Non-dom Status In The UK
Non-dom Status In The UK
“Non-dom” describes a UK resident whose permanent home – or domicile – for tax purposes is outside the UK. It refers to a person’s tax status. While the UK government estimates that abolishing the non-dom tax status, will raise over £12 billion to £34 billion over the next five years. However, analysts warn that the changes could actually cost the Treasury, with some estimates suggesting a potential £10 billion annual loss in revenue due to the exodus of wealthy individuals. Most non-doms are based in London, particularly in areas like Kensington and Westminster. The UK government abolished this system to replace it with a new, residence-based regime.
- New System: From April 6, 2025, a new four-year foreign income and gains (FIG) regime was introduced. New arrivals to the UK do not pay tax on foreign income for their first four years of residence, but after that, they are taxed on their worldwide income.
- Transition: Specific rules, including a Temporary Repatriation Facility (TRF) and capital gains tax rebasing, were introduced to help transition existing non-doms to the new system.
- Disclaimer: This information reflects the status of the non-dom regime up to its abolition in April 2025 and subsequent changes.
Ref Policy Paper: Reforming The Taxation Of Non-UK Domiciled Individual
New Residence Based System
The UK government is abolishing the traditional non-dom status, to replace it with a new residence-based system starting in April 2025. The net impact remains highly uncertain, depending on whether the tax increase on those who stay, outweighs the loss of investment from those who leave. While the government aims to raise significant revenue, some studies suggest that if 25% of non-doms leave, the net gain could be zero, and a 50% exodus could lead to a £2.4 billion loss in the first year alone.
Potential Gains vs. Losses
- Economic Impact: The changes have already been linked to a £400 million loss in stamp duty revenue.
- Wealth Migration: Reports indicate a significant “flight” of high-net-worth individuals, with one report predicting a net loss of approximately 16,500 millionaires from the UK in 2025.
- Impact on Revenue: Non-doms contributed just under £9bn in tax in 2023. The loss of this tax base could necessitate a 1.5p increase in the basic rate of income tax to compensate.
- Alternative View: Some, such as researchers from the London School of Economics, have argued that scrapping the tax status could actually raise £3.6 billion a year, suggesting that the feared mass exodus may be exaggerated.
The final impact of the changes introduced to make the tax system fairer by ensuring long-term residents pay tax on foreign income, is dependent on the behavioural response of non-doms. Approximately 83,000 to 83,900 people in the UK held non-domiciled (non-dom) tax status in the year ending 2024, representing a slight decline from previous years. Figures from HMRC show that while the number of individuals claiming this status was roughly 68,800 to 74,000 between 2021 and 2023, total taxpayers including “deemed” domiciles reached about 83,800 in 2022/23.
- Recent Data (2023-2024): An estimated 83,000 non-domiciled and deemed domiciled taxpayers existed, with 9,100 new arrivals and 9,500 people leaving the status.
- Previous Data (2021-2022): HMRC reported 68,800 individuals claimed non-dom status in the 2021-22 tax year.
- Trend: The number of non-doms peaked in the early 2010s (over 113,000 in 2012/13) and has generally decreased due to rule changes.
- Concentration: Most non-doms are based in London, particularly in areas like Kensington and Westminster.
The UK government is abolishing the traditional non-dom status to replace it with a new residence-based system starting in April 2025.
Key Features of the Former Non-Dom Status:
- Definition of Domicile: Domicile is generally where a person’s father had his permanent home at the time of their birth, or a place they have adopted as their permanent home, which is not necessarily their country of birth or citizenship.
- Remittance Basis of Taxation: Non-doms could choose to be taxed on the “remittance basis.” This meant they only paid UK tax on foreign income or gains if they brought (remitted) that money into the UK.
- Costs and Duration: While non-dom status could be used indefinitely in theory, it became costly over time. After being in the UK for 7 of the last 9 years, a £30,000 annual charge was required; this rose to £60,000 after 12 of the last 14 years.
- “Deemed Domicile”: After living in the UK for 15 out of 20 years, individuals were automatically treated as “deemed domiciled” for tax purposes and taxed on their worldwide income, similar to standard UK residents.










