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Non-Domiciled Individuals

Navigating personal and business tax complexities for non-domiciled individuals

The abolition of the non-dom tax regime

In the Spring Budget 2024 Jeremy Hunt announced the abolition of the non-dom tax regime and a new modernised ‘tax holiday’ for individuals moving to the UK.

It is one of the most significant reforms to the non-dom tax regime in our generation. Many affected individuals will now face a dilemma due to the proposed rules, in terms of both their existing structures and ongoing exposure to UK Tax.

In this video series and associated articles we highlight what this could mean for you and how you can prepare for the changes.

Inheritance Tax (IHT)

With domicile no longer playing a part in the IHT regime, the new rules dictate that an individual’s worldwide estate is subject to UK IHT once they’ve been UK resident for 10 years, previously 15.

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Transitional provisions

The three main transitional concessions the Chancellor proposed in the Spring Budget for certain individuals are:

  • Only 50% of foreign income will be subject to UK tax in 2025/26
  • Individuals who have previously claimed the remittance basis at some point will be able to make a remittance of previously untaxed income and gains in either the 2025/26 or 2026/27 tax year at a flat rate of 12%
  • Individuals will be able to rebase their non-UK assets to the market value as at April 2019
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Trust Protection

UK resident non-domiciled individuals can currently benefit from a tax-free roll up of non-UK income and gains where assets are held in a trust structure. From 6 April 2025 the existing trust protection will cease.

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Foreign Income and Gains Regime

When coming to the UK for assignments or short-term work, both employers and employees will be impacted by the abolition of the non-domiciled regime and the introduction of the new Foreign Income and Gains (FIG) Regime.

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The impact for Americans in the UK

Many US citizens and US ‘green card’ holders who live and work in the UK will be impacted by the abolition of the UK’s non-dom tax regime.

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Non-domicile individuals relocating to other countries – A webinar series

From April 2025 the current non-dom regime will be abolished, and we are aware that many people are considering their options

We understand the complexities and considerations involved in relocating to a new country. Our upcoming webinar series is tailored specifically for non-domiciled individuals looking to make a move

Our webinars will delve into the key tax and financial aspects that non-domiciled individuals need to be aware of when considering a relocation and the local considerations each country presents

Hosted by our international experts, and in some cases local partners

How we can help

If you would like to discuss how the abolition of the non-dom regime will impact you, please get in touch with John Bull, one of the team below, or your usual Blick Rothenberg contact.

Contact John

John Bull 2024
John Bull
Partner, Head of Private Client
View John's profile