Einführung
The United Kingdom’s decision to abolish its long-standing non-domiciled (“non-dom”) tax regime has triggered a new wave of wealth relocation by high-net-worth individuals (HNWIs) and ultra-high-net-worth individuals (UHNWIs). From April 2025, all UK tax residents – regardless of domicile – will be liable for tax on worldwide income and gains, ending the remittance basis that once attracted international wealth. In 2024 alone, the UK saw a net loss of around 10,800 millionaires, and projections for 2025 indicate 16,500 more will leave – the highest outflow ever recorded. An estimated £66 billion in private assets could follow these individuals offshore. Wealth is not vanishing; instead, it is relocating to jurisdictions deemed more tax-friendly and stable.
Where Are HNWIs and UHNWIs Relocating?
Affluent families are relocating from the UK and strategically re-domiciling in jurisdictions that offer lighter taxes, robust legal systems, and a high quality of life. Preferred destinations include Switzerland, Italy, the UAE (Dubai), Portugal, Ireland, Greece and Malta. Each offers unique incentives: the UAE levies no personal income tax, Switzerland allows lump-sum taxation, and Italy attracts newcomers with a flat annual tax of € 100,000 on foreign income.
| Jurisdiction | Tax Attractiveness | Qualität des Lebens |
|---|---|---|
| Schweiz | Lump-sum taxation for foreign UHNWIs; low corporate taxes in many cantons. | Exceptional safety, healthcare, schools and infrastructure. Central European location. |
| Italien | Flat €100k tax on foreign income (up to 15 years), family add-ons possible. | Modern, safe and cosmopolitan. Luxury infrastructure, though with very hot summers. |
| UAE (Dubai) | No personal income, capital gains or inheritance tax. 10-year Golden Visas. | Sunny climate, affordability, and attractive Golden Visa options. |
| Portugal | IFICI regime: 20% flat tax on specific local income, some exemptions for foreign income. | Mild Mediterranean climate, safe, strong expat communities. |
| Irland | Unlimited remittance basis for non-doms, no deemed domicile rule. | English-speaking, EU-based, strong tech and finance economy. |
| Griechenland | Flat €100k on worldwide income for 15 years; 7% flat tax for pensioners. | Non-doms are taxed only on Maltese income and remitted foreign income. No wealth/inheritance tax. |
| Malta | English is widely spoken, good healthcare, and a Mediterranean island lifestyle. | Non-doms are taxed only on Maltese income and foreign income remitted to Malta. No wealth/inheritance tax. |
What’s Driving Global Wealth Migration?
The UK’s non-dom abolition is the catalyst. Under the old rules, residents could pay UK tax only on UK-source income and foreign income remitted to the UK. From April 2025, all residents will be taxed on their worldwide income, while the exposure to inheritance tax has widened. Combined with higher capital gains and dividend taxes, many wealthy families no longer see Britain as a hospitable environment for wealth preservation.
Lifestyle factors also matter. Concerns about safety, quality of life and politics in the UK add to the push, while jurisdictions such as Dubai, Switzerland and Italy actively court newcomers with favourable regimes. High-profile names, such as John Fredriksen, Lakshmi Mittalund die Livingstone brothers, have already restructured or relocated to more welcoming jurisdictions.
Implications for Independent Wealth Managers
Für unabhängige Vermögensverwalter and private bankers considering a move, the implications are significant. Clients are becoming increasingly global, and they demand advisors who can manage cross-border wealth strategies. This requires understanding multi-jurisdictional tax compliance, building international networks, and providing holistic advice that combines tax, residency, and estate planning.
Independent advisors have a distinct edge: flexibility. Free from institutional constraints, they can offer tailor-made, borderless solutions. For UHNWIs navigating wealth relocation, such agility is increasingly valuable.
Notable Wealth Relocation Examples
- John Fredriksen: The shipping tycoon sold his £250m London mansion and moved his base to Dubai, citing UK tax changes.
- Lakshmi Mittal: The steel magnate is diversifying into Monaco and Dubai to mitigate UK tax exposure.
- Ian & Richard Livingstone: London property developers exploring Swiss residency and offshore structures.
- Nassef Sawiris: Egyptian billionaire and Aston Villa co-owner, shifting wealth management towards Ireland and Dubai.
Sources
Selected media reporting on notable wealth relocation after the UK non-dom reform:
- The Times – “Super-rich millionaires leaving Britain after non-dom tax” (2024)
- Financial Times – “Steel tycoon Lakshmi Mittal plans to leave UK after non-dom tax change” (2024)
- Financial Times – reporting on John Fredriksen and other HNWIs (2024–2025)
- MoneyWeek – “Where the wealthy are going after UK tax changes” (2024)
Schlussfolgerung
The end of the UK’s non-dom regime is reshaping the private banking and wealth management landscape. UHNWIs and HNWIs are relocating wealth to countries offering the best mix of tax efficiency and quality of life. Switzerland, Italy, Dubai, Portugal, Ireland, Greece and Malta are among the winners.
For independent wealth managers, this is an opportunity to become trusted global navigators. Those who combine deep technical expertise with agility and international perspective will thrive in guiding clients through this new era of global mobility.
