Thousands of millionaires leaving the UK – the new tax rules don’t make sense

The UK lost a net 10,800 millionaires to migration in 2024, a 157% increase compared to the year before (net loss of 4,200 in 2023), according to the Henley Wealth Migration Dashboard.

The figures, compiled by global analytics firm New World Wealth and investment migration advisors Henley & Partners, refer to individuals who have liquid wealth of at least USD 1 million.

The abolition of the non-dom tax status could cost the UK up to £111 billion by 2035, and 44,415 jobs by 2030, according to analysis by the Adam Smith Institute in April 2025.

The economics think tank forecasts the UK could face up to £14.2 billion of lost growth each year by 2035.

An HM Treasury spokesperson said: “Replacing the outdated non-dom tax regime with a new internationally competitive residence-based system addresses unfairness in our tax system, attracts the best talent and investment to the UK, and ensures everyone who is a long-term resident in the UK pays their taxes here.”

How have non-dom tax rules changed?

A non-dom is a UK resident whose permanent home, or domicile, for tax purposes is outside of the UK.

Previously, non-doms only had to pay UK tax on the money they earn in the UK, unless money made elsewhere in the world was paid into a UK bank account.

Under the old rules, some non-doms had to pay an annual charge if they did not pay UK tax on foreign income or gains and had been resident in the UK for a certain amount of time.

This was known as the “remittance basis” and annual fees stood at either:

  • £30,000 if the person had been living in the UK for at least seven of the previous nine tax years
  • £60,000 for at least 12 of the previous 14 tax years

In March 2024, the then Conservative chancellor Jeremy Hunt announced plans to phase out the non-dom tax regime. He said non-doms who moved to the UK from April 2025 would be exempt from paying tax on the money earned overseas for the first four years. They would then be taxed on these earnings if they remained living in the UK after this time. Existing non-doms were granted a two-year transition period.

Chancellor Rachel Reeves announced a new tax regime, based on residence, in the 2024 Autumn Budget, which was introduced on 6 April 2025. She went further, ending the use of offshore trusts to shelter assets from inheritance tax and abolishing the planned 50% tax reduction for foreign income in the first year of the new regime.

Reeves extended the transition period – giving the wealthy three years to bring foreign income into the UK at a low tax rate.

Now, new arrivals to the UK don't have to pay tax on foreign income and gains in their first four years of tax residence – provided they haven't been a UK tax resident in any of the past 10 years prior to their arrival. After that, all foreign income and gains will be taxable at the corresponding marginal rate.

The Treasury estimates the further reforms to the non-dom tax regime, announced in Reeves' 2024 Autumn Budget, will raise £12.7 billion over the next five financial years.

Though a report by the economic consultancy Centre for Economics and Business Research (CEBR) estimates that if 25% of non-dom remittance basis taxpayers left the UK, the net gain to the Treasury would be zero.

The net losses to the Treasury in the first year of the scheme would rise to £2.4 billion, if 50% left, CEBR's report said.

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