As governments across Europe compete to attract internationally mobile entrepreneurs, executives and high net worth individuals, several jurisdictions now offer highly differentiated residence and tax frameworks. The duration of these regimes has become an increasingly important factor for individuals considering long-term relocation and wealth structuring.
Italy: One of Europe’s longest regimes
Italy continues to stand out through its special regime for new residents under Article 24-bis TUIR. Qualifying individuals relocating to Italy may elect to pay a fixed annual substitute tax on foreign-source income instead of ordinary Italian worldwide taxation.
One of the regime’s key attractions is its duration: it may apply for up to 15 consecutive tax years, making it one of the longest preferential inbound tax regimes in Europe.
Recent reforms increased the annual fixed tax amount for new entrants from 2026 onwards, reportedly to approximately €300,000 annually for the principal applicant. Italian-source income remains taxable under ordinary Italian rules.
Italy separately offers the “impatriate” worker regime for employed and self-employed individuals relocating to Italy. Following reforms under Legislative Decree 209/2023, qualifying individuals may benefit from partial exemption on Italian employment or professional income for five years, with limited extension possibilities in certain cases involving dependent children or residential property acquisition.
United Kingdom: A short transitional model
The United Kingdom abolished its historic non-dom regime from April 2025 and replaced it with the new Foreign Income and Gains (FIG) regime.
Under the new framework, qualifying individuals who have not been UK tax resident for a substantial prior period may benefit from exemption on most foreign income and gains for up to four consecutive UK tax years after becoming UK resident.
This represents a major reduction compared to the historic non-dom framework, which in practice could benefit some individuals for significantly longer periods.
The UK therefore now operates one of the shorter inbound relief models among major European financial centres.
France: Executive-focused relief
France’s impatriate regime under Article 155 B of the French Tax Code is principally designed for executives, employees and specialists relocating to France.
The regime can provide exemptions on qualifying employment income and certain foreign-source income streams. In most cases, the regime applies until 31 December of the eighth calendar year following arrival in France.
Although attractive for internationally mobile executives, the French system is more employment-oriented and technically structured than Italy’s lump-sum foreign income regime.
Malta: Remittance basis flexibility
Malta operates a remittance basis regime for individuals who are resident but not domiciled in Malta.
Foreign-source income is generally taxable only if remitted to Malta, while foreign capital gains may remain outside Maltese taxation even when remitted. Unlike some jurisdictions, Malta’s framework is not strictly limited to a short fixed-duration incentive period and can potentially apply over a long-term residence horizon, subject to residence status, domicile position and ongoing compliance with applicable residence programme conditions.
Malta therefore remains attractive for individuals seeking flexibility rather than a short-term incentive window.
Cyprus: Long-term Non-Dom advantages
Cyprus has become increasingly attractive through its “non-domiciled” tax resident framework.
Individuals who become Cyprus tax resident but are not Cyprus-domiciled may benefit from exemption from Special Defence Contribution on dividends and interest income for up to 17 years.
Cyprus also offers favourable treatment for many foreign investment structures and certain capital gains, making it attractive for entrepreneurs, investment managers and internationally mobile families seeking medium-to-long term planning stability.
Monaco: Permanent structural attraction
Monaco differs fundamentally from the other jurisdictions because it does not operate a temporary inbound tax incentive regime.
For most residents, Monaco does not levy personal income tax, capital gains tax or wealth tax. Accordingly, there is no fixed “duration” because the position derives from Monaco’s domestic tax system itself rather than from a temporary preferential regime.
The principal exception remains French nationals, who are generally subject to French taxation under the France-Monaco bilateral arrangements unless historic exemptions apply.
For many internationally mobile families, Monaco’s attraction lies in long-term stability, legal certainty, security, banking infrastructure and international lifestyle rather than temporary tax incentives alone.
At Rosemont International, we assist internationally mobile individuals and families with residence planning, cross-border structuring, fiduciary services and coordination with international tax and legal advisers across multiple jurisdictions.
For more information, please contact office@rosemont-mc.com
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