Wealth mobility after the abolition of the non-dom regime: from reaction to strategic planning

The global movement of wealthy individuals appears to be entering a new phase. After a period marked by significant political uncertainty, tax reform and high-profile relocation decisions, recent data suggests that the number of high-net-worth individuals changing, or actively planning to change, their principal tax residence has fallen sharply.

This does not mean that wealth mobility is no longer relevant. On the contrary, relocation remains a central planning point for internationally mobile individuals and families. However, the nature of the discussion is changing. The emphasis is moving away from immediate, event-driven reactions and towards more structured, long-term planning around residence, succession, asset protection and family governance.

A slowdown in tax-driven relocation

Recent reporting based on Capgemini’s 2026 World Wealth Report indicates that the proportion of wealthy individuals who changed, or intended to change, their principal tax residence in 2025 fell materially compared with the previous year. The reduction appears particularly pronounced in the United Kingdom, where the abolition of the non-dom regime had already prompted a number of affected individuals to review their position.

This is an important development. Over the last two years, the UK has been at the centre of the international private wealth debate following the decision to abolish the remittance basis of taxation and replace the old domicile-based framework with a residence-based regime. From 6 April 2025, all UK residents are generally taxed on the arising basis in respect of worldwide income and gains, subject to the new Foreign Income and Gains regime available to qualifying new arrivals during their first four years of UK tax residence.

For many long-term UK resident non-domiciled individuals, the reform represented a fundamental change. The previous regime allowed qualifying individuals to shelter foreign income and gains from UK taxation provided these were not remitted to the United Kingdom. The new framework is substantially different and requires a fresh analysis of residence history, foreign income and gains, offshore structures, trusts, inheritance tax exposure and future remittance planning.

It is therefore unsurprising that the initial reaction was significant. Those most directly affected, particularly individuals with substantial foreign assets or offshore structures, were required to consider whether remaining UK resident remained compatible with their wider tax and succession planning. In that sense, the sharp decline in further intended departures may indicate not that the issue has disappeared, but that the first wave of decision-making has already taken place.

The UK position: less panic, more planning

The UK remains a complex jurisdiction for private wealth planning. The abolition of the non-dom regime has reduced one of the country’s long-standing attractions for internationally mobile individuals. At the same time, the United Kingdom continues to offer important non-tax advantages, including legal certainty, deep financial markets, education, professional services, political stability compared with many jurisdictions, and lifestyle factors that remain highly relevant for families.

The result is a more nuanced position than a simple “wealth exodus” narrative suggests.

Some individuals have left, or will leave, because the new regime materially changes their tax profile. Others may decide to remain because the non-tax factors outweigh the additional tax cost. A further category may still be attracted to the UK under the new four-year Foreign Income and Gains regime, particularly where they have not been UK tax resident in the previous ten years and are considering a defined period of residence in the United Kingdom.

This distinction is important. The UK is no longer offering the same long-term remittance basis model that historically attracted non-domiciled individuals. However, it may still remain competitive for certain new arrivals, especially where the expected period of UK residence is limited and the individual can benefit from the new regime during the initial four-year window.

Tax is no longer the only driver

A further point emerging from recent data is that wealthy individuals appear less likely to identify lower tax rates as the sole reason for relocation. Increasingly, mobility decisions are also linked to inheritance planning, family security, political stability, education, access to markets and the long-term governance of family wealth.

This is consistent with what is typically seen in private client planning. Relocation decisions are rarely purely tax-driven. A move to another jurisdiction may create tax advantages in one area while introducing complexity in another. For example, a change in residence may alter exposure to income tax, capital gains tax, wealth taxes, inheritance tax, forced heirship rules, exit taxes, reporting obligations and the treatment of trusts or foundations.

For international families, the question is therefore not simply “which jurisdiction has the lowest tax rate?” The better question is whether the jurisdiction is coherent with the family’s overall objectives. These may include succession planning, asset protection, business continuity, children’s education, philanthropic arrangements, access to healthcare, governance of family companies and the preservation of flexibility for future generations.

The importance of succession and inheritance tax planning

The increased focus on inheritance planning is particularly relevant in the UK context. The replacement of the non-dom regime has also been accompanied by wider changes to the inheritance tax landscape for internationally connected individuals. Residence, rather than domicile, is becoming increasingly central to the UK tax analysis.

For wealthy families, inheritance tax exposure can be more significant than annual income tax or capital gains tax leakage. A poorly planned residence position may affect not only the individual during their lifetime, but also the transmission of wealth to the next generation.

This makes pre-arrival and pre-departure planning essential. Individuals considering leaving the UK should assess the impact of departure on their existing structures, foreign assets, UK situs assets, trusts, companies and family members who remain UK resident. Similarly, individuals considering moving to the UK should review the position before becoming UK resident, rather than after arrival.

The timing of a move can be decisive. Residence days, split-year treatment, remittances, trust distributions, asset rebasing, disposals, dividend planning and debt restructuring may all have different consequences depending on whether they occur before or after UK residence begins or ends.

Destination jurisdictions: opportunity and caution

Recent data suggests that Singapore and the United States remain among the most attractive destinations for wealthy individuals. Other jurisdictions, including Italy, Switzerland, the United Arab Emirates, Portugal and Monaco, also continue to feature regularly in private wealth relocation discussions, depending on the family’s profile and objectives.

However, destination planning should not be approached superficially. A favourable headline regime does not automatically mean that relocation will be effective or sustainable. The individual must consider local residence requirements, immigration status, substance, reporting obligations, treaty access, inheritance rules, matrimonial property considerations and the treatment of existing trusts or corporate structures.

In addition, tax authorities increasingly scrutinise whether a change of residence is genuine. It is not sufficient to obtain residence status in another jurisdiction if the individual’s personal, economic and family connections remain substantially elsewhere. Effective relocation requires practical consistency: home, family life, business activities, board positions, investment management, travel patterns and documentary evidence should all support the intended residence position.

Practical considerations for internationally mobile individuals

For individuals and families reviewing their residence position, the key starting point should be a full mapping exercise. This should identify current and historic tax residence, domicile or deemed domicile status where relevant, citizenships, asset locations, trust and company structures, income sources, expected liquidity events, family members’ residence positions and succession objectives.

Once this has been established, the analysis should consider the tax consequences of remaining in the current jurisdiction, relocating to a new jurisdiction, or adopting a more flexible multi-jurisdictional lifestyle. Particular care should be taken where the individual has substantial unrealised gains, offshore trusts, carried interest, family investment companies, real estate portfolios or business interests managed across borders.

Documentation is also critical. Residence planning should be supported by clear evidence, including travel records, lease or property documentation, employment or board arrangements, school records, healthcare registration, banking arrangements and minutes of relevant decision-making where companies or trusts are involved.

Finally, any relocation should be coordinated across jurisdictions. Advice limited to the departure country is rarely sufficient. A move from the UK to another country, for example, requires an integrated analysis of UK exit implications, the tax regime of the destination jurisdiction, treaty position, reporting obligations and any transitional rules.

Final considerations

The recent slowdown in wealthy individuals changing tax residence should not be interpreted as the end of global wealth mobility. Rather, it suggests that the immediate reaction to recent political and tax shocks may be stabilising. The first wave of departures following major reforms, including the abolition of the UK non-dom regime, may already have occurred.

The next phase is likely to be more strategic. Wealthy individuals and families will continue to move, but decisions are increasingly likely to be driven by a broader assessment of tax, succession, governance, lifestyle and geopolitical risk.

For the United Kingdom, the position remains finely balanced. The abolition of the non-dom regime has materially changed the private client landscape, but the UK continues to offer non-tax advantages that remain significant. For new arrivals, the four-year Foreign Income and Gains regime may still provide a window of opportunity. For existing residents, the focus should be on reviewing exposure, restructuring where appropriate and ensuring that any decision to remain or relocate is based on a complete cross-border analysis.

In this environment, mobility should not be treated as a reaction to tax reform alone. It should be approached as part of a wider wealth planning strategy, with residence, succession and family governance considered together.