The UK Killed the Non-Dom, But it Lives on in These Countries

The non-dom may be dead in the UK, but Marco Mesina shows its legacy lives on globally from Thailand’s beaches to Singapore’s skyscrapers.

On April 6, 2025, the United Kingdom officially dismantled its historic “non-dom” tax regime — a model that allowed foreign income and gains to remain untaxed unless remitted to the UK.

This reform closes a chapter for many global entrepreneurs and internationally mobile individuals.

But does it really end the story?

In reality, the “remittance basis” concept, or at least its territorial spirit, is thriving in several parts of the world.

For those willing to look beyond familiar shores, there are still jurisdictions offering highly favorable frameworks to structure global wealth efficiently while enjoying premium lifestyles.

And perhaps the most ironic — and compelling — example is Thailand.

Thailand: Where the old UK model still draws breath

Thailand, a country with a curious British heritage (think left-side driving), has preserved what the UK is now abolishing: A territorial taxation system.

Thailand does not tax foreign income and capital gains unless a person brings them into Thailand. Offshore earnings, trusts, dividends, and gains remain outside the Thai tax net if they stay offshore.

In other words, Thailand operates a modern-day equivalent of the UK’s old non-dom system — effectively, quietly, and without the political storms surrounding the British debate.

Beyond taxation, Thailand offers a unique blend of lifestyle and affordability. It has a tropical climate akin to Bali or the Caribbean, a laid-back yet vibrant lifestyle, excellent international schools, attractive real estate opportunities for foreigners, and thriving entrepreneurial and digital nomad communities; Thailand feels like a natural extension for many accustomed to living abroad.

Beyond Thailand: Other major jurisdictions preserving territorial or remittance-based taxation

Thailand isn’t the only “escape route.” Several other countries maintain territorial or remittance-friendly systems, each offering unique advantages.

Malaysia

Malaysia continues to operate a territorial taxation system where foreign income is generally exempt unless one remits it to Malaysia. Cities like Kuala Lumpur, Penang, and Langkawi offer high-quality, affordable living and an abundance of residency programs.

Malta

As an EU member state, Malta still offers a remittance basis to residents who are not domiciled there. Foreign income kept abroad remains untaxed, and Malta’s strong financial services sector, strategic Mediterranean location, and English-speaking environment make it a compelling choice.

Mauritius

Mauritius has emerged as a rising star for global wealth structuring. Through its territorial taxation system and competitive tax rates, combined with a stable political environment and a tropical lifestyle, it increasingly appeals to entrepreneurs and retirees alike.

Panama

Panama boasts one of the purest territorial tax systems globally, exempting all foreign-sourced income from taxation regardless of remittance.

Its vibrant capital city, strong banking sector, attractive residency programs, and tropical retreats make it a key contender.

Caribbean Jurisdictions

Several Caribbean nations, such as Saint Kitts and Nevis, Antigua and Barbuda, Dominica, Grenada, and Saint Lucia, offer variations of territorial taxation or remittance systems.

Often paired with citizenship-by-investment programs, these jurisdictions provide tax advantages and greater global mobility options.

Singapore and Hong Kong: Financial powerhouses on territorial principles

Two of Asia’s leading hubs, Singapore and Hong Kong, have built global reputations on their adherence to territorial taxation models.

In Singapore, the government generally taxes foreign income only when remitted under certain conditions. As for living standards, it boasts outstanding infrastructure, healthcare, and education systems.

Meanwhile, Hong Kong applies a purely territorial basis, taxing only income one generates from within its borders, as foreign income remains untaxed even when brought into the jurisdiction.

Both cities, heavily influenced by British traditions, offer top-tier financial services and are natural homes for wealth management and international business.

Cyprus: The UK model, Mediterranean edition

While the UK abandons its historic model, Cyprus maintains one of the most attractive non-dom systems in Europe—combining Mediterranean lifestyle with significant tax advantages.

The Cyprus non-domicile regime offers remarkable benefits to foreign residents establishing tax residency on the island. The government only taxes Cypriot source income while foreign-generated dividends, interest, and capital gains remain entirely untaxed when kept offshore.

Cyprus introduced its non-dom program in 2015, but recently enhanced its appeal: The program exempts non-doms from the Special Defence Contribution tax on worldwide dividends and interest for a generous 17-year period. High-earning professionals also enjoy a 50% tax exemption on employment income when earning above €55,000 annually.

Ireland: The original model, preserved

While Cyprus adapted the UK’s system, Ireland preserves one of the purest forms of the original UK non-dom model—and in some ways, offers even more favorable terms.

The Ireland non-domicile regime follows similar principles to the former UK system, taxing individuals on the remittance basis. This means the Irish government only taxes foreign income and gains when non-doms actually bring them into Ireland.

However, Ireland’s version boasts notable advantages over the former UK model: Unlike the UK, Ireland does not have a time limit and therefore does not impose a deemed-domicile rule after a certain number of years. Ireland also charges no annual fee for non-doms and requires no application or formal qualification process.

For non-domiciled individuals in Ireland, the tax benefits remain straightforward: The Irish tax authorities only tax Irish sources of income while income from foreign sources only faces taxation to the extent that it enters Ireland.

This system particularly benefits those who maintain their lifestyle using pre-existing wealth or foreign income kept offshore. Careful planning allows some individuals to achieve near-zero taxation while enjoying full European Union residency.

Remittance basis vs. territorial taxation: A strategic distinction

While often achieving similar outcomes, it is important to distinguish between remittance basis and territorial taxation.

Under the remittance basis (as in the old UK system and Malta), the government only taxes foreign income only if a person brings it into the country.

Under territorial taxation (as in Thailand, Malaysia, Panama, Singapore, and Hong Kong), the government generally doesn’t tax foreign income at all, whether or not remitted.

Understanding this distinction is critical for structuring cross-border wealth efficiently and avoiding unintended tax consequences.

Special regimes in traditional worldwide tax countries

In addition to countries offering territorial or remittance-based systems, some jurisdictions traditionally applying worldwide taxation have introduced special regimes to attract international investors and wealthy individuals.

Notably, Italy and Greece have implemented programs that temporarily exempt foreign income from domestic taxation.

Italy offers a “lump sum” regime under which new residents can opt to pay a flat €200,000 annual tax in lieu of ordinary taxation on their foreign income for up to 15 years.

This framework provides a highly attractive alternative for those seeking the lifestyle advantages of Italy without the full weight of worldwide taxation.

Similarly, Greece has introduced a parallel regime, allowing eligible individuals to pay a reduced €100,000 flat tax annually on foreign income, also for a duration of up to 15 years.

Both programs represent a strategic blend of traditional residency benefits with the flexibility typically associated with remittance or territorial models.

It is worth mentioning that Portugal, once one of the most popular destinations under its Non-Habitual Resident (NHR) regime, also offered substantial exemptions on foreign income, but the government has abolished this regime for new applicants, further reshaping the European landscape for tax migration.

A similar model still survives in Ireland, where non-domiciled residents continue to benefit from a remittance basis of taxation, although within a more restrictive and technical framework.

The end of an era — and the dawn of new horizons

The UK’s abolition of the non-dom regime may feel like the end of an era.

Yet for those willing to adapt, the world still offers multiple jurisdictions honoring the spirit of international wealth protection.

From the beaches of Thailand to the skyscrapers of Singapore, from the serene shores of Mauritius to the vibrant life of Panama City, and the idyllic Caribbean islands, the possibilities remain wide open.

The non-dom may be dead in the UK, but around the world, its legacy — and its opportunities — live on.