Non-domiciled taxation.

Domicile is the oldest idea in cross-border tax and the one my clients understand least. It is the country a legal system treats as your permanent home — the place you would return to and intend to end up. You inherit one at birth and keep it until you genuinely replace it. Moving does not replace it.

For two centuries that idea sat under the most-copied tax arrangement in Europe. The United Kingdom removed it on 6 April 2025, and a steady share of the enquiries reaching my team now come from families whose plan was built on a status that no longer exists.

Citizenship, residence and domicile answer three different questions. Citizenship is a permanent legal relationship with a state; residence is where you are, tested by days and ties, and it can change from one tax year to the next; domicile is your permanent home in the eyes of the law, and the law expects you to have exactly one. A family can hold all three in different countries at once — UK resident, Indian-domiciled, travelling on a Canadian passport.

Under the old British system, domicile decided whether foreign income and gains were taxed as they arose or only when brought into the country, and whether the worldwide estate sat inside the inheritance-tax net. The remittance basis was never free for long — £30,000 a year once you had been UK resident for seven of the previous nine tax years, £60,000 after twelve of the previous fourteen, and gone entirely from 6 April 2017 at fifteen of the previous twenty, when you became deemed domiciled.

The remittance basis is gone and domicile has been removed as the connecting factor for personal tax. A UK resident is now taxed on worldwide income and gains as they arise unless a specific relief applies.

That relief is the four-year foreign income and gains regime, which everyone calls FIG. A qualifying new resident pays no UK tax on eligible foreign income and gains for their first four tax years of UK residence. The gate is residence history, not domicile: you must not have been UK tax resident in any of the ten consecutive tax years before arriving. Nationality is irrelevant, so a British citizen back after a clean decade abroad qualifies — the new regime is open to people the old one deliberately excluded. It is claimed on a Self Assessment return, source by source, and in the years you claim it you give up the income-tax personal allowance and the capital-gains annual exempt amount.

The Temporary Repatriation Facility is the closest thing to a bargain the reform produced. Former remittance-basis users holding foreign income and gains that arose before 6 April 2025 can designate those amounts and pay 12% for the 2025–26 and 2026–27 tax years, or 15% for 2027–28 — and the money does not have to enter the United Kingdom to lock the rate. The same group can rebase foreign assets held on 5 April 2017 to their value at that date. The Temporary Repatriation Facility closes after 2027–28, which makes that a deadline rather than a planning horizon; the rebasing election is a separate relief and is not time-limited in the same way.

The income-tax change got the headlines; the inheritance-tax change reprices a family. From 6 April 2025, whether non-UK assets sit inside the UK inheritance-tax net turns on long-term residence — UK tax resident for at least ten of the previous twenty tax years, not necessarily consecutive. Reach that line and the worldwide estate is in scope at 40% above the available allowances.

Leaving does not end it on the day of the flight. A departing long-term resident stays in the net for a tail of three to ten tax years, scaled to how long they were there: three years at ten to thirteen years of residence, then a further year for each additional year, to a ceiling of ten. The counter runs in tax years, so an early-April departure and a late-March one give different answers, and ten consecutive tax years of non-residence resets the test.

Spouses carry the most expensive assumption. Where a long-term resident leaves assets to a spouse who is not one, the exemption is capped at the £325,000 nil-rate band rather than being unlimited. That spouse can elect to be treated as a long-term resident, which restores the unlimited exemption and simultaneously pulls their own worldwide estate into the UK net for ten years or more. I routinely see the second half go unpriced.

Trusts moved too: settlors of trusts established before 30 October 2024 keep protection from the gift-with-reservation-of-benefit rules on excluded property, but that is a narrow carve-out, and any offshore trust designed around domicile should be re-read against the new rules rather than assumed to have survived.

It still helps three groups: new arrivals with a clean decade outside the United Kingdom, who get four years of untaxed foreign income and gains — long enough to sell a business or rebuild a structure before the worldwide net closes; former remittance-basis users sitting on unremitted pre-April-2025 money; and families whose life already sits in a jurisdiction that still runs the concept.

It no longer helps the people it was famous for helping. At fifteen of the previous twenty years you lost the remittance basis back in 2017, and 2025 closed the estate side behind you. There is no indefinite version now — there are four years, then worldwide taxation like everyone else.

What I will not do is tell you how this ends. HMRC’s statistics for the tax year ending 5 April 2025, the last full pre-reform year and published in July 2026, counted roughly 81,900 non-domiciled and deemed-domiciled taxpayers — down about 1% from 83,100 — paying £13.6 billion in tax and National Insurance, with around 9,000 departures against 11,200 the year before. That is not the collapse the commentary promised, and it is not evidence about what happened after April 2025 either, because the data does not reach that far yet. Anyone quoting a confident number for the post-reform exodus is guessing.

Britain did not take the idea with it. Ireland keeps the cleanest version: an Irish resident who is not Irish-domiciled is taxed on foreign income only to the extent it is brought into Ireland, with no annual charge and no fixed time limit, provided the non-Irish domicile genuinely holds. Malta also runs a remittance basis, and foreign capital gains fall outside the Maltese net whether or not they are remitted — over a minimum annual tax of €5,000 where foreign income reaches €35,000 and is not fully brought in.

Cyprus is a carve-out rather than a remittance basis: a non-domiciled resident pays no Special Defence Contribution on dividends or interest for up to seventeen of twenty years. A 2026 reform added a paid route past that seventeen-year cliff — on terms I have seen reported inconsistently, so it is a question for Cypriot counsel rather than a figure I will publish as settled.

Italy is a substitute tax: foreign-source income taxed at one flat annual figure instead of Italian rates, for up to fifteen years. It has moved twice in under two years — €100,000 originally, €200,000 from August 2024, and €300,000 for anyone taking up Italian tax residence from 1 January 2026, with each family member at €50,000. Existing electors keep the number they signed up at. Greece asks €100,000 a year plus €20,000 per additional family member for fifteen years, conditional on investing €500,000 in Greece and on seven of the previous eight years spent outside it.

The pattern is repricing rather than abolition, and the direction of travel is one way — the wider picture is in what is left of Europe’s golden doors. Closer to my own patch, Barbados taxes new residents on a remittance basis, the nearest thing in the region to what Britain removed, alongside the flat-tax arrangements next door.

Start with the part that saves you time: almost nothing above changes an American’s income tax. US citizens remain taxed by the United States on worldwide income regardless of a second citizenship, and none of the five Caribbean programs has a US income tax treaty. Domicile is not the hinge for a US person; citizenship is.

Where domicile matters enormously for Americans is the estate and gift tax, a separate system running on a separate test. A US citizen or US domiciliary is exposed on the worldwide estate against a basic exclusion of $15,000,000 for deaths in 2026, at rates reaching 40%. A non-citizen who is not US-domiciled is exposed only on US-situs assets — but against an exclusion of $60,000, with an estate tax return required once US-situated assets exceed that figure at death.

That gap catches non-American families more often than American ones. Domicile for estate-tax purposes is a facts-and-intention test — presence plus an intent to remain indefinitely — and it does not track the substantial-presence test used for income tax. Green-card holders are frequently US domiciliaries, and someone who has stayed carefully under the income-tax day count can still be domiciled. A family holding a Florida apartment, US-listed shares or a US-incorporated fund holds US-situs assets against that $60,000 line whether or not anyone has mentioned it.

Two more points decide real numbers. The unlimited marital deduction does not apply where the surviving spouse is not a US citizen — the usual answer is a qualified domestic trust, and lifetime gifts to a non-citizen spouse run against a separate annual exclusion of $194,000 for 2026. And the United States has estate or gift tax treaties with fifteen countries: the United Kingdom is one, which matters for a family leaving Britain, and none is in the Caribbean, which matters for a family arriving. I make sure that arithmetic is run by your own cross-border counsel before anything is bought in a US name — what the international tax planning side of the practice exists to keep on the rails.

A closing non-dom regime is one of the few events that reliably puts a family on a plane, and a fair share of the people I work with arrived in the region that way. It is not uniformly tax-free. Of the five citizenship states, only St. Kitts & Nevis and Antigua & Barbuda levy no personal income tax on residents; Dominica taxes residents at rates up to 35%, St. Lucia up to 30% and Grenada up to 28%, as I set out in the countries with zero income tax in 2026.

What does the work is residency, not a passport. Anguilla’s High Value Resident program grants tax residency for a flat US $75,000 a year alongside a qualifying property of US $400,000 or more and at least 45 days a year on-island, against no income, capital-gains or inheritance tax. Caribbean citizenship carries no residency requirement, so on its own it creates tax residency nowhere — a distinction the citizenship by investment pages set out in full. The American caveat applies to every line: a zero-tax island describes the island’s system, not an American’s global position. For an American staying American, Puerto Rico’s Act 60 changes the arithmetic inside the US system rather than around it, as do territorial systems.

None of the European regimes on this page pays me anything. I earn on the real-estate and citizenship side of a file, which is the only reason to take me seriously when I tell a family that Ireland answers their question better than anything I sell, or that they should stay in the United Kingdom, absorb the inheritance-tax exposure and stop shopping.

The sequence rarely changes: establish where the family will genuinely be resident and for how many nights, plan the exit in parallel rather than afterwards, settle the ownership structure, then let the property and the passport follow. The dates that matter almost all fall before the move. The associates coordinate with the accountants and lawyers you already use; where a mandate runs past coordination, I introduce a dedicated specialist private-capital practice and stay on the real-estate and citizenship side myself.