March 2025
Effective 6 April 2025, the United Kingdom (UK) is set to implement significant changes to its non-domiciled (non-dom) tax status, transitioning from a domicile-based to a residence-based taxation system. This will result in all UK residents being taxed on their worldwide income and gains, eliminating the previous remittance basis that allowed non-doms to pay UK tax only on income brought into the country.
This update and change to the UK non-dom rules shall have substantial tax implications for those who have previously relied on their non-dom status, especially those with significant foreign income or assets. Key changes being:
Expansion of the Tax Base: as noted above, the new rules will subject more foreign income and assets to UK taxation, especially for long-term residents. This will extend to inheritance tax on foreign assets.
Reduction of Tax Benefits: foreign income relief will be reduced, with reductions and limitations on the time period for claiming tax relief. Such changes will diminish tax optimisation opportunities for high-income individuals.
Temporary Concessions: whilst there will be a temporary repatriation facility offered with a reduced tax rate on remitted foreign income, this will be limited in time.
Increased Administrative Burden: overall the new system is set to require more meticulous management of tax obligations, leading to additional legal and accounting costs.
The UK’s shift from a remittance-based tax system to one focused on tax residence years has raised concerns, particularly amongst high-net-worth individuals (HNWIs), making the UK less appealing to wealthy individuals, placing a higher burden on foreign nationals with significant wealth and assets, and prompting some to consider relocating to countries with more favourable tax regimes.
In 2024, nearly 1,000 HNWIs from the UK relocated to Dubai, contributing to a broader trend of wealthy individuals moving to the United Arab Emirates (UAE). A London-based investment migration consultancy predicted that a total of 6,700 millionaires would move to the UAE by the end of the year, with a significant portion coming from the UK.
Why the UAE?
Despite the introduction of corporate tax in the UAE in 2023, the UAE still offers a considerably more favourable tax environment for HNWIs and businesses compared to the UK. Key benefits include:
Low or Zero Taxes for Individuals
Corporate Tax Incentives for Businesses
Other Benefits
All of these factors contribute to the UAE’s growing appeal to UK HNWIs and businesses looking to reduce their tax burden, and utilise and benefit from tax advantages supporting growth and profitability. ■