{"id":201635,"date":"2026-07-23T10:00:00","date_gmt":"2026-07-23T08:00:00","guid":{"rendered":"https:\/\/vellumfinance.com\/non-categorise\/non-dom-analog-regimes-2026-scorecard\/"},"modified":"2026-07-23T10:00:00","modified_gmt":"2026-07-23T08:00:00","slug":"non-dom-analog-regimes-2026-scorecard","status":"publish","type":"post","link":"https:\/\/vellumfinance.com\/en\/insights-education\/non-dom-analog-regimes-2026-scorecard\/","title":{"rendered":"Non-dom and analog regimes: a 2026 scorecard of remaining programs"},"content":{"rendered":"

By mid-2026 the British remittance basis is no longer a living option. It ended on 6 April 2025. What remains, for families who still talk as if \u201cnon-dom\u201d were a European product shelf, is a non-dom regimes 2026 scorecard<\/strong> of analog programmes: Italy\u2019s substitute tax for new residents, the Swiss expenditure-based forfait, Portugal after the NHR rewind, Greece\u2019s article 5A alternative tax, and the United Arab Emirates as a no-personal-income-tax residence rather than a remittance clone. The scorecard is qualitative. It is not a ranking of \u201cbest places,\u201d and it is not a relocation brochure.<\/p>\n

This article is general information for families and family offices. It is not a tax opinion, a mandate, or personalised advice. Access to any regime depends on facts, statutory tests, and counsel who can read the official pages in force. Nationality, tax residence, domicile in the private-law sense, and immigration status are four different files. Mixing them is how kitchen-table plans fail.<\/p>\n

What a non-dom regimes 2026 scorecard can and cannot do<\/h2>\n

A useful scorecard asks the same questions in each jurisdiction. Who may elect? How many prior years of non-residence are required? What income is carved out, and what remains taxed locally? How long does the election last? What substance, investment, or employment condition sits underneath? What happens to gifts, estates, and exit when the family later leaves? Official tax authorities answer those questions. Private-bank slides do not.<\/p>\n

The scorecard cannot tell a household where to live. Schooling, operating companies, succession law, and the French IFI snapshot if anyone remains resident in France sit in other files. Families who still need a real-estate inventory in France should keep the IFI 2026 taxable-wealth note<\/a> on the same desk. A move that \u201csolves income tax\u201d and quietly leaves French bricks in a French-resident spouse is not a solution.<\/p>\n

United Kingdom: the reform already happened<\/h2>\n

HMRC is explicit. From 6 April 2025 the remittance basis was abolished and domicile ceased to be a connecting factor for this part of the tax system. UK residents are taxed on the arising basis on worldwide income and gains, subject to a new, time-limited relief. The government\u2019s own note on reforming the taxation of non-UK domiciled individuals<\/a> describes a four-year foreign income and gains (FIG) regime for qualifying new residents: 100% relief on foreign income and gains in the first four tax years of UK residence, provided the individual was not UK tax resident in any of the ten consecutive years before arrival.<\/p>\n

That is not the old non-dom. It is a short incoming-resident holiday with a ten-year absence test. Claims are made. Unused years do not roll forward. Overseas Workday Relief was aligned to four years, with a financial cap described by HMRC as the lower of \u00a3300,000 or 30% of total employment income. Former remittance-basis users who still hold pre-6 April 2025 foreign income and gains sit in a different drawer, including the temporary repatriation facility. The UK is no longer an analog of Italy or Greece. It is a four-year FIG, then arising-basis worldwide tax. Families who still say \u201cwe are non-dom in London\u201d are describing a regime that closed.<\/p>\n

Italy: substitute tax for new residents<\/h2>\n

Italy\u2019s analog is an optional substitute tax on foreign-source income for individuals who transfer tax residence to Italy and who were not Italian tax residents for at least nine of the ten preceding years. The Agenzia delle Entrate page on the optional regime for new residents<\/a> is the official source. The election can last up to fifteen years. Italian-source income remains on the ordinary scale. An interpello (advance ruling) is possible before electing.<\/p>\n

The lump-sum amount has moved. Until 10 August 2024 it was \u20ac100,000 a year. For transfers of tax residence after that date and through 31 December 2025 the Agenzia\u2019s own notice records \u20ac200,000. The 2026 budget law raised the substitute tax to \u20ac300,000 a year for individuals who move their Italian tax residence from 1 January 2026, and raised the amount for each qualifying family member to whom the option is extended to \u20ac50,000 (it had been \u20ac25,000). Those figures are statutory steps, not a private-bank \u201cItaly package.\u201d A household that elected earlier may sit on the amount that applied at its transfer date. A household arriving in 2026 should not quote a 2017 brochure.<\/p>\n

Qualitatively, Italy still scores as a long, expensive, foreign-income cap with ordinary tax on Italian assets and a ruling culture. It is not a territorial system. It is not a four-year holiday. Families who need Italian operating income, Italian property, or Italian employment will still meet IRPEF on those lines. Inheritance and gift tax on foreign assets can be lighter for electors; that is a separate statute to read, not a slogan that \u201cItaly has no succession tax.\u201d<\/p>\n

Switzerland: expenditure-based forfait, canton by canton<\/h2>\n

Switzerland\u2019s analog is expenditure-based taxation, often called forfait. The Federal Department of Finance describes it as a simplified assessment for foreign nationals who take up Swiss domicile for the first time, or after at least ten years outside, and who are not gainfully employed in Switzerland. Ordinary rates then apply to a deemed base. The official lump-sum taxation page<\/a> is the federal orientation. Cantons implement, and several have abolished the cantonal and communal layer: Zurich, Schaffhausen, Appenzell Ausserrhoden, Basel-Stadt, and Basel-Landschaft. Federal expenditure-based tax can still exist in those cantons; living there on a forfait is usually unattractive because cantonal and communal tax then looks through to ordinary worldwide assessment.<\/p>\n

The base is not \u201crent times twelve.\u201d Federal law uses worldwide living costs, a minimum of seven times the annual rent or rental value of the principal Swiss home, a federal minimum floor that is indexed, and a control calculation so that the tax is not lower than ordinary tax on specified Swiss-source items and on foreign items for which treaty relief is claimed. This article does not invent a 2026 federal floor as a planning number. The indexed amount is set by ordinance; families should read the ordinance in force with cantonal counsel, not a three-year-old slide.<\/p>\n

Qualitatively, the Swiss forfait scores as a lifestyle-and-immigration file more than a \u201cforeign income holiday.\u201d Gainful activity in Switzerland ends the right. Swiss citizenship ends it. The control calculation pulls Swiss assets and treaty claims back into view. It is available only to foreign nationals. A French family that intends to keep running the operating company from Geneva is usually not in this regime at all.<\/p>\n

Portugal after NHR: IFICI is not the old NHR<\/h3>\n

Portugal\u2019s Non-Habitual Resident regime was wound down. What remains for new residents is the tax incentive for scientific research and innovation (IFICI), in article 58-A of the Estatuto dos Benef\u00edcios Fiscais. The Autoridade Tribut\u00e1ria FAQ on IFICI<\/a> is the official reading. It is a talent regime, not a wealth regime. Eligible employment and self-employment income can meet a special 20% IRS rate for up to ten years, subject to highly qualified activities, designated sectors, and registration with the competent body (FCT, AICEP, IAPMEI, the tax authority, and others depending on the activity). Prior Portuguese residence in the previous five years, and prior use of NHR or certain other regimes, block access.<\/p>\n

Foreign-source income is not the old NHR postcard. Pensions and blacklisted-jurisdiction investment income are treated differently from the 2009-2024 product. Families who still quote \u201cPortugal, ten years, foreign income exempt\u201d are quoting a closed shop. IFICI can still be useful for a principal who actually works in an eligible role. It is a poor analog of non-dom for a retired household whose only plan is a Lisbon apartment and a securities book.<\/p>\n

Greece article 5A and the UAE as a different species<\/h2>\n

Greece offers an alternative tax on foreign-source income under article 5A of Law 4172\/2013. The Independent Authority for Public Revenue sets out the architecture on its page on tax incentives for new tax residents<\/a>. The headline tests, in the Authority\u2019s own materials, are: the person was not a Greek tax resident for seven of the eight years before the transfer; and an investment in Greece of at least \u20ac500,000 (real estate, businesses, or securities of Greek-based entities), to be completed within three years, unless a residence permit for investment activity already covers that condition. If accepted, the person pays a lump-sum tax of \u20ac100,000 each year on foreign-source income, regardless of amount, for up to fifteen years. Relatives can be extended for an additional amount. Greek-source income stays on the ordinary code.<\/p>\n

Qualitatively, Greece scores as a long, cheaper-than-Italy foreign-income cap with a real investment condition. The investment is not a decoration. Banks, land registries, and the tax office will look for it. Families who wire the money into a personal account and call it \u201cinvested\u201d have not completed the statutory test.<\/p>\n

The United Arab Emirates is not a non-dom analog. There is no federal personal income tax on wages or on ordinary personal investment income. The Federal Tax Authority service for tax-residency certificates<\/a> exists so that a person who is a UAE tax resident can evidence that status, including for treaties. Cabinet rules describe physical presence of 183 days in twelve months, a 90-day test with residence permit and a home or business, and a centre-of-interests test. Corporate tax at 9% can still reach a natural person who conducts a business in the UAE above the turnover threshold. The UAE therefore scores as a residence-and-substance file, plus corporate tax for operating activity, plus whatever the departure country charges on the way out. It is not a fifteen-year election. It is not FIG.<\/p>\n

How to read the scorecard without turning it into a league table<\/h2>\n

Duration: UK FIG is four years after a ten-year absence. Italy and Greece can run to fifteen. IFICI can run to ten for eligible work. Swiss forfait lasts while the conditions hold. UAE residence lasts while the tests hold.<\/p>\n

Price of the cap: Italy\u2019s 2026 inbound lump sum is \u20ac300,000 on foreign income (plus family members). Greece\u2019s article 5A is \u20ac100,000 plus a \u20ac500,000 investment. Switzerland prices a deemed lifestyle base at ordinary cantonal rates. Portugal\u2019s IFICI prices eligible work at 20% and does not sell a wealth cap. The UAE does not charge personal income tax on the ordinary personal book.<\/p>\n

Local income: every analog still taxes local-source income on some ordinary basis. Italian work, Greek rents, Swiss-source items in the control calculation, Portuguese ineligible work, UK income during FIG, UAE business activity above the corporate-tax line. The slogan \u201cforeign income only\u201d is never the whole return.<\/p>\n

Substance: Switzerland forbids gainful activity. IFICI requires a qualified role. Greece requires an investment. Italy requires actual tax residence. The UAE requires days or a centre of interests if a residency certificate is to mean anything in a treaty. The UK FIG requires qualifying new-resident status, not a historic domicile story.<\/p>\n

Exit and overlays: leaving France can still meet article 167 bis. Leaving a forfait canton can still meet Swiss departure rules. UK inheritance tax connecting factors after 2025 are a statute to read, not a memory of excluded property. Holding-company interest limitation, including the French ATAD operating rule in the ATAD 2026 holding note<\/a>, does not disappear because the principal elected a personal analog. Vellum maps those layers as a fee-only office; the work sits on the services map<\/a>, not in a jurisdiction beauty parade.<\/p>\n

Conclusion<\/h2>\n

The 2026 scorecard is a set of official tests, not a league of \u201cnon-dom replacements.\u201d The United Kingdom closed the remittance basis in 2025 and offers a short FIG. Italy sells a long substitute tax whose inbound price moved in 2024 and again for 2026 arrivals. Switzerland still offers a canton-limited forfait for non-working foreign nationals. Portugal\u2019s remaining programme is a talent incentive. Greece offers a fifteen-year foreign-income lump sum with an investment condition. The UAE is a no-PIT residence with corporate tax and residency-certificate tests. Families who read the authorities will still need counsel. Families who buy a 2019 non-dom slide will buy a closed shop.<\/p>\n

Discretion. Stability. Prosperity.<\/strong><\/p>\n","protected":false},"excerpt":{"rendered":"

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