Introduction Italy’s flat tax regime, widely regarded as one of Europe’s most sophisticated tools for internationally mobile wealth is evolving. For UK residents reassessing long‑term plans after the reform of the UK non‑dom system, the 2026 updates are especially significant. From January 2026 , the annual substitute tax under Article 24‑bis of the Italian Income Tax Code will increase to: €300,000 for the main applicant €50,000 for each eligible family member Rather than signalling a restriction, the change reflects Italy’s confidence in its status as a premium European jurisdiction for high‑net‑worth relocation , supported by Milan’s rapid rise as a modern financial and lifestyle hub. Why Italy’s Flat Tax Remains Among Europe’s Strongest Options for UK Movers Since its introduction in 2017, the flat tax regime has transformed Italy’s appeal to globally mobile individuals. For UK residents exploring relocation in a post–non‑dom environment, the regime offers clarity, control, and long‑term predictability. Qualifying applicants who elect the regime benefit from: A fixed annual tax on all foreign‑source income , regardless of value No ordinary Italian income tax on non‑Italian income No IVIE or IVAFE on foreign real estate or financial assets No Italian inheritance or gift tax on assets held outside Italy For families with cross‑border investments, trusts, companies, or diversified holdings, the regime offers a level of stability rarely seen elsewhere in Europe. Milan: A Growing Magnet for UK High‑Net‑Worth Relocation Over the past decade, Milan has evolved from a business centre into a European private wealth destination. Increasing numbers of UK residents, entrepreneurs, fund managers, executives, and family offices, are choosing Italy for its blend of lifestyle and legal certainty. Milan now offers: A stable legal and political environment A well‑developed private banking and advisory ecosystem High‑quality international schools and cultural institutions Direct access to the EU single market, strategically valuable post‑Brexit This combination places Milan alongside Geneva, Monaco, and Luxembourg as a leading European centre for internationally mobile families. Understanding the €300,000 Increase: Why the Regime Remains Competitive While the new €300,000 rate is a notable change, its practical impact for typical applicants is modest. Most individuals considering the regime manage: multi‑jurisdictional investment portfolios, operating companies or holding structures, trusts or family wealth vehicles, and significant international income streams. Against this backdrop, the regime’s core advantages remain fully intact: No requirement to report foreign income to Italy No wealth taxes on non‑Italian assets No Italian inheritance or gift tax on foreign structures Up to 15 years of guaranteed clarity and predictability Even with €50,000 per additional family member, Italy provides one of the simplest and most competitive frameworks in Europe. Why UK Interest in Italy Continues to Rise The surge in interest from UK residents goes far beyond tax efficiency. Families moving from the UK increasingly seek: access to a stable civil law system predictable succession planning strong treaty protection a lifestyle suited to long‑term residence cultural, educational and quality‑of‑life benefits Italy’s regime has matured into a strategic relocation framework, not a temporary tax opportunity. The Importance of Pre‑Move Tax Rulings (Interpello) A key feature - often overlooked by UK applicants - is the ability to obtain a tax ruling before relocating. This pre‑clearance process allows families to: verify eligibility for the flat tax test how existing structures (trusts, partnerships, companies) will be treated identify any jurisdictions excluded from the regime secure certainty from the Italian tax authorities before becoming resident For UK families with longstanding structures, this step aligns Italy with the advisory standards traditionally associated with Switzerland or the UK. A Clear Signal from Italy to Global Wealth The move to a €300,000 annual rate delivers a clear message: Italy is positioning itself as a top‑tier, long‑term destination for globally mobile wealth. For UK families seeking stability, clarity, and access to Europe in 2026 and beyond, Italy and particularly Milan, stands out as one of the most compelling relocation options. The flat tax regime remains one of the most elegantly constructed frameworks in Europe: predictable, protective, and designed with long‑term residence in mind. We’re Ready to Assist With Your Move to Italy At Mosaic Chambers Group, we advise internationally mobile families, entrepreneurs and wealth owners navigating cross‑border relocation. Italy’s updated flat tax regime continues to offer one of the most secure and strategically valuable frameworks in Europe, particularly for UK residents reassessing long‑term plans after the UK’s non‑dom reform. Whether you are exploring Italy as a primary residence, evaluating the interaction with existing trust or corporate structures, or planning a multi‑generational move, our team is positioned to guide you through every step - from initial feasibility and pre‑move structuring to ongoing compliance and advisory support.

Introduction More wealthy UK residents are exploring life overseas ahead of the 2026/27 tax year. Higher UK taxes, political uncertainty and a desire for a different way of living are all pushing people to look at alternatives. Four destinations stand out for high-net-worth UK individuals as at late 2025: 1. United Arab Emirates (Dubai) 2. Portugal 3. Switzerland 4. Malta Each offers a different blend of tax advantages, residency options and lifestyle. United Arab Emirates (Dubai) - Dubai is now the default choice for many UK entrepreneurs and professionals. Tax For individuals, there is currently no personal income tax on salaries, bonuses or most investment income, and no local capital gains or inheritance tax regime for individuals. There is VAT and a developing corporate tax regime, but personal tax remains far lighter than in the UK. The UK–UAE double tax treaty helps reduce the risk of the same income being taxed twice and needs to be considered alongside UK residence rules. Residency Common routes for UK nationals include: Employer- or company-sponsored residence visas Remote-worker visas for those employed or self-employed abroad Long-term “golden” style visas linked to investment, property or professional status Retirement options for over-55s. (All require private health insurance and periodic renewal.) Lifestyle Dubai offers a high standard of living, excellent connectivity and a large, well-established British community. Housing and schooling are expensive and the lifestyle can encourage overspending, but for many the tax position and opportunity outweigh the costs. Best for: Maximising net income and building or scaling a business in a dynamic, international city. Portugal - Portugal appeals to those who want EU residency, a milder climate and a slower pace of life. Tax The old NHR regime has closed to new applicants and been replaced by a newer incentive framework (often referred to as IFICI) aimed at certain professionals and activities. The UK–Portugal tax treaty reduces double taxation, and Portugal does not operate a classic wealth tax, though property-related charges can apply. (It's signed and ratified but not yet fully in force as of early 2026, which may slightly affect immediate tax planning). Residency Post-Brexit, common routes for UK nationals include: D7 visa – for those with sufficient passive income (pensions, investments, rentals). D8 / Digital Nomad visa – for remote workers with qualifying income from abroad. Work and other residence visas tied to employment or specific skills. These can lead to long-term residence and, ultimately, citizenship if physical presence and integration tests are met. Lifestyle Cost of living is generally below the UK (though higher in central Lisbon and the Algarve), English is widely spoken in cities, and the public and private healthcare systems are well regarded. There are large British and wider international communities. Best for: Those wanting EU residence, good quality of life and a balance of tax and lifestyle advantages. Switzerland - Switzerland attracts UK families who prioritise security, discretion and top-tier services. Tax Tax is set at federal, cantonal and communal level, so overall rates vary widely by canton. Well-chosen cantons can be very competitive for both individuals and companies. Private capital gains are not generally taxed, but there is an annual wealth tax on net assets, with rules depending on location. For suitable non-working individuals, some cantons still offer lump-sum (forfait) taxation, where tax is based on living costs rather than worldwide income, subject to minimum levels and conditions. Residency As non-EU nationals, UK citizens use: B permits – time-limited residence, often linked to work L permits – short-term residence for specific assignments C permits – longer-term settlement after sustained residence and integration Wealthy retirees and non-working individuals may be able to obtain residence based on financial self-sufficiency and, in some cantons, lump-sum taxation. Lifestyle High costs are offset by excellent infrastructure, schools and healthcare (with compulsory private health insurance). International communities are strong in Zurich, Geneva and other cities, though social life can feel more formal than Southern Europe. Best for: Those seeking stability, discretion and first-class public services and education, rather than the lowest day-to-day costs. Malta - Malta is a compact EU state with a very familiar feel for UK nationals: English is an official language and the legal and business environment is comfortable for British professionals. Tax Malta’s tax system and UK–Malta treaty can be particularly attractive where you hold significant foreign-source income. Under the Global Residence Programme, qualifying individuals can pay a favourable flat rate on foreign income remitted to Malta, while foreign capital gains kept offshore are generally not taxed in Malta. There is no separate wealth tax and no classic inheritance tax, though duties may apply to certain Maltese assets. The separate “golden passport” (citizenship by investment) route has been struck down by the EU’s top court, but residence programmes remain available. Residency Options for UK citizens include: Employer-sponsored Single Permits combining work and residence The Global Residence Programme for financially self-sufficient individuals meeting property and minimum tax thresholds Digital-nomad-style visas for remote workers Long-term residence after several years of compliant stay Lifestyle Costs (especially rent and property) are typically lower than in the UK outside the most fashionable areas. English is widely used in government and business, healthcare is solid, and London is only a short flight away. Best for: Those wanting an English-speaking EU base with favourable treatment of foreign-source income and a tight-knit expat community. How to decide & next steps - All four countries can work extremely well for UK high-net-worth individuals, but for different profiles: Choose Dubai if your priority is low personal tax on active income and you are comfortable with a high-energy city. Choose Portugal if EU residency, climate and lifestyle matter as much as tax. Choose Switzerland if stability, education and healthcare are at the top of your list. Choose Malta if you want an English-speaking EU base with flexible options for foreign income. The right answer depends on your overall wealth, income mix, family plans and how tied you remain to the UK. If you would like bespoke, confidential advice on whether remaining UK-resident or relocating to Dubai, Portugal, Switzerland or Malta is the better strategy for your situation, you are welcome to get in touch to explore your options in detail.