Everything ultra-high-net-worth individuals need to know about relocating to the United Kingdom after the abolition of the non-dom regime
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The United Kingdom has long attracted wealthy individuals from around the world seeking a stable jurisdiction with world-class education, sophisticated financial services, and an established legal system. However, the landscape for high-net-worth and ultra-high-net-worth individuals considering UK residency has fundamentally changed in 2025, requiring a complete reassessment of immigration strategies and tax planning approaches.
If you are contemplating a move to the United Kingdom or currently hold UK residency, understanding these changes is essential for protecting your wealth and making informed decisions about your future. This comprehensive guide examines the current visa options, the dramatic transformation of the non-domicile tax regime, inheritance tax implications, and strategic planning considerations for affluent individuals navigating this new environment.
The End of the Golden Visa Era
For decades, the Tier 1 Investor Visa offered wealthy individuals a straightforward pathway to UK residency. By investing a minimum of two million pounds in qualifying UK investments, applicants could secure residency and eventually permanent settlement. Higher investment thresholds of five million or ten million pounds accelerated the timeline to indefinite leave to remain, with some investors achieving settlement in as little as two years.
The Home Office closed this route to new applicants in February 2022, citing concerns over source of funds verification, national security considerations, and broader questions about the integrity of the programme. This decision left the United Kingdom without a direct investment-based immigration route, distinguishing it from other jurisdictions that continue offering residency or citizenship by investment programmes.
Existing Tier 1 Investor visa holders retain the ability to extend their visas until February 2026 and apply for indefinite leave to remain until February 2028, provided they continue meeting the investment maintenance requirements. For these individuals, careful attention to deadlines and portfolio compliance remains critical to preserving their settlement pathway.
For prospective applicants, however, the message is clear: the United Kingdom no longer offers residency in exchange for passive investment. Those seeking UK residency must now explore alternative pathways requiring more active engagement with the British economy.
Current Visa Options for Wealthy Individuals
Despite the closure of the investor route, several visa categories remain available to high-net-worth individuals willing to contribute actively to the UK economy. Understanding these options enables informed decision-making about whether UK residency aligns with your objectives.
Innovator Founder Visa
The Innovator Founder Visa represents the primary route for entrepreneurs seeking to establish businesses in the United Kingdom. Introduced in April 2023, this category replaced the previous Innovator and Start-up visa schemes with a streamlined pathway focused on innovation and economic contribution.
Unlike the former investor visa, this route requires active business involvement rather than passive capital deployment. Applicants must demonstrate a business concept that is genuinely innovative, commercially viable, and structured for scalability. A Home Office-approved endorsing body must validate the business plan before any visa application proceeds.
The endorsement process scrutinizes whether the proposed venture offers something meaningfully different from existing market offerings. Generic business models or simple extensions of established concepts typically fail to secure approval. Successful applicants demonstrate clear competitive advantages, technological differentiation, or novel approaches to market problems.
Significantly, no minimum investment threshold applies to the Innovator Founder route. However, applicants must demonstrate sufficient funding to execute their business plans, and settlement requirements include criteria around investment levels, revenue generation, or job creation. Many successful applicants invest between fifty thousand and one hundred thousand pounds in their ventures, though individual circumstances vary considerably.
The accelerated settlement timeline proves attractive for many applicants. After three years of continuous residence and demonstrated business success, Innovator Founders may apply for indefinite leave to remain. This compares favourably to the five-year residence requirement applicable to most other visa categories.
Global Talent Visa
The Global Talent Visa provides an alternative pathway for individuals recognised as leaders or emerging leaders in specific fields. While commonly associated with academic researchers and creative professionals, this route also accommodates exceptional business talent and technology pioneers.
Endorsement from a designated competent body is required, with different organisations handling different sectors. Applicants must demonstrate exceptional achievement or exceptional promise in their field through substantial evidence of accomplishments, recognition, and impact.
Successful applicants enjoy considerable flexibility, including the ability to work for any employer, pursue self-employment, or establish businesses. The route leads to indefinite leave to remain after three years for recognised leaders or five years for those endorsed as having exceptional promise.
Skilled Worker Self-Sponsorship
An increasingly popular approach involves establishing a UK company that obtains a sponsor licence, then sponsoring the founder’s own skilled worker visa. This self-sponsorship arrangement requires navigating complex regulatory requirements but offers a pathway to UK residency for individuals with genuine business intentions.
The sponsoring company must demonstrate that it is a legitimate, operating business capable of meeting its sponsorship obligations. Applications for sponsor licences face considerable scrutiny, and the Home Office rejects applications from businesses that appear structured primarily to facilitate immigration rather than genuine commercial activity.
Self-sponsorship arrangements work best when the underlying business has genuine commercial substance, including office premises, employees, clients, and trading activity. Those considering this approach should engage experienced immigration advisors and ensure their business planning addresses both commercial and regulatory requirements.
Understanding the New Non-Dom Tax Landscape
The abolition of the non-domicile tax regime from April 2025 represents the most significant change to UK taxation of internationally mobile individuals in decades. Anyone considering UK residency must understand these changes thoroughly before making relocation decisions.
The Historical Remittance Basis
Previously, individuals resident in the United Kingdom but domiciled elsewhere could elect to be taxed on the remittance basis. Under this arrangement, UK tax applied to UK-source income and gains in full, but foreign income and gains attracted UK tax only when remitted to the United Kingdom.
This created powerful planning opportunities for wealthy individuals with substantial overseas assets. Investment income, capital gains, and other wealth accumulation occurring outside the UK could compound tax-free, provided the funds remained offshore. The system attracted considerable numbers of wealthy individuals to the UK, who contributed to the economy through spending, employment, and investment while benefiting from favourable tax treatment on their international wealth.
The remittance basis remained available for up to fifteen years before individuals became “deemed domiciled” and lost access to these benefits. Annual charges applied after seven years of residence, and individuals claiming the remittance basis sacrificed their personal allowance and capital gains tax annual exemption.
The New Residence-Based Regime
From 6 April 2025, domicile no longer determines UK tax treatment for income and capital gains purposes. Instead, a residence-based system applies to all UK residents regardless of their domicile status.
The most significant feature for new arrivals is the four-year Foreign Income and Gains regime. Individuals who become UK tax resident after at least ten consecutive years of non-UK residence may claim relief on their foreign income and gains for their first four years of UK residency. During this period, foreign income and gains are entirely exempt from UK tax, regardless of whether funds are brought to the UK or remain offshore.
This represents a substantial benefit for qualifying new arrivals, effectively providing a four-year window during which foreign wealth can be restructured, investments realised, and affairs organised without UK tax consequences on international assets. However, the four-year duration is significantly shorter than the fifteen-year benefit available under the previous regime.
After the four-year period expires, UK residents face taxation on worldwide income and gains as they arise. There is no longer any benefit to keeping money offshore, and the previous distinction between remitted and unremitted foreign income becomes irrelevant for new accruals.
Transitional Arrangements for Existing Residents
Individuals who previously claimed the remittance basis and remain UK resident face the transition to worldwide taxation from April 2025. However, several transitional provisions provide planning opportunities.
The Temporary Repatriation Facility allows former remittance basis users to bring historic foreign income and gains to the UK at reduced tax rates. Funds designated in 2025/26 or 2026/27 attract a twelve percent tax rate, increasing to fifteen percent in 2027/28. This facility applies only to income and gains arising before 6 April 2025, not to new accruals.
For individuals with substantial unremitted foreign income and gains accumulated over years or decades, the TRF provides a time-limited opportunity to bring these funds to the UK at rates considerably below the standard income tax and capital gains tax rates that would otherwise apply. Careful analysis of existing foreign holdings is essential to determine optimal use of this facility.
Additionally, individuals who claimed the remittance basis for at least one year between 2017/18 and 2024/25 benefit from automatic rebasing of foreign assets to their market value on 5 April 2017. This reduces the capital gains tax exposure on historic appreciation, though gains accruing after that date remain fully taxable.
Inheritance Tax: The Long-Term Residence Test
The changes extend beyond income and capital gains to fundamentally reshape inheritance tax exposure for international individuals and their trusts.
From Domicile to Residence
Previously, inheritance tax on worldwide assets applied to individuals who were UK domiciled or deemed UK domiciled. Non-domiciled individuals faced UK inheritance tax only on their UK-situated assets, with foreign assets remaining outside the UK inheritance tax net.
From 6 April 2025, the domicile concept is replaced with a long-term residence test for inheritance tax purposes. Individuals become subject to UK inheritance tax on their worldwide assets once they have been UK resident for ten of the previous twenty tax years.
The implications are substantial. Someone who has lived in the UK for a decade, regardless of their domicile status or intentions, will find their global estate potentially subject to UK inheritance tax at forty percent. This applies to assets held anywhere in the world, including foreign property, overseas investments, and international business interests.
The Departure Tail
Perhaps more significant for planning purposes is the lengthy “tail” that continues after departure from the UK. Individuals who have been long-term residents remain within the UK inheritance tax net for a period after leaving, depending on how long they were resident.
Someone who was UK resident for twenty years would remain subject to UK inheritance tax on worldwide assets for ten years after departing the UK. Even relatively short periods of UK residence can result in extended tail provisions lasting three years or more.
This fundamentally changes the calculus for wealthy individuals considering UK residency. What was previously a temporary arrangement during which international assets remained protected may now create inheritance tax exposure lasting a decade or more after leaving.
Impact on Offshore Trusts
The changes also affect offshore trust structures that have historically provided inheritance tax protection. Previously, non-UK assets settled in trust by individuals who were neither domiciled nor deemed domiciled in the UK remained “excluded property” outside the UK inheritance tax net, even if the settlor later became UK resident.
From April 2025, the inheritance tax status of trust assets depends on the settlor’s long-term residence status rather than their domicile when the trust was created. If the settlor is a long-term UK resident at the time of a chargeable event, non-UK assets held in offshore trusts may be brought within the UK inheritance tax charge.
This represents a fundamental departure from previous planning approaches. Trusts established decades ago by individuals who were non-domiciled when they settled assets may now face UK inheritance tax exposure on their worldwide holdings.
Transitional provisions offer some protection for existing structures, particularly trusts established before 30 October 2024 by individuals who were not UK domiciled at that time. However, the details are complex, and professional advice is essential for anyone with existing offshore trust arrangements.
Strategic Tax Planning Considerations
Given these substantial changes, individuals considering UK residency or currently resident in the UK should undertake comprehensive planning reviews addressing multiple dimensions of their affairs.
Pre-Arrival Planning
For individuals who have not yet become UK resident, the period before arrival presents valuable planning opportunities. The four-year FIG regime provides significant protection for foreign income and gains during initial years of UK residence, but careful structuring before arrival can maximise these benefits.
Realising capital gains before becoming UK resident removes those gains entirely from the UK tax net. Restructuring investment portfolios, selling appreciated assets, and crystallising profits before arrival should be carefully considered against commercial and tax implications in other jurisdictions.
Similarly, income timing can affect exposure during the transition to UK residence. Bonuses, dividends, and other payments received before becoming UK tax resident avoid UK taxation entirely, while the same payments received after arrival may attract UK tax depending on whether the individual qualifies for FIG relief.
The long-term residence test for inheritance tax also rewards pre-arrival planning. Establishing offshore trusts before becoming UK resident, while the settlor is not a long-term resident, may preserve excluded property status for non-UK assets under transitional provisions.
During UK Residence
Individuals who qualify for the four-year FIG regime should consider whether claiming this relief optimises their overall position. Claiming FIG relief results in loss of the personal allowance and capital gains tax annual exemption, so individuals with limited foreign income may benefit more from paying UK tax normally.
During the FIG period, no distinction exists between remitted and unremitted foreign income and gains—all are equally protected from UK tax. This provides opportunities to consolidate overseas holdings, reorganise international structures, and bring foreign funds to the UK without tax consequences.
However, individuals should plan carefully for the transition to worldwide taxation after their fourth year. Steps taken during the protected period can significantly affect future tax exposure.
Exit Planning
Given the long inheritance tax tail applying after departure, individuals who may leave the UK should consider timing and structure carefully. The duration of the tail depends on how long the individual was a long-term resident, creating potential advantages for departing before completing ten years of residence.
However, immigration considerations may constrain options. Indefinite leave to remain requires continuous residence, and extended absences can jeopardise settlement applications or result in loss of ILR status.
Coordinating immigration objectives with tax planning requires careful analysis of individual circumstances, including the value of UK residency rights, exposure to inheritance tax, and plans for future residence.
Wealth Structuring in the New Environment
The changes require fundamental reconsideration of traditional wealth structuring approaches. Techniques that proved effective under the previous regime may now prove counterproductive or even create additional complications.
Trust Structures
Offshore trusts face substantially reduced benefits for UK residents under the new regime. Income and gains arising within settlor-interested trusts will generally be taxable on UK resident settlors as they arise, eliminating the previous deferral benefits.
For new arrivals qualifying for the four-year FIG regime, settling trusts before becoming UK resident may preserve some benefits during the protected period. However, once the settlor becomes subject to worldwide taxation, the trust protections largely disappear.
Existing trusts require careful review to understand their status under transitional provisions and ongoing exposure. Some structures may benefit from restructuring, while others may be better left unchanged depending on specific circumstances.
Investment Structures
Investment bonds and other insurance-based structures may offer continued benefits through tax deferral and favourable withdrawal treatment. However, these products require careful analysis against alternatives and may not suit all circumstances.
Pension contributions remain highly tax-efficient for UK residents, offering income tax relief on contributions and tax-free investment growth within the pension wrapper. International individuals should consider whether UK pension arrangements align with their long-term plans, particularly given complexities around overseas transfers and death benefit taxation.
Business Structures
For entrepreneurs and business owners, corporate structures require evaluation against both commercial objectives and personal tax exposure. UK companies are subject to corporation tax on worldwide profits, but can provide more favourable treatment than personal ownership for certain income types.
Employment arrangements, profit extraction strategies, and exit planning all require consideration against the individual’s residence status, applicable reliefs, and long-term intentions.
Is UK Residency Still Attractive?
The cumulative effect of these changes raises legitimate questions about whether UK residency remains attractive for wealthy individuals. The abolition of the non-dom regime, combined with inheritance tax exposure after relatively short residence periods, represents a significant shift in the UK’s competitive position.
Several factors continue to favour the United Kingdom as a residence location. The legal system provides strong property rights and contract enforcement. Educational institutions remain among the world’s finest. The financial services sector offers sophisticated wealth management, banking, and investment capabilities. Political stability, though occasionally questioned, compares favourably to many alternative jurisdictions.
The four-year FIG regime for new arrivals provides a meaningful transition period during which foreign wealth remains protected. For individuals planning limited UK residence—perhaps while children complete their education—the combination of lifestyle benefits and tax-protected initial years may prove attractive.
However, individuals planning indefinite UK residence face eventual worldwide taxation and inheritance tax exposure that compares unfavourably to jurisdictions offering permanent territorial taxation or residency by investment programmes with more generous terms.
The optimal approach depends entirely on individual circumstances, including existing asset structures, family situations, commercial interests, and personal preferences. Professional advice from immigration lawyers, tax advisors, and wealth planners working in coordination is essential for making informed decisions.
Taking Action
Whether you are considering UK residency, currently resident under transitional arrangements, or reassessing your position in light of these changes, prompt action is advisable. The implementation of the new regime from April 2025 creates deadlines for certain elections and planning opportunities.
Review your current structures with advisors familiar with both the previous and new regimes. Understand how transitional provisions apply to your specific circumstances. Consider whether existing trusts, investments, and arrangements require restructuring.
For those yet to arrive in the UK, evaluate whether the four-year FIG regime provides sufficient protection for your objectives, and consider pre-arrival planning to maximise available benefits.
The landscape has changed dramatically, but opportunities remain for those who approach UK residency with proper planning and professional guidance. Understanding the new rules and their implications is the essential first step toward protecting your wealth while achieving your residency objectives.
This article provides general information only and does not constitute legal, tax, or immigration advice. Individual circumstances vary significantly, and professional advice tailored to your specific situation is essential before making decisions affecting your residency status or tax position.