Britain’s ultra-wealthy exit ahead of proposed non-dom tax changes

LONDON — Monaco, Italy, Switzerland, Dubai. They’re just a few of the destinations trying to lure away the U.K.’s uber wealthy ahead of proposed changes to the country’s divisive non-dom tax regime.

Almost two-thirds (63%) of wealthy investors said they plan to leave the U.K. within two years or “shortly” if the Labour government moves ahead with plans to ax the colonial-era tax concession, while 67% said they would not have emigrated to Britain in the first place, according to a new study from Oxford Economics, which assesses the implications of the plans.

The U.K.’s non-dom regime is a 200-year-old tax rule, which permits people living in the U.K. but who are domiciled elsewhere to avoid paying tax on income and capital gains earnings overseas for up to 15 years. As of 2023, an estimated 74,000 people enjoyed the status, up from 68,900 the previous year.

Labour last month set out plans to abolish the status, expanding on a pledge set out in its election manifesto and stepping up earlier proposals by the previous Conservative government to phase out the regime over time. It comes as Prime Minister Keir Starmer had pledged to improve fairness and shore up the public finances, with further announcements expected in the Oct. 30 Autumn budget statement.

Finance Minister Rachel Reeves has said that scrapping the program could generate £2.6 billion ($3.45 billion) over the course of the next government. However, Oxford Economics’ research, which was produced earlier this month in collaboration with lobby group Foreign Investors for Britain, estimates the changes will instead cost taxpayers £1 billion by 2029/30.

CNBC reached out to the Treasury for comment and did not immediately receive a response.

“We are ringing out the alarm bell that this is a perilous time,” Macleod-Miller, CEO of Foreign Investors for Britain, told CNBC over the phone. “If the government doesn’t listen they’ll put at risk revenues for generations.”

Under the proposals, the concept of “domicile” will be eliminated and replaced with a resident-based system, while the number of years in which money earned abroad goes untaxed in the U.K. will be cut from 15 to four.

Individuals will also have to pay inheritance tax after 10 years of U.K. residency and would remain liable for 10 years after leaving the country. They will also be prevented from avoiding inheritance tax on assets held in trust.

However, Macleod-Miller, a private wealth practitioner who launched the lobby group in response to the proposals, said the changes would stymy wealth generation and is instead calling for a tiered tax regime.

According to the Oxford Economics research, which surveyed 72 non-doms and 42 tax advisors representing a further 952 non-dom clients, virtually all (98%) said they would emigrate from the U.K. sooner than previously planned if the reforms were implemented. The 72 non-doms surveyed were said to have invested £118 million each into the U.K. economy.

The majority (83%) cited inheritance tax on their worldwide assets as their key motivator for leaving, while 65% also referenced changes to income and capital gains tax.

It comes as other countries are shaking up their tax regimes to incentivize wealthy investors.

Switzerland, Monaco, Italy, Greece, Malta, Dubai and the Caribbean island of the Bahamas are among the various destinations proving most attractive to wealthy investors, according to industry experts and agents CNBC spoke to.

“Wealthy investors have a lot of choices now and a lot of domiciles are fighting for them,” Helena Moyas de Forton, managing director and head of EMEA and APAC at Christie’s International Real Estate, told CNBC.

Moyas de Forton, whose team advises clients on international relocation, said Labour’s plans were the latest in a string of political developments which have shaken the U.K.’s reputation as a safe haven over recent years.

“It’s just another hit,” she said. “I’m not sure if they’re all leaving but definitely they’re questioning and taking their time to see what’s changing.”

A record number of millionaires are expected to leave the U.K. this year, according to a June report from migration consultancy Henley & Partners, which cited the July general election as adding to a period of post-Brexit political flux. It is estimated that Britain will record a net loss of 9,500 high-net-worth individuals in 2024, more than double last year’s 4,200.

“It is definitely a danger. The markets are so fungible nowadays. It’s easy for people to move home. It’s easy for people to move their businesses,” Marcus Meijer, CEO of real estate investor Mark, told CNBC’s “Squawk Box Europe” of the non-dom changes last week from Monaco.

Among the alternative offerings available to the ultra wealthy are indefinite inheritance tax exemptions in Monaco, Malta and Gibraltar, and an absence of income, capital gains and inheritance tax in Dubai. In Italy and Greece, flat tax regimes allow the wealthy to avoid paying tax on their worldwide assets for an annual fee of 100,000 euros for up to 15 years.

Italy last month doubled its fee for new arrivals to 200,000 euros ($223,283) in a move its economy minister said was designed to avoid “fiscal favors” for the wealthy. However, Macleod-Miller said the regime would likely remain appealing to the top 1% even at a slightly higher rate.

“Other countries are smelling the fear and actively promoting their jurisdictions and attracting their investment and their families,” Macleod-Miller said.

“Italy is one of those countries which is courting the wealthy and seems to think if you treat them well they will contribute,” he added.

That is also impacting the U.K.’s prime real estate market. James Myers, director at London-based luxury real estate agency Oliver James, saw an uptick in sales activity in anticipation of Labour’s election in July. But now, around 30% to 40% of clients are lowering asking prices to generate a quicker sale.

“A lot of people are worried. They would rather get out now before it’s too late,” Myers told CNBC over the phone. Many of Myers’ multimillionaire and multibillionaire clients have already started to put down roots in Monaco and Dubai, with Italy “becoming a thing” more recently, too, he said.

Transactions in London’s super-prime residential market, which covers homes valued at £10 million and above, fell 22% in the year to July compared to the previous 12 months, according to whole market data published Wednesday by property agency Knight Frank.

The decline was most pronounced in properties valued above £30 million, with just 10 sales generated compared to 38 the previous year, which the report attributed to higher buyer discretion.

Stuart Bailey, Knight Frank’s head of super-prime sales for London, noted that Autumn Statement uncertainty had now replaced election uncertainty, with non-doms not the only group being spooked by Labour’s anticipated tax changes.

Ultra-wealthy U.K. citizens, who are typically highly active in the super-prime market, are also in “wait and see” mode ahead of possible changes to capital gains and inheritance tax. It follows previously announced VAT (tax levy) charges for private schools.

“Non doms are a sector of that super-prime market, but they’re not the be all and end all,” Bailey said over the phone.

That is, however, creating opportunities for other investors, Bailey noted. U.S. citizens, who are already subject to U.S. tax on their worldwide assets, and so-called 90 dayers, whose annual stay in the U.K. falls below the tax threshold, could ultimately benefit from reduced competition.

“U.S. buyers, especially those sitting on a lot of cash, would be crazy not to think it’s a good time to buy right now,” he said.