Tax Decisions Compared

Which European flat tax regime is best for UK leavers?

Answered by Jordan Onraet-Wells, Founder & Chartered Tax Adviser (CTA). Published 9 August 2026. Last reviewed 9 August 2026.

The short answer

For most UK leavers Cyprus is the cheapest of the four Mediterranean regimes: its non-dom rules take tax on dividends and interest to nil for up to 17 years for a running cost of a few thousand euros, not six figures. Italy's flat tax, raised to EUR 300,000 a year for moves from 1 January 2026, is now only worth it for foreign incomes comfortably into seven figures. Greece sits in between with a EUR 100,000 lump sum for investors and a separate flat 7% route for foreign pensioners, and Malta suits people who can hold income offshore and remit only what they spend. Match the regime to your income type, not the brochure.

Italy's Article 24-bis flat tax costs EUR 300,000 a year for residence transfers from 1 January 2026 (plus EUR 50,000 per family member), covers all foreign income and gains, and runs up to 15 years.
Greece's Article 5A charges EUR 100,000 a year but requires a EUR 500,000 investment in Greece within three years; Article 5B taxes foreign pensioners at a flat 7% on all foreign income for up to 15 years.
Cyprus has no lump sum: a non-dom resident pays 0% Special Defence Contribution on dividends and interest for up to 17 years, with only the GHS levy at 2.65% capped at roughly EUR 4,770 a year.
Malta taxes resident non-doms only on Malta income and remitted foreign income, and never taxes foreign capital gains even if remitted, subject to a EUR 5,000 minimum tax where foreign income is at least EUR 35,000 and not fully remitted.
All four regimes are worthless until you have genuinely broken UK residence under the Statutory Residence Test, and the five-year temporary non-residence and 10-year IHT tails follow you to any of them.

Match the regime to your income

The four regimes solve different problems at very different prices. Company owners and investors living on dividends and interest usually land on Cyprus, where the non-dom regime costs a few thousand euros a year rather than six figures. Very large foreign incomes, broadly seven figures a year, land on Italy: a fixed EUR 300,000 covering unlimited foreign income and gains is a genuine ceiling, and nothing else offers that certainty at scale. Substantial wealth below Italy's price point points to Greece's Article 5A at EUR 100,000 a year, if the EUR 500,000 Greek investment condition suits you. Retirees point to Greece's flat 7% route or Cyprus's flat 5% rate on foreign pension income. And people who can keep capital offshore and remit only living costs point to Malta, whose remittance basis never taxes foreign capital gains at all, even when the proceeds are brought in.

2026 repriced the market

Italy tripled its entry price in under two years: EUR 100,000 originally, EUR 200,000 for transfers from 11 August 2024, and EUR 300,000 from 1 January 2026 under the 2026 Budget Law, with earlier electors grandfathered at their original rate. Cyprus's January 2026 reform deliberately kept its non-dom offer intact and added paid five-year extensions at EUR 250,000 each, while Greece held its lump sum at EUR 100,000. One caveat sits under Greece: the UK-Greece treaty dates from 1953 and is one of the UK's oldest and narrowest, so a Greek plan leans hardest on an unambiguous SRT exit. Full country detail sits in our guides to moving to Italy and moving to Cyprus.

The UK exit is the same whichever you choose

None of these regimes touches your UK bill until you are non-resident under the Statutory Residence Test, and the UK departure checklist is identical for all four: break residence, claim split-year treatment, file the P85 and a final return, and keep paying UK tax on UK rent and UK property gains. Two tails follow you anywhere: return within five years and the temporary non-residence rules can tax gains realised abroad in your year of return, and since 6 April 2025 the residence-based inheritance tax tail can run for up to 10 years after leaving. Horizon advises on the UK side on fixed fees agreed upfront and coordinates the local adviser in Italy, Greece, Cyprus or Malta; if you are still choosing, a free clarity call is the quickest way to narrow it down.

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Sources and further reading

This is general information for the 2026/27 UK tax year, not personal tax advice; speak to a Chartered Tax Adviser about your own position.

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