The UK’s non-domiciled tax regime has been fundamentally reformed. From April 2025, the remittance basis of taxation for non-doms was replaced with a new four-year foreign income and gains (FIG) regime, and from 2026 the inheritance tax framework shifts to a residence-based test. For wealthy individuals who have relied on the UK’s non-dom status to shield offshore income, the window to act is narrowing.
Mirabello Consultancy has seen a significant increase in enquiries from UK-based HNW individuals exploring Caribbean citizenship by investment as part of their exit strategy. This guide explains why Caribbean CBI is one of the most effective tools for wealth protection in the post-non-dom era.
- Remittance basis abolished: From April 2025, the remittance basis is no longer available. All UK residents are taxed on worldwide income after four years of residence.
- New FIG regime: A four-year exemption on foreign income for new UK arrivals replaces the old system. After four years, worldwide income is fully taxable.
- IHT shift: Inheritance tax moves to a residence-based test. Ten years of UK residence triggers UK IHT on worldwide assets; the tail extends ten years after departure.
- Trust protections reduced: Excluded property trusts lose much of their shielding for UK residents.
UK Non-Dom Exit Strategy 2026: Caribbean CBI as a Wealth Protection Tool
The UK’s non-domiciled tax regime has been fundamentally reformed. From April 2025, the remittance basis of taxation for non-doms was replaced with a new four-year foreign income and gains (FIG) regime, and from 2026 the inheritance tax framework shifts to a residence-based test. For wealthy individuals who have relied on the UK’s non-dom status to shield offshore income, the window to act is narrowing.
Mirabello Consultancy has seen a significant increase in enquiries from UK-based HNW individuals exploring Caribbean citizenship by investment as part of their exit strategy. This guide explains why Caribbean CBI is one of the most effective tools for wealth protection in the post-non-dom era.
What Changed with UK Non-Dom Tax Rules?
The Spring Budget 2024 announced the end of the non-dom regime as it had existed for over 200 years. The key changes taking effect in 2025–2026 include:
- Remittance basis abolished: From April 2025, the remittance basis is no longer available. All UK residents are taxed on worldwide income after four years of residence.
- New FIG regime: A four-year exemption on foreign income for new UK arrivals replaces the old system. After four years, worldwide income is fully taxable.
- IHT shift: Inheritance tax moves to a residence-based test. Ten years of UK residence triggers UK IHT on worldwide assets; the tail extends ten years after departure.
- Trust protections reduced: Excluded property trusts lose much of their shielding for UK residents.
For current non-doms who have been in the UK for more than four years, these changes mean a substantial increase in tax liability. The strategic response for many is to leave the UK before the full IHT tail takes effect — and a Caribbean second passport provides the means to do so.
Considering a Caribbean programme? Speak to our experts for personalised guidance on programme selection, family inclusion, and application strategy.
Why Caribbean CBI for UK Non-Dom Exit?
Caribbean citizenship by investment offers UK non-doms a practical, fast, and tax-efficient exit route. Here is why it has become the preferred option for many Mirabello clients:
Zero Personal Income Tax
All five Caribbean CBI nations — Antigua, St. Kitts, Dominica, Grenada, and St. Lucia — impose no personal income tax, no capital gains tax, no inheritance tax, and no wealth tax on their citizens. For a UK non-dom with significant offshore assets, this represents a complete tax shield.
Fast Processing (3–6 Months)
Unlike European residency programmes that take 12–18 months, Caribbean CBI delivers a second passport in 3–6 months. This speed is critical for non-doms who need to establish an alternative tax residency before the IHT tail extends further.
No Residency Requirement
Caribbean CBI does not require you to live on the island. You can obtain citizenship and a passport without relocating, giving you maximum flexibility in choosing your primary residence — whether that is Dubai, Switzerland, Singapore, or the Caribbean itself.
Visa-Free Access to 130–150+ Countries
Caribbean passports provide visa-free access to the Schengen Area, the UK, Singapore, Hong Kong, and many other destinations. Combined with a British passport, a Caribbean second passport creates a powerful travel portfolio.
Tax Planning: Breaking UK Tax Residency
Simply obtaining a Caribbean passport is not enough. To stop UK tax liability, you must also break UK tax residency under the Statutory Residence Test (SRT). The key requirements are:
- Spend fewer than 16 days in the UK per year (if you were previously resident and have a UK home) or fewer than 46 days (if you were previously resident with no UK home)
- Be tax resident in another country (the Caribbean or a third jurisdiction)
- Establish genuine economic ties outside the UK
For the IHT tail specifically, the new residence-based test means you must remain non-UK-resident for up to ten years after departure before worldwide assets are fully outside UK IHT. Early departure is therefore critical to start the clock.
For more on Caribbean tax benefits, see our comprehensive guide to tax benefits of second citizenship in 2026.
Cost Comparison: Caribbean CBI Options for UK Non-Doms
| Programme | Min. Investment | Visa-Free Countries | Key Advantage |
|---|---|---|---|
| Dominica | $200,000 | 136 | Lowest cost |
| Antigua & Barbuda | $230,000 | 144 | Premium lifestyle |
| Grenada | $235,000 | 140 | US E-2 visa treaty |
| St. Lucia | $240,000 | 140 | Scenic lifestyle |
| St. Kitts & Nevis | $250,000 | 148 | Strongest passport |
Need help choosing the right path? Book a free consultation with Mirabello Consultancy and let our team guide you through every step.
Case Study: UK Non-Dom to Antigua Citizen
Consider a typical scenario: a UK-based entrepreneur of Middle Eastern origin who has been living in London for 12 years under the non-dom regime. With approximately £5 million in offshore assets held through a trust structure, the new tax rules would expose both the trust income and the worldwide estate to UK taxation.
By obtaining Antigua citizenship through CBI ($230,000 donation route), establishing tax residency in Antigua (or a combination of Antigua and Dubai), and breaking UK tax residency under the SRT, the individual can legally shield offshore assets from UK income tax and begin the IHT tail countdown. The entire process, from initial consultation to passport in hand, can be completed in under six months.
Combining Caribbean CBI with Other Jurisdictions
Many UK non-doms use Caribbean citizenship as part of a multi-jurisdiction strategy. Common combinations include:
- Caribbean CBI + UAE Golden Visa: Zero tax in both jurisdictions, with the UAE providing a physical base and the Caribbean providing the passport. Explore the UAE Golden Visa programme.
- Caribbean CBI + Portugal NHR: Use Portuguese residency for EU access and Caribbean citizenship for global mobility
- Caribbean CBI + Nevis LLC: Combine personal citizenship with a Nevis LLC for maximum asset protection
View all available programmes on our citizenship by investment hub and golden visa hub.
Timeline for UK Non-Doms: Act Now
The IHT tail started accumulating from April 2025. Every year of continued UK residence adds another year to the ten-year tail. For non-doms who have been in the UK for more than a decade, the earliest possible departure date reduces long-term tax exposure significantly. With Caribbean CBI processing taking 3–6 months, applications submitted in early 2026 can result in passports by mid-2026 — enabling a tax year 2026/27 departure.
For guidance from HMRC on non-dom changes, consult the official UK government publication. For programme-specific guidance, ECCIRA provides the regulatory framework for all Caribbean CBI programmes.
Frequently Asked Questions
Can I still use the non-dom regime in 2026?
The traditional remittance basis is abolished from April 2025. A new four-year FIG regime is available for new arrivals only. Existing non-doms who have been in the UK for more than four years are now taxed on worldwide income.
How fast can I get a Caribbean passport?
Most Caribbean CBI programmes process applications in 3–6 months. St. Kitts and Grenada recently reduced processing times. Dominica and Antigua also typically deliver within this timeframe.
Do I need to live in the Caribbean to benefit from zero tax?
You need to establish tax residency somewhere with favourable rates. The Caribbean, the UAE, or a combination are popular choices. Simply holding a Caribbean passport without breaking UK tax residency does not eliminate UK tax liability.
Which Caribbean programme is best for UK non-doms?
It depends on your priorities. St. Kitts offers the strongest passport (148 visa-free countries). Grenada offers the US E-2 visa treaty. Dominica is the most affordable. Mirabello Consultancy can advise on the optimal choice.
How do I start planning my exit?
Contact Mirabello Consultancy for a confidential consultation. We work with UK-based tax advisers and international structuring specialists to design a comprehensive exit plan. Book your free consultation today.
Not Sure Which Programme Is Right for You?
Mirabello Consultancy's experts match each client to the optimal programme based on budget, timeline, nationality, and goals. Book your complimentary consultation today.
View all available programmes on our citizenship by investment hub and golden visa hub.
The IHT tail started accumulating from April 2025. Every year of continued UK residence adds another year to the ten-year tail. For non-doms who have been in the UK for more than a decade, the earliest possible departure date reduces long-term tax exposure significantly. With Caribbean CBI processing taking 3–6 months, applications submitted in early 2026 can result in passports by mid-2026 — enabling a tax year 2026/27 departure.
For guidance from HMRC on non-dom changes, consult the official UK government publication. For programme-specific guidance, ECCIRA provides the regulatory framework for all Caribbean CBI programmes.


