Starting April 2025, the UK is introducing significant changes to its tax framework for non-domiciled individuals. These reforms will bring heightened tax obligations and increased complexity, prompting a need for proactive and strategic financial planning.
For those affected, now is the time to reevaluate their position. For some, Malta could provide the optimal solution.
Key Changes in the UK Tax Landscape
1. Global Taxation for Non-Doms
From April 2025, non-UK domiciliaries who have been UK residents for over four years will be taxed on worldwide income and gains, replacing the existing remittance basis of taxation.
2. Trust Protections Withdrawn
The new framework introduces taxation on trust income and gains as they arise for UK-resident settlors or transferors, effectively dismantling previous protections.
3. Inheritance Tax Scope Expands
Global assets of non-doms will fall under UK inheritance tax (IHT) after 10 years of residency, with this rule applying for a decade post-departure.
4. Temporary Repatriation Facility (TRF)
A reduced tax rate of 12% on pre-April 2025 foreign income and gains is available for limited repatriation during 2025–2027, providing relief for some but with strict conditions.
5. Limited Benefits for Newcomers
Non-doms entering the UK after a 10-year absence will see restricted benefits under the Foreign Income and Gains (FIG) regime, available for up to four years.
6. Personal Allowances Removed
FIG regime participants will lose access to personal tax allowances and capital gains tax exemptions.
Malta: A Compelling Alternative
Amid these shifts, Malta is a highly attractive option for those seeking a stable and tax-efficient jurisdiction. Its Resident Non-Domiciled (Res Non-Dom) regime is straightforward and beneficial:
– Income Earned in Malta: Taxed in full.
– Foreign Income: Taxed only if remitted to Malta, with competitive progressive rates.
– Foreign Capital Gains: Exempt from taxation, even if remitted.
Moreover, Malta imposes no inheritance tax, and its extensive network of over 70 double taxation treaties ensures robust international tax planning.
The Global Residence Programme (GRP): Tailored for High-Net-Worth Individuals
For non-EU nationals, Malta’s Global Residence Programme (GRP) offers an elegant solution:
– Flat Tax Rate: 15% on foreign income remitted to Malta (with an annual minimum tax of €15,000).
– Tax-Free Capital Gains: A significant advantage for global investors.
– Residency Benefits: Enhanced access to Europe through Schengen mobility.
– Asset Protection: Trusts and foundations supported within a business-friendly framework.
Why Malta?
Malta’s blend of British-influenced legal systems, EU compliance, and strategic tax incentives make it an ideal jurisdiction for high-net-worth individuals, retirees, and global business professionals. Coupled with its Mediterranean lifestyle and stable economic environment, Malta is a destination where opportunity meets quality of life.
Take Control of Your Financial Future
The upcoming UK tax reforms signal a time for action. Whether you’re seeking to safeguard your wealth or explore new opportunities, the key lies in making informed decisions now.
At CLA Malta, we specialise in helping clients navigate these changes and optimise their global tax strategies. Let us help you turn this challenge into an opportunity.
Contact us today and start planning for a future that’s built differently.