Press Room

8 Mar 2024

The Government tries to soften the blow for non-doms – Huw Griffiths

Director Huw Griffiths comments on the transitional arrangements the Government has announced to prevent significant numbers of UK non-doms from relocating.

Huw’s comments were published in the Financial Times, 8 March 2024.

“While the abolition of the non-dom regime came as a surprise to no one, its replacement is not as bad as many feared. For people arriving in the UK from 6 April 2025, they will only be taxed on their UK source income and gains for the first four years. Then, once those four years are up, if they stay, they will be taxed as any other UK resident – no more remittance basis, clean capital and mixed funds to worry about.

“The new regime will not depend on their domicile, so there will be no more questions about where one’s Dad was born or where one intends to be buried. The sole determining factor will be whether one has been resident in the UK for at least 10 years.

“Anyone who has just arrived in the UK will be able to take advantage of the new regime from 6 April 2025 until they hit four years of residence. For those who are already past this limit, there are sweeteners to try and stop them from rushing for the airport. Pre-April 2025 income and gains can be brought to the UK in 2025/26 and 2026/27 with a flat rate of 12%, assets rebased to April 2019 and income and gains within a pre-April 2025 trust will not be taxed as long as they stay there.”

Huw Griffiths

Huw Griffiths is a Director in the Corporate Tax group at Andersen LLP. His client experience ranges from SMEs to private equity backed businesses to large multinational groups. Huw primarily works with UK groups and UK subsidiaries of international groups.

Email: Huw Griffiths