The UK Non-Dom Regime Is Gone. Malta’s Is Not.

On 6 April 2025 the UK ended a tax regime that had stood for about two hundred years.

Until then, a UK resident who was not domiciled in the UK could keep foreign income and gains outside the UK tax net unless they brought the money in. That is finished.

What replaced it is much narrower. New arrivals get four years of relief on foreign income and gains, and only if they were not UK resident for the previous ten years. There is a temporary window to bring old foreign money onshore at 12% for 2025/26 and 2026/27, rising to 15% for 2027/28. And inheritance tax now follows residence, so worldwide assets come into charge after a long enough stay.

People did not wait to see how it settled.

By October 2025 at least 1,800 non-doms had already left, about half again as many as the government’s own forecaster predicted. Companies House logged 3,790 directors changing to non-UK addresses between October 2024 and July 2025, up 40% on the year before. April 2025 alone set a record at 691.

Now the part that gets less attention.

Malta’s equivalent regime has not changed.

Someone resident in Malta but not domiciled there is taxed on Maltese income, and on foreign income they bring into Malta. Foreign income kept outside Malta is not taxed in Malta.

And foreign capital gains are exempt even when they are brought in. That is the unusual bit. Most remittance systems tax gains the moment the money lands.

There is no deemed domicile clock either. Malta has no rule that flips you to domiciled after a set number of years, so the treatment does not run out on a timetable. It does depend on your circumstances continuing to hold, which is a genuine condition rather than a formality.

There is a minimum annual tax once foreign income passes a threshold. The figure we work to is 5,000 euros where foreign income is above 35,000 euros, and we confirm the current figure for the year rather than quoting from memory.

Compare the alternatives and the gap is wide. Italy charges a flat 300,000 euros a year from January 2026 and runs for fifteen years. Greece charges 100,000 euros a year plus a 500,000 euro investment. Portugal’s replacement is limited to certain professions and lasts ten years. The UAE charges nothing and sits outside the EU.

For a yacht owner that last point is not about lifestyle. An EU base and an EU flag are what keep the VAT and customs position workable in the Mediterranean.

Which brings up the thing most owners are never asked. The yacht is usually structured by one firm and the owner is advised by another. A structure can be efficient all the way up and still lose the benefit at the last step, when money finally reaches the person.

That is one question, not two.

For the full picture, including both residency programmes and what they cost, read our guide: Malta Residency and Tax Planning for International Yacht Owners.

Zenco Partners handles the vessel’s structure and the owner’s own tax position in one relationship. To talk it through, email info@zencopartners.com or message us on WhatsApp at +356 7921 2598.

This article is for informational purposes only and does not constitute legal, tax, or financial advice. Professional advice should be obtained before taking any action based on the contents of this article.