permanent residence opportunities, European mobility, legal certainty and sophisticated private client infrastructure.

Selecting the right jurisdiction is therefore no longer simply a tax decision. It is a strategic decision affecting family governance, business succession, investment structures, international mobility and future generations.

"The UK's FIG regime represents a significant reform, but it is not a direct replacement for the former non-dom model. Increasingly, internationally mobile families are looking beyond temporary tax incentives towards jurisdictions offering long-term certainty. Malta's combination of tax efficiency, European mobility and legal stability makes it one of Europe's most compelling alternatives."
‍Dr. Jean-Philippe Chetcuti, Senior Partner, European Citizenship & Tax Advisory

[question]What is the UK's Foreign Income and Gains (FIG) regime?[/question]

[answer]
The Foreign Income and Gains (FIG) regime replaced the UK's former non-dom remittance basis from 6 April 2025. It allows qualifying new UK tax residents to benefit from relief on qualifying foreign income and gains for up to four UK tax years, subject to meeting the statutory eligibility requirements.
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[question]Who qualifies for the UK FIG regime?[/question]

[answer]
Broadly, the regime is available to individuals becoming UK tax resident after at least ten consecutive tax years of non-UK residence. Eligibility depends on an individual's tax residence history rather than their domicile.
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[question]How long does the UK FIG regime last?[/question]

[answer]
The relief is generally available for the first four UK tax years after becoming UK tax resident. Once this period expires, individuals are generally subject to UK taxation on their worldwide income and gains if they remain UK tax resident.
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[question]Does the FIG regime replace the former UK non-dom regime?[/question]

[answer]
Yes, but it is not a direct equivalent. The former non-dom regime provided long-term planning opportunities based on domicile and the remittance basis, whereas the FIG regime is a temporary, residence-based relief intended primarily for new arrivals.
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[question]How have the UK non-dom reforms affected inheritance tax planning?[/question]

[answer]
The reforms introduced a more residence-based approach to inheritance tax, making long-term residence status increasingly relevant. Individuals with significant international assets should review their estate planning and trust structures before becoming UK tax resident or changing residence.
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[question]Why are internationally mobile families reconsidering the UK?[/question]

[answer]
Many families are reassessing the UK because the new regime provides only temporary tax relief. Increasingly, decisions are based on long-term legal certainty, succession planning, residence rights, European mobility, political stability and family office considerations rather than tax alone.
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[question]Which European countries are considered the main alternatives to the UK's FIG regime?[/question]

[answer]
Among the leading alternatives are Malta, Italy and Switzerland. Each offers a different combination of tax treatment, residence options and lifestyle benefits, making professional cross-border advice essential before relocating.
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[question]Why is Malta frequently compared with the former UK non-dom regime?[/question]

[answer]
Malta offers a long-established remittance basis of taxation for qualifying non-domiciled residents together with European Union membership, Schengen mobility, English as an official language and a mature legal and financial services sector. This combination makes Malta one of Europe's most attractive long-term alternatives for internationally mobile private clients.
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[question]Does Malta tax foreign income?[/question]

[answer]
For individuals who are resident but not domiciled in Malta, foreign-source income is generally taxable only if remitted to Malta. The precise tax treatment depends on the individual's personal circumstances and professional advice should always be obtained.
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[question]Does Malta tax foreign capital gains?[/question]

[answer]
Foreign-source capital gains realised by individuals who are resident but not domiciled in Malta are generally not subject to Maltese income tax, even if remitted to Malta. The application of the rules depends on the individual's residence, domicile and the nature of the assets concerned.
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[question]Does Malta have wealth tax or inheritance tax?[/question]

[answer]
Malta does not impose a general wealth tax or inheritance tax. However, other taxes, including duty on certain transfers of property or shares, may apply depending on the circumstances.
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[question]What is the Malta Global Residence Programme?[/question]

[answer]
The Malta Global Residence Programme provides a special tax status for qualifying non-EU, non-EEA and non-Swiss nationals who establish residence in Malta and satisfy the programme's statutory conditions, including property and minimum tax requirements.
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[question]What is the Malta Permanent Residence Programme?[/question]

[answer]
The Malta Permanent Residence Programme allows qualifying third-country nationals to obtain permanent residence rights in Malta through a regulated investment-based framework, offering long-term residence together with Schengen travel benefits.
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[question]Is Malta residence the same as Maltese citizenship?[/question]

[answer]
No. Residence and citizenship are separate legal concepts. Residence grants the right to reside in Malta, whereas citizenship confers nationality together with the rights and obligations associated with Maltese and European Union citizenship. Different legal criteria apply to each.
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[question]How does Italy compare with Malta for former UK non-doms?[/question]

[answer]
Italy offers an attractive flat-tax regime for qualifying new residents and remains an excellent choice for individuals wishing to establish long-term residence there. Malta may offer greater flexibility for internationally mobile families seeking a remittance-basis tax framework together with permanent residence options and broader European mobility.
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[question]How does Switzerland compare with Malta?[/question]

[answer]
Switzerland is renowned for its expenditure-based lump-sum taxation, political stability and private banking sector. Malta generally offers broader European mobility, a remittance-basis tax framework for qualifying residents and a wider range of residence pathways for internationally mobile families.
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[question]Is the UAE a better alternative than Malta?[/question]

[answer]
The answer depends on individual objectives. The UAE may appeal to entrepreneurs seeking a low-tax environment outside Europe, whereas Malta provides European Union membership, Schengen access, long-term residence options and a comprehensive legal framework for international families.
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[question]Should I leave the UK because of the FIG regime?[/question]

[answer]
The decision should never be based solely on tax. It requires careful consideration of family circumstances, business interests, succession planning, lifestyle, residence objectives and international mobility. Professional legal and tax advice should always be obtained before changing tax residence.
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[question]How can CCLEX help?[/question]

[answer]
CCLEX advises internationally mobile entrepreneurs, investors and high-net-worth families on residence, citizenship and international tax planning across Malta, Italy, Switzerland and other leading jurisdictions. We help clients compare alternative residence strategies and coordinate cross-border legal, tax and immigration advice before relocation.
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Choosing the right jurisdiction after the UK's non-dom reforms requires more than comparing tax rates. It demands a coordinated assessment of residence rights, immigration pathways, personal taxation, succession planning, wealth structuring and long-term family objectives.

CCLEX adopts a holistic legal approach, bringing together immigration, international tax and private client expertise within one multidisciplinary team. This enables clients to evaluate residence and tax strategies as part of a single, integrated plan rather than through fragmented advice from multiple advisers.

Unlike advisers focused on a single jurisdiction or residence programme, we take a jurisdiction-agnostic approach. We compare Malta alongside other leading destinations – including Italy, Switzerland, the UAE and additional European jurisdictions – before recommending the solution that best aligns with each client's personal, family and commercial priorities.

Our lawyers regularly advise entrepreneurs, investors, family offices and internationally mobile families on:

• Comparing the UK's FIG regime with alternative European residence and tax frameworks.
• Selecting the most appropriate jurisdiction based on tax, immigration and succession objectives.
• Coordinating international tax residence with residence permits, permanent residence and citizenship pathways.
• Structuring cross-border relocation strategies for individuals, families and family offices.
• Working alongside clients' existing accountants, wealth managers and international advisers to deliver coordinated, long-term planning.

Our objective is not simply to facilitate relocation, but to help clients establish the right long-term legal, tax and mobility strategy for themselves and future generations.