The UK abolished non-dom status on April 6, 2025, under the Finance Act 2025. Whether you think the resulting wealth outflow is a modest adjustment or a historic exodus depends on whose data you believe — Henley and Partners projected 16,500 net millionaire departures in 2025 representing USD $91.8 billion of private wealth, while the Tax Justice Network argues this represents only 0.63 percent of the UK's millionaire population and should not be called an exodus at all. Both of these positions can be accurate simultaneously, and the honest answer matters for anyone planning their own move. Here is where UK non-doms are actually going in 2026, and what each destination trades off.
Most UK non-doms making the move are comparing three or four destinations across the Gulf, Mediterranean, and North America. Private charter compresses an otherwise impossible scheduling problem — Dubai, Milan, Zurich, Monaco, and Lisbon are not on the same commercial route maps.
Get a Charter Quote →The UK non-domicile regime dated to 1799 and had survived largely unchanged for more than two centuries. It allowed UK residents whose permanent home for tax purposes was outside the UK to pay UK tax only on income earned in the UK, or on foreign income that was remitted to the UK. Foreign income that stayed offshore was not taxed by the UK. This regime was the specific mechanism that made London viable as a base for internationally mobile wealth during the late twentieth and early twenty-first centuries, and its abolition represents the most significant change to UK personal tax policy affecting wealthy international residents in living memory.
The Finance Act 2025 replaced non-dom status with a four-year Foreign Income and Gains (FIG) regime, effective April 6, 2025. Under FIG, new UK residents (specifically, individuals who have been non-UK resident for at least ten consecutive tax years before arrival) receive 100 percent relief on non-UK income and gains for their first four UK tax years of residence. After four years, the full standard UK tax regime applies — worldwide income taxation at UK rates (which reach 45 percent at the top marginal band), and full UK capital gains tax (18 percent or 24 percent depending on the asset and rate band) on worldwide gains.
Inheritance tax was simultaneously moved to a residence-based system. Under the new rules, individuals become in-scope for UK inheritance tax after ten of the previous twenty tax years, with an IHT "tail" of three to ten years after leaving the UK depending on total length of prior residence. Trust protections that non-doms had historically relied on were abolished — trusts set up by non-doms can now be brought into the UK IHT net retroactively, which has been the specific change most disruptive to established family wealth planning structures. A Temporary Repatriation Facility was introduced for former non-doms to bring historical foreign income back to the UK at reduced rates: 12 percent for tax years 2025/26 and 2026/27, rising to 15 percent for 2027/28.
For UK non-doms who had established their planning around the old regime, none of this is minor adjustment. The combination of retroactive trust changes, worldwide income taxation after four years, and residence-based inheritance tax fundamentally repriced UK residency for the wealthy international cohort, and the behavioural response has been substantial.
Henley and Partners' 2025 Private Wealth Migration Report, published in mid-2025, projected a net loss of approximately 16,500 millionaires from the UK in 2025. This represented more than double the approximately 7,500 millionaires who left in 2024, making 2025 the steepest single-year millionaire outflow ever recorded for any country in Henley's ten-year tracking dataset. The aggregate wealth of the 16,500 projected departures was estimated at USD $91.8 billion, and Henley's client data showed that UK nationals submitted 183 percent more applications for alternative residence and citizenship programs through Henley in Q1 2025 versus Q1 2024.
These numbers were widely reported in UK and international media and have influenced UK government policy discussions. Labour's decision in January 2025 to soften elements of the non-dom reform was widely credited to concerns about wealth outflow, though a Treasury official denied this causation to Politico at the time. Headlines across the UK financial press described a "Wexit" (wealth exit) or a "millionaire exodus."
The counter-narrative is important and worth taking seriously. In a detailed critique published in early 2026, the Tax Justice Network, working with Patriotic Millionaires UK and Tax Justice UK, argued that the 16,500 figure represents only 0.63 percent of the UK's total millionaire population of approximately 2.6 to 3 million individuals, and that this proportional rate is actually similar to or smaller than historical migration rates in other major economies (India at 0.77 percent in 2023, South Africa at 0.66 percent in 2024). The critics also pointed out that Henley's methodology counts as a "migrant" anyone who spends more than six months abroad, even if they retain a UK passport, a UK home, and an active UK business — which means the definition of "leaving the UK" may be looser than the headlines suggest.
In my view, both of these positions can be accurate simultaneously and applicants should understand both rather than picking sides. The absolute number of UK non-doms leaving is smaller as a proportion of the millionaire population than the headlines suggest, which is the Tax Justice Network's fair point. At the same time, the direction and acceleration of the trend are real — Q1 2025 applications were up 183 percent year-on-year, LonRes reported a 36 percent decline in prime London property transactions in May 2025 versus May 2024, and Companies House data showed more than 4,400 directors leaving the UK over the year. The second-order effects on UK tax revenue, prime property, legal and advisory services, and the household economy around ultra-high-net-worth residents are measurable. Whether you call this an "exodus" or an "adjustment" is largely semantic. For the individual non-dom weighing their own decision, the relevant question is not what label to attach to the aggregate data but what destination actually works for their specific situation.
| Rank | Destination | Primary tax draw | Typical profile |
|---|---|---|---|
| 1 | UAE (Dubai) | 0% personal income tax | All profiles; dominant default |
| 2 | Italy (Milan, Florence) | €200,000 annual flat tax on foreign income | Foreign income above €1M/year |
| 3 | Switzerland (Zug, Geneva) | Cantonal forfait lump-sum taxation | Ultra-HNW; CHF 400k+ negotiated |
| 4 | USA (Florida, Texas) | No state income tax | US-facing business interests |
| 5 | Monaco | 0% personal income tax (except French nationals) | €1M+ net worth, €500k bank deposit, housing constraint |
| 6 | Singapore | Max 22% personal income tax; territorial for some | Asia-facing business interests |
| 7 | Portugal (Lisbon, Algarve) | NHR substantially wound down; lifestyle remains | Retirement, moderate wealth |
The ranking is driven by Henley's reported destination data for 2025, cross-referenced with the specific tax and lifestyle trade-offs each jurisdiction offers to UK non-doms. The UAE is clearly the top destination and the margin over other destinations is substantial. Italy is second largely because of the €200,000 flat tax, which was specifically doubled from €100,000 in August 2024 — and notably, has not deterred applications despite the doubling, and the Italian government has reportedly signalled potentially raising it further to €300,000 in future budgets. Switzerland, the USA, and Monaco occupy the middle of the ranking and serve specific applicant profiles rather than being mass-market destinations.
The UAE has been the clear single destination for UK non-doms since the 2024 budget cycle, and Henley projected a net inflow of approximately 9,800 millionaires to the UAE in 2025 — the largest single-country inflow in their tracking data. Dubai has been the specific centre of gravity, both because of the established financial infrastructure (DIFC, ADGM, international banking presence) and because the UAE Golden Visa program has been repeatedly expanded since its 2022 introduction to widen eligibility.
The tax proposition is straightforward: zero personal income tax, zero capital gains tax on personal investments, zero inheritance tax, zero wealth tax. Corporate tax was introduced in 2023 at 9 percent on business profits above AED 375,000, but this applies only to operating businesses and not to personal investment returns or passive wealth. For a UK non-dom moving to Dubai with foreign investment income, the effective personal tax rate drops from the UK's 45 percent top marginal band to zero, which is the largest single tax advantage available among the destinations on this list.
The trade-offs are specific and should be understood before committing. Climate — summer temperatures regularly exceed 45°C and the outdoor season is effectively November to March. Political and regulatory environment — the UAE is a federation of monarchies with different legal norms than Western democracies. Schooling — while Dubai has many international schools, capacity has been under pressure as the population has grown rapidly through 2024 and 2025, and applicants with school-age children should secure places before committing to the move. Distance from UK family — Dubai is seven hours flying from London, which is manageable for business trips but meaningful for frequent family visits. Property costs — Dubai prime property has been appreciating consistently since 2023, and the February 20, 2026 policy circular removing the 50 percent down payment requirement for the Golden Visa property route has further expanded demand.
For the specific profile of a UK non-dom who can actually base themselves in Dubai (spending 183+ days per year there to establish UAE tax residency), the combination of the Golden Visa, zero personal tax, and established infrastructure is the strongest tax and residency package currently available to wealthy internationally mobile individuals. This is why the UAE has been the dominant destination in 2025 and why I expect it to remain so through 2026.
Italy is the second-most-cited destination for UK non-doms in the Henley 2025 data, and the specific draw is the €200,000 annual flat tax regime under Article 24-bis of the Italian Consolidated Income Tax Code (TUIR). The regime was introduced in 2017 at €100,000 per year, was doubled to €200,000 for new applicants from August 2024, and the Italian government has reportedly signalled potential further increases to €300,000 in future budgets. Despite the doubling, applications have continued to grow — which tells you something about the underlying demand and the math.
The maths of the Italian flat tax favour very high earners specifically. €200,000 is a fixed annual cost regardless of foreign income level, which means the effective tax rate decreases as income scales. An applicant with €1 million of foreign income pays an effective 20 percent on that income; an applicant with €5 million pays an effective 4 percent; an applicant with €10 million pays an effective 2 percent. For most applicants with foreign income below approximately €800,000 per year, the Italian flat tax is more expensive than regular Italian taxation after accounting for deductions and treaty relief, and does not make economic sense. For applicants with foreign income above approximately €1 million per year — which is exactly the non-dom profile — the Italian package becomes dramatically attractive and scales favourably as wealth increases.
Beyond the tax, Italy offers specific advantages that the UAE does not: European time zone and climate, mature cultural and professional services infrastructure, easy travel to and from the UK (two hours direct), and lifestyle amenities across Milan, Florence, Lake Como, Tuscany, and the major southern destinations. Milan specifically has benefited from non-dom inflows because it combines Italian lifestyle with mature private banking infrastructure and a concentration of English-speaking professional services that the Italian second-tier cities do not match.
The trade-offs. Italian civic and legal infrastructure is slower than UK equivalents, bureaucracy is genuinely more complex, and the ten-year path to Italian citizenship is longer than most competing programs. The Italian flat tax is available for a maximum of fifteen years and is not renewable after that period, which means applicants need to have a long-term plan that accommodates the eventual exit from the regime. For ultra-high-net-worth applicants whose fifteen-year tax savings under the flat tax justify the move, Italy is often the strongest European alternative to the UAE.
Switzerland remains a top destination for a specific slice of the UK non-dom population — typically ultra-high-net-worth applicants who can negotiate favourable terms with Swiss cantons under the forfait (lump-sum) taxation system. The forfait allows qualifying foreign nationals to pay a negotiated fixed annual tax payment based on estimated living expenses rather than actual income or wealth, and for applicants whose actual income and wealth are substantial, the negotiated payment can be dramatically lower than standard Swiss progressive taxation would produce.
The Swiss forfait is not a standardised program with published headline pricing. The actual negotiation happens canton by canton (each Swiss canton has its own tax authority and its own approach to forfait), typical minimum negotiated annual payments start at approximately CHF 400,000 and can range significantly higher depending on the specific canton and the applicant's profile. Zug, Geneva, Vaud (Lausanne), and Ticino are the cantons most commonly associated with forfait arrangements, though not every canton offers the instrument — Zurich notably abolished forfait for new applicants in 2009, and applicants should verify current canton-specific rules with Swiss tax counsel.
The trade-offs are the specific Swiss profile. Cost of living — Switzerland is among the world's most expensive countries to live in, and the forfait's tax savings can be partially absorbed by higher general costs. Political stability and financial privacy — Switzerland scores extremely well on both, which is often the primary non-tax draw for applicants from jurisdictions with less stable governance. Language — Swiss French, German, Italian, and Romansh are the national languages; English is widely spoken in business contexts but formal tax and legal documentation is typically in one of the national languages. Residency requirements — Switzerland expects genuine residency, not paper residency, and applicants who maintain parallel residency in the UK are increasingly at risk of challenge from both the UK and Swiss tax authorities.
Switzerland is the right answer for UK non-doms who are genuinely ultra-high-net-worth, who value political stability and financial privacy specifically, and who will actually relocate to Switzerland in a meaningful sense rather than using Swiss residency as a pure tax optimisation play. For that specific profile, Switzerland remains one of the strongest alternatives; for everyone else, the cost of Swiss relocation typically exceeds the tax savings.
Every destination on this ranking — UAE, Italy, Switzerland, USA, Monaco, Singapore, Portugal — requires proof of international health insurance during the residency application process and typically for at least the first year of residence. SafetyWing's global policy covers all seven jurisdictions and simplifies a documentation burden that varies widely between programs.
Get a Quote →The United States has been the third or fourth most cited destination for UK non-doms in the Henley 2025 data, specifically for applicants with US-facing business interests or family connections. The US tax proposition is counterintuitive: federal income tax at rates up to 37 percent plus state tax is often higher than what a UK non-dom was paying under the previous UK regime, which means the US is not a pure tax optimisation destination. The UK non-doms who have moved to the US are primarily doing so for business, family, or lifestyle reasons rather than for tax.
The exception is the no-state-income-tax cluster — Florida, Texas, Tennessee, Nevada, Wyoming, and a handful of other states that do not impose state personal income tax. For UK non-doms with substantial US-sourced income or US-based business activity, relocating to Florida or Texas specifically can reduce the state tax layer while accepting the federal tax bill. The savings relative to high-tax US states like California or New York are meaningful but the savings relative to the previous UK non-dom regime are not — a UK non-dom moving to Florida is typically trading one high-tax environment for another at the federal level while gaining access to US markets and lifestyle.
For applicants whose primary goal is tax minimisation, the US is the wrong destination. For applicants whose primary goal is access to US business opportunities, proximity to US family, or specific American lifestyle factors (climate, culture, professional networks), the US is often the right answer regardless of tax implications, and Florida or Texas are the least-bad US tax environments within that choice set.
Monaco offers zero personal income tax for non-French nationals (French citizens are taxed by France under a bilateral treaty), and the principality has historically been a top destination for ultra-high-net-worth applicants seeking tax residency with Mediterranean lifestyle. The challenge with Monaco is not the tax proposition — that is genuinely favourable — but the practical constraints of actually establishing residence.
Monaco residency requires proof of sufficient means (typically interpreted as minimum €500,000 deposited with a Monaco bank), proof of accommodation in Monaco (either ownership of Monaco property or a rental lease, and Monaco property prices are the highest in the world at approximately €50,000 per square metre on average), clean criminal record, and genuine intention to make Monaco the applicant's primary residence. The practical minimum net worth to make Monaco residency workable is approximately €5 to €10 million, driven almost entirely by the housing cost constraint rather than by the nominal €500,000 bank deposit.
Monaco is the right answer for ultra-high-net-worth UK non-doms whose wealth is above €10 million, who specifically value Monaco's combination of zero tax, Mediterranean climate, Italian and French cultural accessibility, and concentrated wealth-management infrastructure, and who can accept housing costs that are roughly ten times prime London equivalents. For UK non-doms below the €10 million threshold, Monaco is typically impractical — the housing cost alone exceeds the tax savings for most profiles, and other destinations (UAE, Italy flat tax) deliver better economics at lower cost of living.
The new UK FIG regime grants 100 percent relief on non-UK income and gains for the first four UK tax years of residence, for individuals who have been non-UK resident for ten consecutive years prior. For new arrivals to the UK who meet the ten-year prior non-residence test, the FIG regime is reasonably favourable during the four-year window — the specific tax treatment of foreign income during that period is comparable to the old non-dom remittance basis for the limited duration.
The problem is the four-year cliff. After the FIG window expires, the full UK worldwide income taxation applies, along with capital gains at 18 or 24 percent and inheritance tax under the residence-based rules. An applicant who moves to the UK expecting to stay long-term will face a dramatic tax rate increase at year five, and the total tax liability over a ten or fifteen year horizon is typically much higher under FIG than under most international alternatives.
For existing UK non-doms whose position was based on the old regime, FIG is generally not a reason to stay — the four-year protection does not apply to applicants who have been UK resident during the qualifying decade, and the main effect of FIG for existing non-doms is to accelerate the decision whether to remain under the new regime or to relocate. The Oxford Economics survey finding that 63 percent of non-doms intended to leave within two years of the reforms reflects this dynamic: FIG did not fix the non-dom problem, it restructured the problem in ways that made many existing non-doms worse off.
For new international arrivals considering whether to move to the UK versus another destination, FIG is competitive for the first four years but uncompetitive beyond that window. Applicants with a genuine long-term commitment to the UK for non-tax reasons may find the FIG window adequate; applicants whose decision is primarily tax-driven typically find UAE, Italy flat tax, or Switzerland forfait more attractive over the full planning horizon.
Per the Henley Private Wealth Migration Report 2025, the top destinations for UK millionaires in 2025 were the United Arab Emirates, the United States, Italy, and Switzerland, with secondary destinations including Monaco, Singapore, and Portugal. The UAE is the single largest beneficiary — Henley projected a net inflow of approximately 9,800 millionaires to the UAE in 2025, driven by zero personal income tax, the 10-year Golden Visa program, and Dubai's established financial infrastructure. Italy has become the second-most-cited destination specifically because of the €200,000 annual flat tax regime under Article 24-bis TUIR, which applies to foreign-source income regardless of amount for up to fifteen years. Switzerland's forfait (lump-sum taxation) system attracts ultra-high-net-worth applicants who can negotiate fixed annual tax payments with Swiss cantons.
The honest answer is that the exact number is disputed and depends on how you count. Henley & Partners projected a net loss of 16,500 UK millionaires in 2025, approximately double the 7,500 reported in 2024, with aggregate wealth of USD $91.8 billion. These figures have been widely reported and have influenced UK government policy. The Tax Justice Network, Patriotic Millionaires UK, and other critics have pointed out that 16,500 represents only about 0.63 percent of the UK's estimated 2.6 to 3 million millionaires, that Henley's methodology counts anyone spending more than six months abroad as a migrant even if they retain UK business and property interests, and that the absolute numbers are proportionally similar to historical rates in other major economies. Both things can be true simultaneously: the absolute number is a small share of the total millionaire population, and the directional trend is real and accelerating, with Q1 2025 seeing 183 percent more applications through Henley than Q1 2024.
The UK non-domicile regime was abolished on April 6, 2025, under the Finance Act 2025. The old non-dom remittance basis, which dated to 1799, allowed UK residents whose permanent home for tax purposes was outside the UK to pay UK tax only on income earned in or transferred to the UK. The replacement is the four-year Foreign Income and Gains (FIG) regime, which grants 100 percent relief on non-UK income and gains for the first four UK tax years of residence but requires ten consecutive years of prior non-UK residence to qualify. Inheritance tax was simultaneously moved to a residence-based system — individuals become in-scope after ten of the previous twenty tax years, with an IHT 'tail' of three to ten years after leaving the UK depending on total residence length. Trust protections for non-doms were also abolished, which has been particularly significant for family wealth planning structures that had relied on the previous regime.
The direction is clearly real. Q1 2025 applications for alternative residence and citizenship programs through Henley were 183 percent higher year-on-year. LonRes reported 36 percent fewer prime London property transactions in May 2025 versus May 2024. Companies House data indicates that more than 4,400 directors left the UK over the year through early 2025. Oxford Economics conducted a survey of non-doms and their advisors in September 2024 that found 63 percent said they would leave within two years of the reforms being implemented. Specific high-profile examples include Lakshmi Mittal, chairman of ArcelorMittal, whose personal fortune is approximately £15.4 billion and who moved to Dubai reportedly due to inheritance tax concerns. The absolute numbers are debated. The direction and the acceleration are not. Both the Henley figures and the Tax Justice Network critique can be accurate simultaneously — the exodus is smaller in proportional terms than the headline suggests, but the trend is real and the second-order effects on UK tax revenue, prime property, and the service economy around ultra-high-net-worth households are measurable.
Multi-destination due diligence across Dubai, Milan, Zurich, and Monaco rewards charter flexibility.
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