The pitch in 30 seconds
The historic non-dom regime ended on 6 April 2025. The UK is now a residence-based system. In its place sits the 4-year Foreign Income and Gains regime (FIG): if you have been UK-non-resident for at least 10 consecutive tax years and then become UK tax resident, your first four years of foreign income and gains are 100% exempt — and you can remit them freely. After year four, you pay UK tax on worldwide income.
Inheritance tax has moved with it. You are exposed to UK IHT on worldwide assets once you have been UK-resident for 10 of the previous 20 tax years ("long-term resident"). Leaving doesn't immediately switch IHT off either: a tail of 3 to 10 years applies depending on years of residence.
The honest read: London remains a serious financial centre and a viable short-term play (≤4 years) for newcomers, and a quality-of-life choice for principals who weren't optimising for tax. It is a materially worse long-term tax base than it was 18 months ago.
Who London is for
Founders relocating for one capital cycle (4 years of FIG, then exit before the IHT clock hits 10/20); US persons who are already federally taxed and to whom the non-dom advantage was always secondary; HNW families whose schooling, healthcare and cultural infrastructure decisions outweigh marginal tax; principals planning to genuinely integrate (career, public role, citizenship pathway) and accepting full UK taxation.
Where London is now the wrong answer: long-horizon UHNW principals who built their model around remittance-basis indefinite residence. That model is closed. Modelling has shifted to Dubai, Milan (€200k flat tax — itself rising to €200k since the August 2024 change for new claimants), Monaco, Switzerland and Portugal's IFICI.
The residency programme — step by step
The UK has no investor visa equivalent to a Golden Visa (the Tier 1 Investor route closed in 2022). Routes for UHNW relocators are:
- Innovator Founder Visa: for principals founding a UK-based business with an endorsed innovative plan. 3 years, extendable, route to settlement.
- Global Talent Visa: for endorsed leaders in tech, science, arts, academia. 5 years.
- High Potential Individual (HPI): for recent graduates of top-50 global universities. 2–3 years.
- Skilled Worker via family-office sponsorship: for senior executives transferring into a UK entity.
- Family routes: spouse/partner of a British citizen or settled person.
UK tax residency is determined by the Statutory Residence Test (SRT). The 4-year FIG clock starts the first tax year of UK residency, regardless of visa class — provided the 10-year non-residence prerequisite is met.
The real estate market in 2026
Prime central London has been flat-to-soft since 2014; the 2025 non-dom reform pushed an additional layer of trophy stock onto the market. For UHNW buyers, the result is the best negotiating environment in a decade in the £10M–50M segment.
- Mayfair / Belgravia: £3,500–6,000+/sq ft for prime; trophy lateral apartments and townhouses at £6,000–8,000/sq ft.
- Knightsbridge: £3,000–5,500/sq ft.
- Notting Hill / Holland Park: £2,500–4,500/sq ft for prime stock.
- Chelsea / Kensington: £2,500–4,500/sq ft.
Stamp Duty Land Tax remains the friction layer: residential SDLT scales to 12% on the slice above £1.5M for UK residents; +5% non-resident surcharge; +5% additional-dwelling surcharge if it is not your only home. Trophy purchases routinely carry a 17%+ marginal SDLT load.
Taxes — what you actually pay
- Income tax (post-FIG, or never-FIG): progressive to 45% on income above £125,140 (England rates).
- Capital gains tax: 18%/24% on residential property; 18%/24% on other assets (raised October 2024 Budget).
- National Insurance: for employees and self-employed (FIG users still pay NIC on UK-source employment).
- Inheritance tax: 40% above the £325,000 nil-rate band, applied to worldwide assets once you are "long-term resident" (10 of last 20 tax years).
- VAT: 20% standard.
- SDLT: progressive to 12% + 5% non-resident surcharge + 5% additional-dwelling surcharge as applicable.
The 4-year FIG window is genuinely valuable — 100% exemption on foreign income and gains, with no remittance restriction. But the window is hard-edged. There is no extension.
Honest risks
- The 10/20 IHT clock is unforgiving. A principal who plans to "see how it goes" for 8 years and then leave is fine on IHT. A principal who stays for 11 has triggered exposure on worldwide assets, plus a 3–10 year tail on departure.
- Trust planning has been substantially neutered. Pre-April 2025 excluded property trusts retained for non-dom protection should be re-modelled under the new regime; the previous certainty is gone.
- The political risk is real. Both major parties have signalled that the wealth-tax conversation continues. Underwrite the IHT and FIG numbers as politically exposed.
- SDLT is the silent killer. A £20M Mayfair townhouse can carry £4M+ of SDLT on a foreign-resident additional-dwelling purchase. Structure and timing matter.
Who Camille introduces
- UK tax counsel — Big-4 private client desk or top-tier boutique (Macfarlanes, Charles Russell Speechlys, Withers), specialist in FIG-regime structuring.
- Real estate agent — Mayfair / Belgravia / Knightsbridge specialist with off-market access and SDLT structuring partners.
- Immigration counsel — Global Talent, Innovator Founder, or family route specialists.
- Private banker — Coutts, JPMorgan Private Bank, UBS, Goldman Sachs PWM London.
- Trust and estate planner — for pre-arrival and pre-10-year IHT planning.
CTA
Want the introductions? Send a five-line brief — current residence, last 10-year residence history (FIG eligibility check), nationality, target move date, household, AUM and structure (personal vs trust). Reply within 48 hours.
Sources: UK Finance Act 2025 (abolition of non-dom regime, introduction of 4-year FIG regime and residence-based IHT). HMRC, "Check if you can claim the 4-year foreign income and gains regime" (gov.uk). HM Treasury, Spring Budget 2024 and Autumn Budget 2024 (CGT rate increases). SDLT: Finance Act 2003 as amended; non-resident surcharge under FA 2021. Trust IHT analysis: Charles Russell Speechlys, Withers, Saffery LLP commentary (2025–2026). Always verify with UK tax counsel before any residence decision.
This guide is editorial, not legal advice. We make the personal introductions to your future banker, lawyer and real estate agent.