Tax nomads: Rolling stones gather no moss… and no tax?
Andy Wood • September 5, 2024
Introduction – Tax Nomads
‘A rolling stone gathers no moss’ says the old proverb.
Broadly, it translates to the idea that a person who does not settle in one place will not accumulate wealth, status, responsibilities, or commitments.
Of course, some might say that at least half of these are a decided benefit!
But what, if any, are the advantages of being a ‘fiscal rolling stone’?
This is a question we’re being asked more and more.
In many scenarios, this is because jurisdictions are seeking to attract so-called ‘digital nomads’ or tax nomads to their shores as part of a land grab for the internationally mobile wealthy individual.
So, is there more than just better weather on offer?
What’s the plan?
The plan is rather appealing.
Swapping your home office desk to working from the beach? Swapping the grey skies and bitterly cold wind for a tropical climate?
Sign me up.
Indeed, with the improvements in technology, and perhaps a change in attitude to remote working, the practical side of being an overseas, digital worker has never been easier to achieve.
Traditionally, the tax nomad model has been to split one’s time between a number of carefully chosen countries, moving on before falling to being resident for tax purposes in the current jurisdiction.
In theory, at least, it is possible to wander the world, moving on before the relevant tax authority asks you to join their little club.
However, I am a cynic at heart.
There must be an inherent danger that, despite arguing that you are not resident for tax purposes in ANY jurisdiction, you end of with multiple jurisdictions chasing you for their ‘fair share’!
So my preferred route is to find yourself a low tax jurisdiction to make your home base and establish residency there (more on this later). Plant a flag there.
Additionally, this is likely to help on tax and more mundane things like being able to open a bank account. Financial Institutions tend not to like those of ‘no taxed abode.’
To summarise, our cunning plan is two pronged:
• Dis-establish UK residency by reference to the Statutory Residency Test; and
• Create a ‘home base’ in a favourable jurisdiction.
Dis-establishing UK residence
The first aim is to ensure one is no longer resident for UK tax purposes.
The Statutory Residence Test (“SRT”), with effect from April 2013, replaced the unsatisfactory, and frankly preposterous, position that meant one had to rely on a patchwork of case law.
If Elmer the elephant did tax policy, it would have been the pre 2013 UK approach to tax residence.
There are three tests and they apply as a waterfall.
If one finds safety in the first then there is no need to go on to the next.
If not, it is only then that one moves to the next.
The three tests are as follows:
1. Automatic overseas test: if this test is satisfied then the taxpayer is conclusively non-resident;
2. Automatic residence test: if this test is satisfied then the taxpayer is conclusively UK resident;
3. A sufficient ties test: if neither of the above tests are satisfied then one resorts to a day-counting test
This article is not focused on the SRT, so a detailed exploration of this subject is a little off topic. But you can find a helpful link to one that does here
However, generally, speaking, these tests will limit the amount of time one can spend in the UK and claim to be non-resident.
The statutory residence test is not always easy to apply. However, what it perhaps lacks in simplicity it does, generally speaking, provide a greater degree of certainty than under the old rules.
Of course, there are exceptions!
Tax implications of being non-UK resident
Where one is non-UK resident for tax purposes, then one should only have an exposure to UK tax on UK source income. For example, on UK rental income.
This position is further narrowed by ‘disregarding’ certain UK income sources (including dividends from UK companies) from tax where the recipient is non-UK resident.
Further, one will only be in the scope of UK capital gains tax on the disposals of UK real estate, whether directly or indirectly held.
For both income and capital gains tax purposes, there are anti-avoidance rules which might create tax liabilities where the individual subsequently becomes UK resident within 5 years (and one should never underestimate how long 5 years is).
Choosing a home base?
Assuming one is not going to continually move from one jurisdiction to another, then one next needs to choose a tax base. This is the place where one is putting a flag in the ground and saying ‘yep, this is my home’.
Of course, you might use this as a jumping off point to visit other countries (and note, one would not want to become resident in those countries).
However, constructing a tax base where one is liable to tax does not necessarily mean that you rolling stone dreams have been thwarted.
There are many jurisdictions around the world where one might become resident for tax purposes but can broadly live tax-free from much of your foreign income – only suffering local tax on local source income.
For example, one can qualify under Cyprus’ non-domicile regime if one spends as little as 60 days a year in the UK. Generally speaking, income derived outside of Cyprus is not taxable in Cyprus.
Dubai is another very popular jurisdiction. It is not correct to say it is a no tax jurisdiction. VAT has been payable by GCC states for a few years and the UAE introduced corporate income tax (top rate 9%) in June 2023. However, there is still no personal tax, which is an ideal position for the nomadic world citizen.
Barbados is a more recent popular destination for digital nomads due to its special ‘Welcome’ visa. Again, only Barbados source income is subject to local tax along with foreign income and gains to the extent it is enjoyed on the Island.
Previously, one could also become resident in Portugal and avail oneself of the Non-Habitual Residence (“NHR”) regime. This broadly provided for a 10-year exemption on certain foreign income and gains.
As I’m not a travel agent, I’ll stop there.
Employer beware!
Finally, an employer cannot simply leave its employees to set up and start working remotely from a beach hammock without the fear of any consequences.
They will need to ensure that they deal with their employee properly from a payroll perspective.
However, in addition, they will need to ensure that the employee does not inadvertently create any taxable presence in the country in which they are staying.
Conclusion
To conclude, it is certainly possible to be a tax nomad.
However, my preference is to actually plant a flag in the sand somewhere and create a tax home base.
My opinion is that this will assist in mitigating the chances that you have multiple tax authorities on your tail which might be the case where you have not created that tax base.
Following this plan will also tick some more boring boxes such as more readily being able to open bank accounts and purchase other financial products.
Even so, and obviously depending on your circumstances, it should be possible to limit one’s tax liabilities.
Hopefully, unlike the Rolling Stones song, this will give you some satisfaction.
If you have any queries about tax nomads or tax matters in general, then please get in touch.
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.
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