The UK abolished its non-dom regime on 6 April 2025. Henley & Partners reported 16,500 millionaires leaving the UK in 2025 — a figure that is disputed but signals a real underlying shift. Here is where they went and how each destination compares.
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By Richard J. · 15 October 2025 · Last reviewed: 3 July 2026
The abolition of the UK's non-dom regime is the most significant structural change to the UK's tax environment for internationally mobile wealth in a generation. From 6 April 2025, all UK residents pay tax on worldwide income and gains as they arise, regardless of domicile. The individuals who had anchored their lives in London while managing international assets have been reclassified from a class of specially treated residents into standard UK taxpayers — and a significant number concluded this was the moment to stop living in the UK entirely. Where they went is a mix of the obvious (Dubai) and the surprising, and the arithmetic behind each choice is more specific than the headline numbers suggest.
The UK's non-dom regime had operated since the 19th century. Individuals whose permanent home — their domicile — was legally considered to be outside the UK could elect to be taxed only on UK-source income, and on foreign income only if it was remitted to the UK. For the internationally wealthy, this was the structural mechanism that made London viable as a base: you could live there, attend the schools, use the infrastructure, participate in the social and business fabric, while keeping offshore income outside the scope of UK taxation.
The Finance Act 2025, which received Royal Assent on 20 March 2025, abolished this framework entirely. From 6 April 2025, UK residency means worldwide taxation. A four-year Foreign Income and Gains relief is available for new arrivals who have not been UK-resident for the previous ten consecutive years — but this is a transitional arrangement for new arrivals, not a substitute for what existed before.
The parallel inheritance tax reform is equally significant. UK IHT has moved from a domicile-based system to a residence-based one. Non-UK assets are now within the scope of UK IHT once an individual has been UK-resident for ten of the previous twenty years. For long-standing UK-resident non-doms, this creates a material estate planning exposure that did not previously exist. Our domicile vs residence guide covers the distinction in detail.
The arithmetic that drove the decision: A former non-dom with £10m in foreign income — dividends, capital gains, rental income from overseas property — previously paid no UK tax on that income under the remittance basis. From April 2025, that same income is subject to UK income tax and CGT at rates up to 45% and 24% respectively. The financial case for remaining UK-resident collapsed overnight for a specific, highly mobile subset of the population.
The most-quoted number in coverage of the non-dom exit is Henley & Partners' figure of 16,500 UK millionaires leaving in 2025. It is worth being direct about where this number stands. It comes from Henley's 2025 Private Wealth Migration Report and has been extensively cited, but the Tax Justice Network and Tax Policy Associates have both published methodological critiques of the underlying data. Henley's 2026 report itself softened the language significantly, dropping several country-level estimates and acknowledging that migration was "modest and concentrated in specific circumstances." Even at face value, 16,500 represents around 0.63% of the UK's millionaire population — meaningful, but not a demographic upheaval.
What is not disputed is the direction of travel. HMRC data shows a material decline in non-dom registrations. Knight Frank recorded a 14% drop in five-million-pound-plus London home sales after the reform was announced, with a £401m shortfall in stamp duty attributed to changes in the non-dom regime. Private banks and law firms report elevated enquiries about residency changes and international structuring. The specific volume is contested; the underlying shift is real. This article treats destination data as directional rather than precise.
Zero personal income tax · Zero capital gains tax · Zero inheritance tax on individuals
The UAE absorbed the largest share of departing UK non-doms and consistently ranks as the world's top destination for HNW migration by net inflow. The combination of zero personal income tax, zero capital gains tax, and no inheritance tax on individual worldwide assets represents the most favourable tax environment available in a major global city. Dubai's infrastructure, connectivity, English-language environment, and quality of international schools make it operationally viable rather than merely tax-efficient.
The Golden Visa programme — a ten-year renewable residency available through property investment from AED 2 million (approximately £440,000) or other qualifying routes — provides long-term certainty that temporary visa arrangements do not. Henley & Partners projected a net inflow of 9,800 millionaires into the UAE in 2025. The DIFC and Abu Dhabi Global Market provide financial regulatory frameworks familiar to London-trained professionals. Our detailed Dubai expat-life guide and UAE Golden Visa vs Dubai residency comparison cover the operational side.
The honest limitation: The UAE is not a permanent cultural home for most who choose it. Summer temperatures exceed 45°C. The social infrastructure of a city that has existed for fifty years cannot replicate what London, Milan, or Lisbon offer in terms of cultural depth. Most who relocate to Dubai treat it as a defined chapter — wealth accumulation, school years for children — rather than a permanent settlement.
€300,000 flat annual tax on all foreign income · 15 year duration · €50,000 per family member
Italy's flat tax regime for new residents — formally Article 24-bis of the TUIR — replaced progressive taxation of foreign income with a single annual lump sum. The 2026 Budget Law increased the levy from €200,000 to €300,000 for new entrants from 1 January 2026, plus €50,000 per qualifying family member (up from €25,000). The regime runs for fifteen consecutive years and is grandfathered — those who entered before the increase continue on their original rate.
For a former UK non-dom with €5m or more in foreign annual income, the mathematics are compelling. The tax on that income in the UK would be over £2m at 45%. Italy's flat tax costs €300,000 — approximately £255,000 at current rates. The saving exceeds £2m per year. Italian-source income remains subject to ordinary Italian tax; the flat tax covers foreign income only. Our honest guide to Italy's flat tax covers the mechanics in detail, and Italy vs Portugal vs Greece compares against the alternatives.
What made Italy specifically attractive to the UK non-dom community post-2025 is the timing. The UK abolition created a one-time window to exit before the full UK tax charge crystallised, and Italy's pre-established regime was ready to receive them.
The honest consideration: The regime costs more than it did. At €300,000, it is only economically rational for individuals with foreign income substantially above that threshold — as a rule of thumb, the regime makes sense at foreign income of approximately €1.5m or more annually. For those below this, other options may offer better value.
Expenditure-based lump sum taxation · Cantonal variation · No capital gains tax on private assets
Switzerland's lump-sum tax regime (Pauschalbesteuerung) taxes qualifying foreign residents on their Swiss living expenditure rather than income. The minimum taxable base is CHF 400,000 in most cantons, though the effective tax varies significantly by canton — Geneva and Zurich apply higher rates than Valais or Zug. There is no capital gains tax on private assets in Switzerland, which is particularly relevant for founders and investors with equity positions.
Switzerland attracts a different profile of non-dom relocatee than Dubai or Italy: those prioritising political and financial stability, discretion, proximity to European financial markets, and quality of life in a neutral jurisdiction. Geneva and Zurich maintain world-class private banking infrastructure, international schools, and professional service ecosystems built over centuries rather than decades. Our Zug and Zurich expat-life guide covers the day-to-day.
The honest consideration: Switzerland is expensive — Mercer ranks Zurich and Geneva among the world's most expensive cities for expatriates. The lump-sum regime requires genuine residency and substantial expenditure in Switzerland; it is not available as a nominal arrangement. The minimum cantonal requirements have increased in recent years as Swiss authorities have tightened administration of the regime.
IFICI (NHR 2.0): 20% flat tax on qualifying Portuguese income · Foreign income exempt · 10 years · Restricted eligibility
Portugal's non-habitual resident regime — which attracted tens of thousands of HNW relocatees between 2009 and 2024 — was replaced by the IFICI (Tax Incentive for Scientific Research and Innovation) from January 2025. The original NHR closed to new applications in March 2025. IFICI is more restrictive: it targets highly qualified professionals in specific sectors (technology, science, healthcare, innovation, higher education) rather than the broad wealth and passive income category the original NHR covered.
For those who qualify — technology executives, medical specialists, researchers, startup founders working in qualifying sectors — IFICI offers a 20% flat tax rate on Portuguese-source income and exemption on most foreign-source income for ten years. Portugal's appeal as a country — climate, food, safety, English-language accessibility, quality of life — remains unchanged. The tax regime is narrower than it was. Our Portugal relocation guide 2026 and Portugal Golden Visa fund route cover the practical alternatives.
The critical shift: Portugal no longer offers a broadly accessible preferential tax regime for retirees, passive investors, or the generalist wealthy. The IFICI is specifically targeted. Former UK non-doms with passive income portfolios — the category that most relied on the original NHR — cannot access IFICI. For this group, Portugal remains an attractive country but no longer a tax-efficient one in the way it was before 2025.
No capital gains tax · Progressive income tax up to 24% · Territorial taxation · Global Investor Programme
Singapore taxes income derived in Singapore at progressive rates up to 24%, but does not tax capital gains, foreign-sourced income (with some exceptions for funds and businesses), or offshore income not remitted to Singapore. For the right profile — founder with equity upside outside Singapore, investor with primarily non-Singapore income — this represents genuine tax efficiency alongside world-class infrastructure and political stability.
Singapore's Global Investor Programme provides permanent residency through qualifying investment — typically SGD 2.5m (approximately £1.5m) in approved channels. The island's legal system, financial regulation, and professional service infrastructure are at the highest global standard. For business-active HNWIs with Asia-Pacific interests or international investment portfolios, Singapore is operationally superior to most alternatives. Our Singapore expat-life guide, Dubai vs Singapore family comparison, and Singapore luxury 2026 guide cover the differences.
The honest consideration: Singapore is significantly more expensive than Dubai — cost of living is approximately 35–44% higher across comparable categories. Housing is expensive and geographically constrained. The cultural environment is structured and rule-governed in ways that some find restrictive. Singapore works exceptionally well as a long-term base; it works less well as a transient tax haven.
Monaco should be mentioned briefly. Long the default choice for the wealthiest UK non-doms, Monaco continues to attract a segment of departing UK residents — particularly those with existing Riviera ties and the seven-figure-plus liquid assets required to establish residency there. It is a smaller-volume destination than the five above but a significant one at the very top end.
Property viewing trips across three or four destinations in ten days rarely work on commercial connections — the timing kills each visit. Charter direct into the airport that matters, on the schedule that fits the appointments.
Get a private charter quote → Viewing-trip villa guide →The headline narrative — everyone is going to Dubai — is an oversimplification. Dubai received the largest volume of departures because it offers the cleanest tax position, the easiest residency route, and the most developed infrastructure for mobile wealth. It is the default choice for those whose primary driver is tax efficiency and who have flexibility on lifestyle.
Italy received a disproportionate share of the cultural and lifestyle-driven departures — former non-doms for whom London's cultural, social, and physical environment was part of the attraction, and who sought an equivalent in Europe. The flat tax regime provided the fiscal mechanism; the quality of life in Milan, Rome, Florence, and the Italian countryside provided the pull.
Switzerland, Singapore, and to a lesser extent Monaco received the more business-constrained departures — those whose professional infrastructure, client relationships, or business operations placed specific geographic requirements on their residency choice. Our best countries for UK non-doms 2026 guide runs the more detailed comparison, and where the UK non-dom exodus is going covers the operational side of the move.
Multi-jurisdiction residency, private banking across borders, and site visits to sensitive locations all raise the surface area for financial and digital surveillance. Our residence and domicile privacy guide covers the structural side; on the digital side, a business-grade VPN like NordVPN is the minimum sensible baseline for the internationally mobile.
The tax structure gets most of the attention, but the operational side of a serious relocation usually determines how well the first year goes. Three items reliably underdeliver when they are not planned properly.
Site-visit trips before the decision. The right decision is nearly always made in person. A property visit to Milan, Dubai, and Zurich in ten days is difficult on commercial connections — flight timings compress each visit and the hotel-to-appointment logistics never quite work. Charter aviation solves the timing problem by fitting the flight around the appointments, not the other way round. Our viewing-trip villa guide covers where to stay during these visits, and the first-90-days relocation checklist covers what needs to be resolved on the ground.
Health cover in the transition year. Standard UK health cover ends when residency changes, and destination public healthcare (or private cover) usually has a waiting period or eligibility qualifier that creates a gap. International health cover from SafetyWing is designed exactly for this scenario — cover that follows you across jurisdictions and does not require a fixed home base.
Connectivity during scoping. Property viewing across three countries in a fortnight means three SIMs or expensive roaming. A regional eSIM through Airalo covers Europe, the Middle East, and Asia on a single plan installed before you leave. Small item, but the friction of buying local SIMs on arrival at three airports adds up quickly.
Alongside the tax structure, our practical infrastructure guide and family relocation schooling decision cover the wider execution side, and the international schools comparison for Dubai, Singapore and Geneva covers the school-selection axis that often determines the destination.
The old non-dom regime is abolished and cannot be accessed by new arrivals. New UK arrivals who have not been UK-resident for the previous ten consecutive years can access the four-year Foreign Income and Gains relief, which provides exemption from UK tax on foreign income and gains for the first four years of UK residence. This is more limited than the former non-dom regime, which could last up to fifteen years.
No. Italy's flat tax regime covers foreign-source income only — income arising outside Italy. Italian-source income remains subject to ordinary Italian progressive income tax. UK-source income (rental from UK property, UK dividends, UK capital gains) would still potentially be subject to both Italian ordinary tax and UK tax, subject to the Italy-UK double tax treaty. Specific tax advice is essential before relying on this distinction.
Those who validly obtained NHR status before the transitional deadline retain their status until the end of their ten-year period. No new NHR applications are possible — the programme closed in March 2025. The replacement regime, IFICI, has different eligibility criteria and is not accessible to passive income holders or general retirees in the way the original NHR was.
Establishing genuine non-UK tax residency requires more than purchasing a property abroad. You need to meet the UK Statutory Residence Test conditions for non-residence — broadly, spending fewer than 16 days in the UK in the tax year (for those who have previously been UK-resident for fifteen or more of the previous twenty years), or meeting other conditions depending on your specific history. The rules are complex. Qualified UK tax advisers and international tax specialists in the destination country should be engaged before and during the transition.
The 16,500 figure comes from Henley & Partners' 2025 Private Wealth Migration Report and has been widely cited but is disputed. The Tax Justice Network and Tax Policy Associates have both published methodological critiques, and Henley itself softened its language in its 2026 report, acknowledging that migration was modest and dropping several country-level estimates. What is not disputed is the direction of travel: HMRC data shows a material decline in non-dom registrations, Knight Frank recorded a 14 percent drop in five-million-pound-plus London home sales, and private banks and law firms report elevated relocation enquiries. Treat the specific number as a data point rather than settled fact; the underlying trend is real.
This article is for informational purposes only and does not constitute tax, legal, or financial advice. Tax rules are complex, change frequently, and depend on individual circumstances. Always seek advice from qualified tax advisers in both your home country and destination country before making relocation decisions. Migration data attributed to Henley & Partners represents that firm's projections and has been publicly disputed by Tax Justice Network and Tax Policy Associates; treat it as directional rather than official statistics. This article contains affiliate links to TimeFlys, SafetyWing, Airalo, and NordVPN — bookings and sign-ups through these links may earn a commission at no additional cost to you.
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