At one minute past midnight on 6 April 2025, the United Kingdom's resident-non-domiciled tax regime ceased to apply to new arrivals. The change, announced by Jeremy Hunt in the Spring Budget of 6 March 2024 and confirmed by Rachel Reeves's Autumn Budget of 30 October 2024, ended a two-hundred-year-old fiscal carve-out under which UK-resident individuals with a foreign domicile could elect to be taxed only on UK source income and on overseas income remitted to Britain. The replacement four-year Foreign Income and Gains regime is, by design, materially narrower: full exemption for the first four years of UK residence for individuals who have not been UK tax-resident in any of the previous ten years, then full worldwide taxation thereafter.
The Henley & Partners Private Wealth Migration Report 2025 puts a number on the consequence. The UK was projected to lose a net 16,500 millionaires in 2025 — the largest annual net outflow recorded by any country since Henley and New World Wealth began tracking the data in 2013. The previous record holder, China, was forecast to lose 7,800 in the same year. Companies House filings, separately, show that between October 2024 and July 2025 nearly 3,800 UK company directors moved their official residence abroad, a 40% increase on the comparable prior-year period (Marketplace, 30 April 2025, citing the analysis by Bambridge Accountants).
The relocation map has been more concentrated than the consultancies forecast in 2024. Henley's destination data and the parallel reporting from Knight Frank, Bloomberg and the Financial Times converge on four jurisdictions absorbing the bulk of the flow.
The first is the United Arab Emirates, with a projected net inflow of +9,800 millionaires in 2025 — a record for any single destination since the migration data has been collected. The pull factors are well-rehearsed: no income tax, the Dubai International Financial Centre's English-law jurisdiction, a Golden Visa programme tied to AED 2 million (roughly $544,000) in property investment, and the operational scale of DIFC, ADGM and the on-shore Free Zones for family-office structuring.
The second is Italy, which on 30 December 2025 raised its lump-sum foreign-income flat-tax regime from €200,000 to €300,000 per year, with family members included at an additional €50,000 each (Italian Visa, 2025 official confirmation). The Italian regime, introduced in 2017 under Article 24-bis of the TUIR, was deliberately doubled in price after the 2024 inflow accelerated — a signal that Rome saw the UK exit as a once-in-a-generation capture opportunity and adjusted accordingly. Milan, Como and Forte dei Marmi have been the principal residential destinations.
The third is Switzerland, which retains its forfait fiscal regime in cantons including Geneva, Vaud, Valais and Ticino. The Swiss regime taxes resident foreigners on a deemed lump-sum base — typically a multiple of annual living expenses — rather than on worldwide income. The 2025 inflow has skewed toward Geneva and the Vaud lake-front.
The fourth, which the UK trade press underweighted in its 2024 forecasting, is the United States — specifically Florida and, to a lesser extent, Texas. The combination of a stable legal framework, no state income tax in either jurisdiction, deep advisor and family-office infrastructure in Miami and Palm Beach, and the political volatility now structurally priced into a Britain that has reversed two centuries of fiscal hospitality has produced a US inflow of UK millionaires that Henley's data shows at multi-thousand levels for the first time.
Monaco, often cited in the early 2024 commentary, has absorbed a smaller share than the headlines suggested. The principality's €500,000 bank-deposit requirement, the structural cap on residential supply at roughly €52,000-65,000 per square metre in Larvotto and Carré d'Or (Petrini, 2025), and the eight- to twelve-month residency-permit timeline have constrained the inflow more tightly than the income-tax-free framing would imply.
The structural reading is the one the family offices are now delivering plainly to clients. The UK move was not a one-off policy event. It is the most consequential UHNW fiscal change in any G7 jurisdiction in two decades, and it has produced the largest single-country wealth outflow in the modern data series. The receiving jurisdictions — Dubai, Milan, Geneva, Miami — have repriced their residential and operational property markets to absorb the flow. The London property market, by contrast, is now navigating the second-order effects: the sharp decline in £15m-plus prime sales recorded by Knight Frank and Savills through 2025, and the visible thinning of the buyer pool for the trophy Belgravia and Mayfair stock that the non-dom population had historically supported.
The reversal is, on the current numbers, structural rather than cyclical. The Treasury's projected revenue uplift from the policy is in the range of £2.7 billion a year. The wealth outflow's cost to the broader London ecosystem — service jobs, advisor fees, restaurant covers, school enrolments — has not yet been published in a single document. The next eighteen months will tell.
— Camille Vedy
