Life after the UK Non-Dom Regime: could Malta offer a long-term alternative?
From 6 April 2025, the UK moved away from a domicile-based framework and introduced a new residence-based approach for internationally mobile individuals. For many families who have historically relied on non-dom status, this is more than a technical tax change: it is a prompt to reassess where they wish to live, hold wealth and plan for succession over the longer term.
Why this matters
Under the former regime, eligible UK-resident non-domiciled individuals could generally access the remittance basis of taxation. The abolition of that regime means that individuals with UK connections now need to look carefully at their future exposure, particularly where they intend to remain UK resident for the long term.
The new UK position
The replacement Foreign Income and Gains regime may offer relief for certain new arrivals to the UK, but it is limited in duration and is not designed as a permanent solution. Once the relevant period expires, individuals who remain UK resident may be taxed on worldwide income and gains under the ordinary UK rules.
A key area of concern is inheritance tax. The UK reforms have also shifted inheritance tax towards a residence-based framework. In broad terms, individuals who remain UK resident for a sufficient period may fall within the scope of UK inheritance tax on worldwide assets, creating an important risk for families with substantial non-UK wealth.
Considering alternatives
For individuals and families who do not intend to remain in the UK indefinitely, it may be appropriate to consider alternative residence jurisdictions. Depending on the circumstances, this could include a number of European and non-European options. The right answer will depend on lifestyle, family priorities, investment profile, business interests and succession planning objectives.
Malta may be one such option. It offers an English-speaking environment, EU membership, a familiar legal and professional services framework, and a range of residence routes and tax programmes which may support longer-term relocation and wealth-planning objectives. Importantly, Malta does not impose inheritance tax, wealth tax or estate tax.
Malta as a possible long-term solution
Malta’s framework may be particularly relevant for individuals who are resident but not domiciled in Malta. In broad terms, such individuals may benefit from a remittance-basis system, under which foreign-source income is taxable in Malta only to the extent remitted to Malta, while foreign-source capital gains are generally outside the scope of Maltese tax even if remitted.
Malta also has a number of structured residence programmes which may be suitable depending on the individual’s nationality, income profile and personal circumstances. Rather than considering Malta in isolation, however, the relocation decision should form part of a broader review of residence, succession, family governance and asset-holding structures.
Conclusion
The end of the UK non-dom regime is a significant development for globally mobile individuals and families. For those who do not wish to remain exposed to the UK tax system over the long term, the key question is no longer simply how the new UK rules apply, but whether the UK remains the right jurisdiction from a wider residence and succession-planning perspective.
Malta will not be the answer in every case, and other jurisdictions may also need to be considered. However, for the right profile, Malta can offer a credible longer-term alternative: a stable EU base, an English-speaking environment, a remittance-basis tax framework and no inheritance tax, wealth tax or estate tax.
Individuals affected by the UK reforms should take advice early and review their position holistically, including residence plans, asset ownership, trust structures, inheritance tax exposure and family succession goals. For further detail on Malta’s residence and tax framework, reference can be made to our related articles on Malta’s residence programmes and remittance-basis taxation.
