The verdict: match the regime to your income, not the brochure
These four regimes solve different problems at very different prices, so the comparison is really about who you are. As a rule of thumb:
- Company owners and investors living on dividends and interest: Cyprus. The non-dom regime takes Special Defence Contribution on that income to nil for up to 17 years for a running cost of a few thousand euros, not six figures.
- Very large foreign incomes and gains, broadly seven figures a year: Italy. A fixed 300,000 euros that covers unlimited foreign income and gains is a genuine ceiling, and nothing else here offers that certainty at scale.
- Substantial wealth below Italy's price point: Greece's Article 5A at 100,000 euros a year, if you are willing to invest 500,000 euros in Greece within three years.
- Retirees on foreign pensions: Greece's Article 5B at a flat 7% on all foreign income, with Cyprus's flat 5% rate on foreign pension income a close and simpler second.
- People who can keep capital offshore and remit only living costs: Malta's remittance basis, which never taxes foreign capital gains at all, even when remitted.
The 2026 repricing sharpened these lines. Italy tripled its entry price in under two years (100,000 euros originally, 200,000 for transfers from 11 August 2024, 300,000 from 1 January 2026), which pushes the merely wealthy towards Greece and Cyprus, while Cyprus's January 2026 reform deliberately kept its non-dom offer intact. Price movements cut both ways, so treat any figure in this guide as the position in August 2026 and confirm it before you commit.
The four regimes side by side
The table below is the whole argument in one place. Figures are verified against PwC worldwide tax summaries, the International Bar Association's Greece guide and GOV.UK treaty pages as at August 2026.
| Feature | Italy (flat tax) | Greece (5A and 5B) | Cyprus (non-dom) | Malta (remittance and GRP) |
|---|---|---|---|---|
| Headline annual cost | 300,000 euros lump sum for moves from 1 January 2026 | 5A: 100,000 euros lump sum; 5B: 7% of foreign income | No lump sum; GHS levy 2.65% capped at roughly 4,770 euros | No lump sum; 5,000 euro minimum tax (if foreign income is 35,000 euros plus); GRP minimum 15,000 euros |
| What it shelters | All foreign income and gains (substantial shareholdings sold in the first 5 years excluded) | 5A: all foreign income; 5B: all foreign income at the 7% rate | Dividends and interest free of SDC; no Cyprus CGT on most assets other than Cyprus property | Unremitted foreign income; foreign capital gains even if remitted |
| Duration | Up to 15 years, non-renewable | Up to 15 years each | 17 years, with paid 5-year extensions at 250,000 euros each to a maximum 27 | Open-ended while resident but not domiciled; GRP while conditions met |
| Entry conditions | Not Italian tax resident in 9 of the previous 10 years | 5A: not resident 7 of 8 prior years plus 500,000 euro investment within 3 years; 5B: not resident 5 of 6 prior years, foreign pension income | Not Cyprus tax resident for 17 of the previous 20 years; residence via the 183-day or 60-day route | Resident but not Malta-domiciled; GRP: property bought for at least 275,000 euros or rented for at least 9,600 euros a year |
| Family members | 50,000 euros each per year | 5A: 20,000 euros each per year | Each person qualifies for non-dom status in their own right | Dependants can be included within a GRP application |
| Local-source income | Ordinary IRPEF rates, 23% to 43% | Ordinary Greek rates | Normal bands: 0% to 22,000 euros, then 20% to 35% | Progressive rates up to 35% |
| UK treaty | 1988 convention, in force since 1990 | 1953 convention, in force but old and narrow | 2018 convention, in force | 1994 convention, in force, MLI-modified |
Italy: certainty at 300,000 euros a year
Italy's regime for new residents (Article 24-bis, an imposta sostitutiva or substitute tax) replaces ordinary Italian tax on all foreign income and gains with one fixed annual payment. The 2026 Budget Law set that payment at 300,000 euros for anyone transferring residence from 1 January 2026, with 50,000 euros for each qualifying family member; a couple therefore costs 350,000 euros a year whether their foreign income is 500,000 euros or 50 million. Those who elected earlier are grandfathered at their original 100,000 or 200,000 euro rate for their remaining years.
You qualify if you were not Italian tax resident in at least nine of the ten years before the move, and the election runs for a maximum of 15 years with no renewal. Two carve-outs matter: gains on substantial foreign shareholdings sold in the first five years fall outside the flat tax, which catches founders planning a quick exit, and Italian-source income is always taxed at ordinary IRPEF rates of 23% to 43%. Our moving to Italy guide covers the regime and the UK exit in full. At the new price, the arithmetic is blunt: the flat tax only beats ordinary rates once the Italian tax you would otherwise pay clears 300,000 euros a year, which needs foreign income comfortably into seven figures.
Greece: the mid-priced lump sum and the 7% pensioner route
Greece runs two regimes that interest UK leavers. Article 5A is the non-dom lump sum: 100,000 euros a year covers all foreign-source income, plus 20,000 euros per family member added, for up to 15 tax years. The catches are the entry conditions: you must not have been Greek tax resident in seven of the eight years before the move, and you must invest at least 500,000 euros in Greece (real estate, a Greek business, government bonds or listed securities) within three years of applying. At a third of Italy's price it is now the value play for large foreign incomes, provided the investment condition suits you.
Article 5B is the pensioner regime: individuals with foreign pension income who move their tax residence to Greece pay a flat 7% on all their foreign-source income, not just the pension, for up to 15 years, paid in a single instalment each July. You must not have been Greek tax resident in five of the six prior years and must arrive from a country with a tax cooperation agreement with Greece, which the UK is. One genuine caveat: the UK-Greece double taxation convention dates from 1953 (GOV.UK) and is one of the UK's oldest and narrowest treaties, so if your exit is untidy and both countries claim you, the treaty gives far less help than the modern Italian, Cypriot or Maltese texts. A clean SRT break matters even more here than elsewhere.
Cyprus: the quiet winner on running cost
Cyprus does not charge an entry fee at all. A Cyprus tax resident who is not domiciled there, which covers almost every UK arrival, pays 0% Special Defence Contribution on dividends and interest for up to 17 years. The only charge on that income in practice is the GHS health levy at 2.65%, and because GHS applies only to the first 180,000 euros of income, it is capped at roughly 4,770 euros a year. The January 2026 Cyprus tax reform kept this intact and added a paid extension route: two five-year extensions at 250,000 euros each, taking the maximum window to 27 years.
Cyprus also has the most flexible residence entry: alongside the standard 183-day test, the 60-day route works with a Cyprus home, a Cyprus business or employment tie, at least 60 days on the island and no more than 183 days in any other single country. Employment and pension income are taxed under normal bands (0% up to 22,000 euros, then rates of 20% to 35%, the top rate applying above 72,000 euros), though foreign pension income is taxed by default at a flat 5% on the amount above 5,000 euros, with an annual option to use the normal bands instead. The full detail is in our moving to Cyprus guide and the dedicated Cyprus non-dom regime guide. For a company owner living on dividends, the comparison is stark: near zero in Cyprus against 100,000 euros in Greece and 300,000 in Italy.
Malta: remittance planning rather than a flat price
Malta is the odd one out because it kept the model the UK abolished in April 2025: the remittance basis. A Malta resident who is not domiciled there is taxed on Malta-source income and on foreign income actually remitted to Malta, at progressive rates up to 35%. Foreign income kept outside Malta is not taxed, and foreign capital gains are not taxed at all, even when the proceeds are brought in, which is a genuinely unusual feature. The floor is a minimum tax of 5,000 euros a year where foreign income is at least 35,000 euros and is not fully remitted to Malta.
For UK nationals, who count as third-country nationals since Brexit, the Global Residence Programme adds a packaged alternative: remitted foreign income taxed at a flat 15%, a minimum annual tax of 15,000 euros, and a qualifying property requirement of a purchase of at least 275,000 euros (less in some areas) or rent of at least 9,600 euros a year. Malta suits people whose wealth sits in appreciating assets and who can fund life on the island from a controlled level of remittances; it suits people badly if they need to bring large ordinary income onshore every year, because remitted income at up to 35% quickly overtakes the fixed costs of the other three regimes.
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, so the UK departure checklist is identical for all four: break residence under the SRT, claim split-year treatment for the year you leave, file the P85 and a final return, and keep paying UK tax on anything the UK retains, notably rent under the Non-Resident Landlord Scheme and gains on UK property reported within 60 days.
Two tails follow you to any of the four. Return to the UK within five years and the temporary non-residence rules can tax gains and certain income realised abroad in your year of return, which is fatal to a plan built on extracting dividends cheaply and coming home. And since 6 April 2025 inheritance tax is residence-based: a long-term UK resident stays exposed on worldwide assets for up to 10 years after leaving, no matter which flag is on the new tax card.
Treaties, local advice and making the call
All four countries have UK double taxation agreements in force: Italy's 1988 convention (in force since 31 December 1990), Cyprus's 2018 convention, Malta's 1994 convention as modified by the Multilateral Instrument, and Greece's 1953 convention (GOV.UK treaty collection). The first three are modern OECD-pattern treaties with proper residence tie-breakers; Greece's predates the OECD model, so Greek plans lean hardest on getting the SRT exit unambiguous. Also check how each regime treats any UK government service pension you hold, since those generally stay taxable in the UK under all four treaties.
One boundary to be clear about: Horizon advises on the UK side and coordinates with a local adviser in Italy, Greece, Cyprus or Malta for the local election, registrations and filings, because every regime above is claimed and defended under local law. Our job is making sure the UK half cannot undermine the local half. If you are still choosing between the four, model your day counts with the SRT calculator and compare the destinations side by side with our relocation comparison tool before you pick a departure date.
