Welcome to Britain. When are you leaving?

Britain has spent decades attracting wealth from around the world. Yet over the past few years, my colleagues and I have, increasingly, been helping clients leave for places like Italy, Switzerland, Jersey, Dubai and Singapore. Meanwhile, some wealthy newcomers are planning their exit almost as soon as they arrive.

UK tax rules changed dramatically on 6 April 2025, when the old “non-dom” regime ended. Broadly, the regime applied to UK residents whose permanent home was considered to be elsewhere.

In its place, newcomers who have been non-UK tax resident for at least 10 consecutive tax years can claim relief on eligible Foreign Income and Gains during their first four UK tax years.

In one respect, the new Foreign Income and Gains regime is more generous than the system it replaced, as qualifying foreign income and gains can be brought into Britain without an additional UK tax charge on remittance.

To be clear, people are still coming. I continue to see corporate executives posted to Britain and entrepreneurs who want to spend a few years in London while they complete a transaction, do business and enjoy one of the world’s great cities before the four-year clock runs down.

But I’m also talking to wealthy clients who are planning their arrival and their departure at the same time.

The cooling had already begun before the reforms took effect in April 2025. HMRC recorded 8,600 newly arrived non-dom taxpayers for the tax year 2024/25, down from 10,000 a year earlier.¹

Britain changes the bargain

For families who are already established in Britain, two changes have been particularly important in my conversations: inheritance tax and the treatment of trusts.

From April 2025, inheritance tax moved to a residence-based system. Broadly, once someone has been UK resident for at least 10 of the previous 20 tax years, their non-UK assets may fall within the UK inheritance tax net. After they leave, that exposure can continue for between three and 10 years.

Trusts changed too. Many wealthy families had accumulated assets in offshore trusts under “protected settlement” rules that could shelter foreign income and gains from immediate UK taxation. From April 2025, that protection largely disappeared for settlors of trusts who are resident in the UK and outside the four-year Foreign Income and Gains regime, meaning that trust income and gains can be attributed to them and taxed in Britain.

Recent high-profile departures include Lakshmi Mittal after nearly three decades in Britain, billionaire investor Nassef Sawiris and Goldman Sachs vice-chair Richard Gnodde.

When Britons start leaving too

A separate development may be more revealing still. Chris Rokos is British-born, ranked third in the Sunday Times Tax List 2026 with an estimated £330m tax bill last year, and has spent around £175m restoring Tottenham House, his Wiltshire estate. Yet he is moving his tax residence to Greece.

Rokos has not publicly explained his decision. But his move comes amid growing speculation about a possible UK exit charge — an issue I increasingly hear raised by wealthy UK residents. Uncertainty itself has become part of the cost of staying.

Other UK-domiciled business owners face different concerns. Changes to Business Property Relief and Agricultural Property Relief are among those I hear about most often. Since 6 April 2026, the 100% rate of relief for qualifying business and agricultural property is generally limited to a combined £2.5m allowance, with 50% relief above that level.

Wealthy foreign residents have always been mobile. It is more surprising when people born, educated and established in Britain start thinking about leaving too.

What Britain loses

The cost goes beyond the individual taxpayer. After Sawiris relinquished UK residency, his NNS Group moved to close its London family-office operation. Those offices support investment professionals, lawyers, accountants and other highly skilled people. Capital and decision-making power can move with them.

The sums are substantial. HMRC figures show that non-domiciled and deemed-domiciled taxpayers together accounted for £13.6bn in UK Income Tax, Capital Gains Tax and National Insurance contributions in 2024/25, up 9% from the previous year.

The longer-term concern is investment. Ed Bussey, chief executive of Oxford Science Enterprises, has warned that when the innovation-led companies his organisation backs are hitting their scale-up growth phase “there is not enough UK domicile capital to then grow those companies in the UK”, making their continued access to foreign capital critical to success.²

There is another side to the story. The four-year Foreign Income and Gains regime remains attractive, while the Temporary Repatriation Facility allows former remittance-basis users to bring historic Foreign Income and Gains into the UK at reduced rates.

Britain still offers deep capital markets, world-class universities, a vibrant culture and exceptional professional expertise. The question is whether that is enough to turn a four-year stay into a 20-year commitment.

With Chancellor John Healey due to deliver his first Budget on 28 October, internationally mobile families will be looking for clarity and stability around the rules they will face if they stay.

For those families, investment, estate and succession planning must now be closely coordinated with UK tax status, as a decision about residence can affect the tax treatment of assets around the world.

Britain remains a compelling destination. Increasingly, the length of the stay may be decided before the suitcases are unpacked.

Source:

¹ UK Government July 2026 
² FII March 2026

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