Italy vs Greece vs Malta vs Cyprus: Europe's Non-Dom Tax Regimes Compared (2026)

What are the four main non-dom regimes in Europe in 2026?

The four regimes most often compared by internationally mobile investors are Italy's new-resident substitute tax, Greece's Article 5A alternative taxation, Malta's remittance-basis programmes and Cyprus's non-domicile regime. Each lets a person who moves tax residence pay far less than the ordinary rate on income earned abroad, and each works differently.

The practical consequence is that the right regime depends less on the headline number and more on what kind of income you have and how much of it you actually spend where you live. A fixed fee rewards the investor who earns a great deal and remits freely. A remittance basis rewards the investor who earns a great deal and spends a modest part of it. An exemption by income type rewards the investor whose wealth throws off dividends and interest.

How does Italy's €300,000 flat tax work?

Italy's regime is Article 24-bis of the Income Tax Code. A new Italian tax resident pays one substitute tax on all foreign-source income instead of ordinary progressive tax on it. For people who transfer tax residence to Italy from 1 January 2026 the amount is €300,000 a year, set by the 2026 budget law (Law 199/2025). The Agenzia delle Entrate records the earlier tiers as €100,000 up to 10 August 2024 and €200,000 from that date.

You qualify if you were not an Italian tax resident for at least nine of the ten tax periods before the option takes effect. Family members can be covered for €50,000 each a year. The option renews automatically each year, ends after fifteen years, and is lost if you do not pay on time or move tax residence elsewhere. You may also exclude specific foreign states from the substitute tax, which matters if you want income from one jurisdiction to remain taxed there under a treaty.

Italian-source income is taxed normally, at IRPEF rates reaching 43% before regional and municipal surtaxes. Under the regime, foreign real estate is exempt from IVIE and foreign financial assets from IVAFE, and the Italian inheritance and gift tax charge is confined to Italian assets. Our dedicated guide to the €300,000 Italian flat tax sets out the full mechanics.

How does Greece's €100,000 regime work?

Greece's regime is Article 5A of Law 4172/2013, in force since tax year 2020. An individual transferring tax residence to Greece pays €100,000 a year on all foreign-source income, plus €20,000 for each family member included, for up to fifteen years. You must not have been Greek tax resident for seven of the previous eight years, and you must invest at least €500,000 in Greek real estate, businesses, transferable securities or shares in Greek entities within three years. Holders of the Greek golden visa are exempt from that investment condition, because the golden visa already requires one.

The 2026 changes were procedural. Article 94 of Law 5313/2026 removed the fixed 31 March application deadline and moved payment to a single instalment due by the last working day of December. AADE Decision A.1147/2026, dated 17 July 2026, then set the filing rules: applications go through myAADE, and you apply by 30 September of the year of arrival to be included from that year, or by 30 September of the following year to be included from the next. Those who move tax residence after 2 July apply for the following year. Confirm the dates with the Greek tax authority before relying on them, as the framework is new.

Greek-source income stays under ordinary rates reaching 44%, and no credit is given for foreign tax already paid. The regime also exempts foreign movable property from Greek inheritance and gift tax while it applies. Our guide to Greek golden visa tax benefits covers the wider picture.

How does Malta's remittance-basis regime work?

Malta taxes people who are resident but not domiciled on their Malta-source income and on foreign income received in Malta. Foreign income that stays abroad is not taxed in Malta, and foreign capital gains are not taxed at all, whether or not they are remitted. Malta's top personal rate is 35% on income above €60,000, but a non-dom who keeps most of their wealth offshore rarely meets it.

On top of this ordinary basis, Malta runs residence programmes that fix the rate. Under the Global Residence Programme (GRP), open to non-EU, non-EEA and non-Swiss nationals, foreign income received in Malta is taxed at a flat 15%, with a minimum of €15,000 a year that covers the applicant, spouse and minor children. That minimum is a floor, not a cap, and it bites below roughly €100,000 of remitted income. Other income, including Malta-source income, is taxed at a flat 35%. The programme needs a qualifying home: bought from €220,000 in Gozo or the south of Malta, or €275,000 elsewhere, or rented from €8,750 or €9,600 a year. The application fee is €6,000, or €5,500 for a home bought in the south of Malta. The status ends if you spend more than 183 days in any other single jurisdiction in a calendar year.

EU, EEA and Swiss nationals cannot use the GRP, but they have a parallel residence programme with the same 15% remittance rate, and they are of course free to live in Malta without a permit. Malta also has no wealth tax, no inheritance or gift tax, and no separate capital gains tax. Our guide to the Malta GRP explains the mechanism in detail, and the programme page lists the current requirements.

What changes in Malta on 1 January 2027?

From 1 January 2027 Malta replaces the Global Residence Programme, the Residence Programme, the Malta Retirement Programme and the UN Pensioners Programme with a single Individual Tax Programme, under Legal Notice 195 of 2026, published in the Government Gazette on 14 July 2026. The 15% rate on foreign income remitted to Malta does not change. Nearly everything around it does.

The transitional rule is the part that matters most for anyone deciding now. Existing beneficiaries, and applicants whose complete application is received by the Commissioner for Tax and Customs on or before 31 December 2026, keep the current thresholds until 31 December 2031. Renewals after that date fall under the new rules.

The deadline is real, but it is not a reason to rush a decision that does not fit. A €35,000 minimum remains modest next to Italy's €300,000, and for many investors Malta stays the lowest fixed cost of the four. What the deadline does change is the price of waiting: the qualifying home alone rises by €425,000 to €480,000 when buying. We explain the difference between a purchase and a rental in our guide to Maltese tax rates.

Is 31 December 2026 relevant to your timetable? Book a complimentary consultation and we will check whether a complete application can be lodged in time and whether the programme suits your income profile at all.

How does Cyprus's non-dom regime work?

Cyprus does not charge a fee for non-dom status. A person who is tax resident in Cyprus but not domiciled there is exempt from the Special Defence Contribution (SDC) on dividends and interest, wherever those are earned, until they have been Cyprus tax resident for 17 of the last 20 years. Domiciled residents pay SDC on dividends at 5% for tax years from 2026 (17% on profits up to 2025, with grandfathering) and on interest at 17%, or 3% on certain government and listed bonds.

Residence is easy to establish. You are tax resident if you spend more than 183 days in Cyprus, or you can use the 60-day rule: at least 60 days in Cyprus, a permanent home owned or rented there, business, employment or a directorship with a Cyprus tax-resident company, and no more than 183 days in aggregate in any one other state. From 1 January 2026 the former condition that you must not be tax resident anywhere else no longer applies. That change makes the rule easier to meet, and it also raises the risk of being resident in two places at once, so treaty analysis matters more than it did.

Other income is taxed at ordinary rates, which for 2026 are 0% on the first €22,000, then 20%, 25% and 30% in bands, and 35% above €72,000. There is no wealth tax and no inheritance tax, and capital gains tax applies only to Cyprus real estate, so gains on shares and other securities are exempt. The 2026 reform also introduced a paid option to continue the exemption after the 17 years; confirm its current terms with the Cyprus Tax Department before relying on it. See our guides to Cyprus residency tax benefits and the 60-day rule.

What does each regime actually cost?

The cost depends on the shape of your income, so there is no single answer, but the formulas make the comparison simple. The table below applies each regime's rule to one illustrative investor: a single applicant with substantial foreign investment income who remits €200,000 a year to Malta to live on. It is an illustration of how each rule works, not a forecast and not tax advice.

Four conclusions follow. Italy is the largest fixed sum of the four at every income level, and its price only makes sense where ordinary tax on the same income would exceed €300,000. Greece is the lowest fixed fee but ties up capital. Malta is the lowest total cost for an investor who spends modestly relative to wealth, since the tax scales with remittances rather than income. Cyprus is the lowest cost of all for an investor whose income is dividends and interest, but it gives no comparable shelter for other income, such as employment or trading profits, which is taxed at up to 35%.

For a family the order shifts. Four dependants add €200,000 a year in Italy and €80,000 in Greece. In Malta the minimum covers the spouse and minor children, and in Cyprus there is no per-person charge at all.

Who is eligible for each regime?

All four regimes are open to non-EU and EU nationals alike, with one exception: Malta's Global Residence Programme is for non-EU, non-EEA and non-Swiss nationals, and EU, EEA and Swiss nationals use the parallel residence programme, which becomes a separate status within the Individual Tax Programme from 2027.

Every one of these tests looks at tax residence, not at where you hold a passport. Moving tax residence has to be real. Electing a regime while continuing to live, work and keep a family home in the country you left invites a challenge from that country, and it is decided on the facts. Our guide to establishing tax residency sets out the evidence that counts.

Which immigration route sits underneath each regime?

None of the four tax regimes is a residence permit. If you hold an EU, EEA or Swiss passport you need no permit in any of the four countries. If you do not, you need a separate immigration route, and it is worth choosing the two together.

The Greek combination is the only one where the two interact directly: a golden visa holder is exempt from the €500,000 investment, so the residence investment doubles as the tax condition. The Greek and Italian permits carry no stay requirement, but a tax regime does. To keep Italian or Greek tax residence you have to be resident there, which in practice means spending the greater part of the year in the country. Residence for immigration purposes and residence for tax purposes are separate questions, and confusing them is the most common planning error we see.

What are the risks and weak points of each regime?

Every regime here has shown that the state can change the price. That is the single most useful fact about the category, and it is the reason to prefer a plan that survives a repricing.

Beyond price, each has its own soft spot. Italy asks the most and has moved the most. Greece requires capital in Greek assets, and its procedure has only just been rewritten, so practice is newer than in Italy. Malta rewards you only if you control what you remit, and a home you must own or rent at a much higher threshold from 2027. Cyprus protects dividends and interest but not other income, and its 17-of-20-year clock means the benefit eventually ends.

A point common to all four: they are not a way to avoid the tax authority of the country you leave. Exit taxes, controlled-foreign-company rules and treaty tie-breakers in your current country often matter more than the headline figure. Plan the departure with the same care as the arrival.

What about Portugal and Switzerland?

Portugal and Switzerland are the two other names that appear in these comparisons, and neither is a like-for-like alternative. Portugal closed its non-habitual resident regime to new entrants in 2024. Its replacement, the IFICI regime, is aimed at specific qualifying activities, with a 20% flat rate on Portuguese employment and professional income, and does not cover pensions. Our guide to Portugal's IFICI explains who can still use it, and the Portuguese golden residence permit page covers the residence side. Switzerland offers expenditure-based taxation, which is set by canton and follows its own rules, so we treat it separately.

Which regime fits which investor?

Choose by the shape of your income, how much of it you spend locally, and how much capital you are willing to commit, not by the headline fee.

• Very large, mixed foreign income, freely remitted, no wish to invest locally: Italy. You pay for certainty and simplicity, and you accept the repricing risk.
• Large foreign income and an appetite for Greek property or a Greek golden visa anyway: Greece. The €500,000 is then an asset, not a fee.
• Substantial wealth, modest spending, and income you can leave offshore: Malta, ideally with an application received by 31 December 2026.
• Wealth that produces mainly dividends and interest, or a founder with a Cyprus company: Cyprus.
• Large family: favour Malta or Cyprus, where the per-person charge is absent or small.
• EU, EEA or Swiss passport holder: all four are open to you, but the Malta GRP is not; you would use the parallel EU status.

Unsure which line of that list describes you? Speak to Mirabello Consultancy before you move tax residence, because the exit from your current country is usually harder than the arrival.

Official guidance for each regime is published by Italy's Agenzia delle Entrate, Greece's Independent Authority for Public Revenue, Malta's legislation portal (Legal Notice 195 of 2026) and PwC's Cyprus tax summaries. Read them, or have them read for you, before you commit.

For a broader look at where else to base yourself, see our golden visa comparison and our analysis of Malta versus Cyprus residency by investment.