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UK’s Non-Dom Status Abolition: What It Means for You and Why Malta’s Citizenship and Residency Programmes Are Worth Exploring

Written by Nathalie Galea | Sep 30 2024

The historic bond between Malta and the United Kingdom runs deep, with ties stretching back centuries. As a former British colony, Malta shares much with the UK, especially on a cultural and institutional level. English is not only widely spoken but also one of Malta’s official languages, while the island’s legal and educational systems are firmly rooted in the British model. This long-standing connection has created a strong sense of familiarity between the two nations, making Malta an appealing and welcoming destination for many Britons who find comfort in its blend of Mediterranean charm and British-influenced infrastructure.

Now, as the UK looks to reshape its tax landscape by phasing out its non-domiciled (non-dom) status, individuals and families benefiting from this arrangement are faced with the challenge of exploring new avenues to secure their financial future. 

Given Malta’s strong ties to the UK and its favourable tax position, Malta is being regarded as a leading alternative by those who want to protect their wealth while enjoying a high standard of living.

In this article, we’ll explore the implications of the UK’s shifting tax policies and why Malta’s citizenship and residency programmes might be the perfect solution for those planning their next move.

The UK’s Non-Dom Status: What is it, and What’s Changing?
 

For over 200 years, the UK's non-dom status allowed foreign nationals living in the UK to pay taxes only on their UK-generated income, leaving their global earnings largely untaxed. This arrangement was particularly advantageous for high-net-worth individuals (HNWIs) with international assets, helping them minimise their tax liabilities.

The UK's non-dom population includes over 65,000 people, ranging from multibillionaires to entrepreneurs, executives, and fund managers. For years, they've enjoyed the benefit of avoiding UK taxes on their overseas earnings for up to 15 years while also significantly reducing their exposure to inheritance taxes.

However, the UK government has decided to abolish the non-dom regime due to growing scrutiny over its fairness. According to the Chartered Institute of Taxation, the UK government will enforce these changes from April 2025, meaning that former non-doms will soon be taxed on their worldwide income. As a result, many are already looking for alternatives, whether that means reorganising their financial strategies or relocating to more tax-friendly jurisdictions. 

Key changes to the UK tax regime for non-domiciled individuals who have been UK residents for over four years will now face UK taxation on their worldwide income and gains, whilst opting into the new Foreign Income and Gains (‘FIG’) regime removes personal allowances and the capital gains tax exemption. Additionally, a Temporary Repatriation Facility allows for the repatriation of pre-6 April 2025 foreign income and gains at a reduced 12% tax rate between 2025 and 2027. 

On the other hand, the major changes to non-UK residents returning after 10 years of absence can benefit from the FIG regime for four years. The UK government also plans to introduce a residence-based Inheritance Tax, taxing worldwide assets after 10 years of residency. Lastly, trust protections will be removed for non-domiciled individuals not in the FIG regime, leading to UK taxation of trust income and gains.

Why Malta Stands Out as an Alternative

While there will still be planning strategies available within the UK, a number of non-doms are considering relocation, particularly to countries that offer more favourable tax jurisdictions. For those looking to remain in Europe, Malta offers an appealing option.

With its strong historical ties to the UK, familiar legal frameworks, and advantageous tax policies, Malta is a natural choice for Britons and expatriates seeking an alternative. It’s no surprise that the island is increasingly drawing the attention of those impacted by the UK's changes. Below, we explore the key reasons why Malta stands out as an ideal destination for former non-doms.

1.    Shared Culture and Familiar Legal Framework

Malta’s historical connection with the UK means British nationals or long-term residents will find the transition to Malta easy and familiar, especially in terms of language, business practices, and lifestyle. This sense of familiarity makes Malta an attractive option for those who want to maintain a connection to British culture while benefitting from a more favourable tax regime.

2.    Tax Efficiency for Global Income

Malta’s tax system is a big draw, not only for Britons but for expatriates worldwide. Much like the UK’s previous non-dom system, foreign residents in Malta are only taxed on income generated within the country. Foreign income is taxed only if it’s brought into Malta, providing substantial relief from global taxation. This system is governed by the Income Tax Act (Chapter 123 of the Laws of Malta).

The Maltese tax system for resident non-domiciled individuals offers several advantages. Income and capital gains arising in Malta are fully taxed, but foreign income is only taxed when remitted to Malta, and at favourable progressive rates. Foreign capital gains remain untaxed, even if remitted. Non-domiciled individuals with foreign income exceeding €35,000 are subject to a minimum annual tax liability of €5,000, which also applies to spouses. Malta does not impose inheritance tax, and its extensive network of over 70 double taxation treaties provides relief, ensuring that individuals are not subject to double taxation on their income.

If this tax advantage sounds attractive, exploring the Malta Permanent Residence Programme (‘MPRP’) and the Global Residency Programme (GRP) could be a worthwhile step. These programmes allow individuals to remain financially efficient while enjoying the benefits of Maltese residency.

  • EU Citizenship and Freedom of Movement

    Another major benefit of choosing Malta is the opportunity to regain access to the European Union. Under the Maltese Citizenship Act (Chapter 188 of the Laws of Malta), citizens enjoy the freedom to live, work, and study in any EU member state. This is especially valuable in a post-Brexit world, where UK citizens have lost automatic access to the EU. 

    Maltese citizenship also offers visa-free access to over 180 countries, including the Schengen Area, the United States, and Canada. This global mobility is an attractive option, especially for those with international business or travel needs. If this sounds like you, you might want to explore the various routes to acquiring Maltese Citizenship. Understanding all the available options could be your next smart move toward maximising your ability to move freely around the world.
  • A Stable and Growing Economy

    Malta’s economy is stable and growing, driven by strong sectors in finance, technology, and gaming. The country offers a stable environment for both residents and investors. Coupled with political stability and an excellent quality of life, Malta is an attractive destination for those seeking not just tax advantages, but also personal and family security. 

    To boot, Malta’s real estate market is on the rise, especially in prime locations, offering excellent opportunities for property investment. The Malta Permanent Residence Programme and the Malta Global Residence Programme allows for residency through investment in property or government bonds, providing flexibility for those looking to establish a base in Malta while benefitting from its tax efficiencies.
  • Well-connected for Global Travel 

    Malta’s strategic location in the Mediterranean, along with its strong connectivity, makes it even more appealing among international residents. With a variety of airlines offering daily flights to major European cities, as well as destinations like Dubai, Malta is well-linked to the rest of the world. Additionally, the island offers a daily high-speed ferry (around 1 hour 30 minutes) to Sicily, providing easy access to mainland Europe for those who prefer land travel.
  • A Safe and Secure Living Environment 

    Malta is a relatively safe country with a low crime rate, with its capital city ranking as the best European city for wellness. This makes it an excellent option for those prioritising safety, both if you’re travelling alone or with your family.
  • Luxurious Living Options 

    For those seeking high-end living, Malta has seen a surge in luxury property developments, carefully designed to meet the needs of discerning buyers. These lifestyle projects offer exclusive residences in prime locations, enhancing Malta’s appeal as a destination for those accustomed to luxurious living.
  • English-Speaking Population 

    As one of Malta’s two official languages, English is spoken by the vast majority of the population. This makes it easy for expatriates, especially those from the UK, to communicate and integrate into Maltese society without language barriers. Malta’s bilingual landscape offers a touch of familiarity for English-speaking newcomers, adding to the comfort and convenience of living on this island.
  • Favourable Climate Malta 

    Malta basks in a warm Mediterranean climate, offering sunny summers and mild, breezy winters. This pleasant weather is a key attraction for those looking to leave behind the colder, rain-soaked seasons of Northern Europe.
  • Quality Schooling and Healthcare 

    Malta offers excellent educational and healthcare systems. State schooling is free, and there is a wide selection of affordable private schools to choose from. School fees for private education remain reasonable compared to other European countries. Additionally, healthcare is provided free of charge to EU citizens at public hospitals and facilities, with a range of private healthcare options also available at competitive prices.
  • Wealth Management Hub for Non-UK Domiciled Individuals

    Malta is an appealing jurisdiction for wealth management, offering investment structures like trusts and foundations that provide tax advantages and strong asset protection, making them ideal for HNWIs, including non-UK domiciled individuals. Its legal system, blending UK familiarity with local and EU regulatory certainty, adds to its stability and attractiveness.

Malta’s Citizenship and Residency Programmes: Quick, Straightforward, and Multi-Generational

While several European countries offer similar citizenship or residency programmes targeted at foreign nationals, Malta’s unique combination of factors—including its strategic location, business-friendly environment, and historical ties to the UK—make it a cut above the rest.

The Maltese Citizenship by Investment programme, regulated by the abovementioned Maltese Citizenship Act is well-known for its efficiency. Eligible applicants can obtain citizenship within a relatively short time, provided they meet the investment requirements. For those keen to secure a second citizenship quickly, the process is very efficient, making it even more convenient. The MPRP and GRP also offers a fast-track route to residency, making it a great option for those who are after a flexible and easy solution.
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What is more, Malta’s citizenship and residency programmes allow for the inclusion of family members, ensuring that spouses, children, and even parents and grandparents can benefit from EU citizenship. This flexibility makes it a sustainable choice for families planning for the long term, offering a path to financial and personal security for generations to come.

Honouring Long-Standing Ties While Looking Ahead

To sum up, as the UK moves forward with its plans to phase out non-dom status, the decision marks a shift in the country’s tax policy, creating new challenges for HNWIs, especially those who have relied on the benefits of this system. For those looking to protect their financial interests while maintaining their current lifestyle, Malta is emerging as a strong and appealing alternative that promises both continuity and security.

The island nation’s strong ties to the UK, combined with its advantageous tax regime and EU membership, position it as a natural choice for those looking to preserve their wealth and secure a high quality of life. For British citizens and foreign nationals alike, Malta provides a smooth and attractive alternative for a better future.

To learn more about Malta’s offerings, contact DZ Advisory. We will evaluate your needs and walk you through the Malta Permanent Residence Programme, the Malta Global Residence Programme, and Citizenship by Investment Programme to see how they can serve you in safeguarding your financial future.

If you would like to receive more information, please provide us with your contact details and one of our team members shall be in contact with you promptly.

 is currently preparing a completely new programme that aims to attract third-country nationals who are start-up investors wishing to permanently reside here, subject to achieving the required and legal criteria to successfully establish a fruitful business for Malta. This new permit should entice entrepreneurs to invest and register their start-ups in Malta, bringing along their new and innovative ideas which will help shape the future of the Maltese industries and economy.

The Agency is currently preparing a completely new programme that aims to attract third-country nationals who are start-up investors wishing to permanently reside here, subject to achieving the required and legal criteria to successfully establish a fruitful business for Malta. This new permit should entice entrepreneurs to invest and register their start-ups in Malta, bringing along their new and innovative ideas which will help shape the future of the Maltese industries and econo

This Publication only intends to purport general information and is not intended to be a definitive or a comprehensive analysis of the subject and should not be acted upon or deemed to be considered as advice. DZ Advisory accepts no liability for any loss occasioned to any person acting or refraining from action as a result of any material in this publication.