EuropePolicy Updates

UK Chancellor Announces End of Non-Dom Tax Regime

The UK government, in an effort to raise revenue and appease British voters, is overhauling its centuries-old system of preferential tax treatment for wealthy foreign residents. Advisors to the ultra-rich say the move will “certainly” motivate many of them to move themselves and their capital out of the country.

In his Budget speech on Wednesday, Chancellor Jeremy Hunt announced the abolition of the “non-domicile” (or non-dom) status, effective April 2025. For over two hundred years, this regime has allowed affluent expatriates to avoid paying UK taxes on their overseas income and capital gains.

Hunt framed the new residence-based taxation system as “fairer” while asserting it would remain “competitive with other countries” in attracting global talent. He cited a four-year grace period – granting 100% relief on foreign earnings during that window – as “one of the most attractive offers in Europe” to new arrivals.

The government expects the reforms to generate £2.7 billion in additional annual tax revenue by 2028-29, on top of the £8.5 billion non-doms currently contribute yearly. This influx affords Hunt leeway to trim national insurance (a payroll tax) while adhering to budget targets preceding a general election mandated by January 2024, a priority shared across party lines, as Labour has also vowed non-dom overhaul.

Yet the changes have stoked fears of an exodus among the ultra-wealthy. David Lesperance, an IMI columnist who advises UHNWIs on tax and immigration matters, told Bloomberg the revisions “have only added urgency” to residents’ plans to depart the UK. “They already knew [a] future Labour government was either going to abolish or significantly restrict the remittance basis,” he said. “Now, they know that rather than saving them, the Tories are also willing to throw them under the bus!”

Under the new rules, everyone residing in Britain for over four years must pay UK tax on their global income and capital gains, scrapping the “remittance basis” that taxed only funds brought into the country. Other provisions include temporary tax reprieves to ease the transition.

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Mark Davies of Davies & Associates predicted the reforms “most certainly will mean people will leave” and dissuade billionaires from situating in Britain, as “four years isn’t enough to settle with kids.” He deemed the changes amenable chiefly to those on corporate secondments.

Non-doms have encompassed a diverse array – from multibillionaires to mid-level financiers – united by their avoidance of UK taxes on overseas earnings for up to 15 years under the legacy program. Research indicates over twenty percent of bankers earning above £125,000 have claimed the status. Other impacted industries include oil, automotive, and football; the Premier League alone hosts around 370 non-dom players.

The non-dom regime originated in 1799 to safeguard colonial investments. Its recent beneficiaries have included figures like former HSBC CEO Stuart Gulliver and onetime Conservative deputy chair Michael Ashcroft. In 2022, revelations that Rishi Sunak’s wife exploited the status sparked a furor, prompting her to relinquish it.

As the UK’s tax environment evolves, rival jurisdictions are vying to attract such affluent, mobile residents through low-tax policies. Italy offers a €100,000 flat levy on overseas income or an exemption on 70-90 percent of earnings, and Greece has a similar scheme.

Other European countries, like Malta and Ireland, have non-dom schemes of their own (modeled on the more generous original form of the UK’s), while Spain offers a six-year reprieve on foreign earnings under the Beckham law. Portugal, meanwhile, recently abolished its popular NHR tax regime, which offered reduced taxes for employment income and, in some cases, full exemptions on foreign capital income.

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