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Discover how UK tax reforms are prompting wealthy individuals and business owners to move abroad for better tax outcomes and financial certainty.
Contents
The impact of recent tax reforms on UK wealth
Three years ago, in the wake of scrutiny and a perceived lack of fairness, I wrote about the UK’s tax regime for non-domiciled (‘non-dom’) individuals and how reform might be inevitable. It seemed obvious the UK would want to remain competitive and avoid deterring investment and expertise. However, the abolition of the non-dom regime, increased capital gains tax (CGT) rates and the extended scope of inheritance tax (IHT) on business assets and pensions appear to have created a perfect storm.
In recent months I’ve had many conversations with lawyers, accountants, bankers and financial advisers about the evolving tax landscape. A recurring theme is the increasing number of people leaving the UK. The storm has gathered such force that record numbers of high-net-worth individuals – both non-doms and UK natives – are reportedly relocating to more financially favourable jurisdictions such as Portugal, Spain, Italy, Switzerland, the UAE, Isle of Man and Channel Islands.
Capital gains and offshore strategies
With CGT now at 24% for higher earners, those with valuable assets are reconsidering how to maximise their returns. Many are now starting conversations with advisers about moving offshore, at least temporarily, to dispose of assets free from UK CGT. To ensure gains fall outside the UK tax net, specific conditions must be met, and advice is also required in the destination country.
Experience shows that maintaining long-term absence from the UK can be challenging, especially when family remains here. Contingency plans are also needed for unexpected events such as illness. Still, for many, the prospect of staying in the UK and paying relatively high tax on gains makes the offshore move a risk worth taking.
Non-dom changes and expanding IHT scope
Reforms to the non-dom regime took effect last month. These introduced new rules for taxing worldwide income and gains, replacing the previous remittance basis with a less generous system. UK IHT will now apply to an individual’s global estate after ten years of residence. Even after leaving, former residents may remain liable for IHT on worldwide assets for up to another ten years.
Trusts that were previously excluded from IHT have also been brought into scope. Their tax status now depends on the residence of the settlor, prompting many trustees to seek guidance and understand their compliance obligations. For many, these changes were a step too far, and an exodus of wealthy non-doms occurred before the new tax year began.
Family businesses and future IHT burdens
Proposed changes to the IHT regime for UK business owners are also having an impact. Advisers are seeing more queries from shareholders in UK trading companies who are now considering a move abroad. From April 2026, relief from IHT on trading businesses will be reduced from 100% to 50% on any value above £1 million. This will create a significant liability for many family businesses, whose owners must now plan how they would fund this in the event of a death.
Looking ahead: pensions and broader implications
Further reforms announced for April 2027 will bring pensions into the IHT net. This, combined with other measures, has fuelled demand for professional advice and growing interest in the advantages of relocating overseas (not just for the weather). There’s a lingering sense that the overall cost of these sweeping tax reforms may outweigh the benefits they aim to deliver.
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