Leaving the UK? A Checklist for HNWIs as the Non-Dom Regime Ends

The UK’s non-dom regime is no longer. Changes to the framework were passed in the Finance Bill at the end of March, and from April 2025, the long-standing remittance basis will be replaced with a residence-based framework. As a result, many globally mobile high-net-worth individuals (HNWIs) are leaving the UK. 

Relocating from the UK doesn’t automatically end your tax obligations to the country. HNWIs must carefully prepare for the move, mapping out the exit and generating strong records to ensure tax residency compliance. This article will help identify the essential elements pre- and post-relocation and offer advice on strengthening your day counting and record-keeping, whether you’ve decided to leave the UK already or are still planning the move. 

From 6 April 2025, all UK-resident individuals will be taxed on their worldwide income and gains, marking the end of the remittance basis. A new four-year FIG (foreign income and gains) regime will apply to individuals who become UK tax resident after at least 10 years of non-UK residence. Additional measures include the introduction of a Temporary Repatriation Facility (TRF), the option to rebase certain foreign-held capital assets, and the retention of overseas workday relief, which will continue to apply to income from overseas duties on a just and reasonable basis. 

For more, read our article on the changes.

With the new rules now confirmed, many HNWIs are re-evaluating their ties to the UK. For those considering a move, timing, documentation, and jurisdictional choices are all critical. The following checklist outlines the key actions to take before and after relocating to ensure your exit is compliant, strategic, and well-supported.

Pre-Departure Planning

Choose your next jurisdiction

The most critical question in your checklist is to choose your next destination. We’ve previously done some research into where HNWIs are heading and found the following countries to remain attractive options:

• Monaco — No income tax, strong privacy rules. For more on Monaco, read our article on residency in Monaco.
• UAE — No personal income tax, growing ecosystem for HNWIs.
• Italy — Offers a flat tax of €100,000 on overseas income for new residents.

You’ll want to factor in family preferences, access to education and work, travel and lifestyle, and the financial environment. 

Confirm departure timing

The timing of your relocation may impact your future taxation. If you:

• Left before 6 April 2025, you may be treated under the old regime.
• Leave after 6 April 2025, the new rules and the transitional rules will apply. 

There is a Temporary Repatriation Facility (TRF) that allows non-UK-domiciled individuals who claimed the remittance basis before 6 April 2025 a window of three years to bring funds to the UK at a reduced tax rate. 

Review domicile status

Understand current domicile status, as it remains essential for earlier years and potential HMRC inquiries.

Assess tax residence

Ensure you meet the criteria for non-UK resident status under the Statutory Residence Test. The complex residency assessment evaluates residency beyond just your physical presence in the UK. Our case study shows that accidental or unforeseen overstays in the UK after relocation can create tax liabilities. By understanding the rules before you relocate, you can limit your risk exposure.

You’ll also need to understand and establish tax residency in the new location. Familiarise the rules around tax residency, including any necessary paperwork. 

Check eligibility for split-year treatment

The UK applies a split-year treatment when individuals move in or out of the UK in the middle of a tax year. The treatment may offer some relief to tax liabilities. However, strict rules apply, and you want to check how the treatment may apply in your case.

Assess international reporting obligations

Understand the disclosure rules in both the UK and your arrival jurisdictions. You’ll need to inform HMRC in the UK of your exit date; similar reporting obligations exist in other jurisdictions. 

Consider rebasing options

Explore the option to rebase personally held foreign assets to their 5 April 2017 market value for disposals after 5 April 2025.

Review offshore structures

Assess any settlor-interested trusts and plan for potential changes in tax treatment.

Post-Departure Considerations

Long-term planning

Consider remaining a non-UK resident for at least ten consecutive UK tax years before returning to reset the clock for LTR rules.

Overseas assets

Review the structure and location of foreign income and gains (FIG) to optimise tax efficiency in the new jurisdiction.

UK connections

Assess and potentially minimise ongoing UK ties to support non-resident status.

Prepare for increased HMRC scrutiny

Tax authorities worldwide are increasingly focused on scrutinising the affairs of the wealthy. HMRC and other authorities use digital tools to analyse data, such as social media, flight records, and bank details. These can flag up and result in tax investigations without extra tax paid. You should prepare for this scrutiny and keep clear records of exit date, housing changes and other events.

Throughout your pre- and post-relocation planning, evidencing your move can strengthen your defences. 

Day counting 

You should start counting the days you spend in different tax jurisdictions, even before you decide to relocate. Accurate day counts are especially vital during the transition period. Once you’ve relocated outside the UK, you want to monitor days spent back in the UK to avoid accidentally re-triggering your tax residency. 

While most people have relied on manual day counting, our research has shown this to pose considerable risks. These traditional methods increase the risk of errors and miscalculations. When relocating, an automated system based on your smartphone’s location data and actual tax residency rules gives you clarity and security. 

Record-keeping 

Don’t rely purely on the day counts; ensure you generate supporting evidence to match travel dates. These can be boarding passes, hotel receipts and rental receipts. With Daysium, you can add geotagged photos, such as a selfie in the Shard, to your day counting records.

Leaving the UK amidst the end of the non-dom regime is complex. To ensure you’re considering all the necessary legal obligations and managing your wealth planning, consulting UK tax advisors is a must. They can help ensure you understand your specific situation and prepare for all eventualities. 

You’ll also want to ensure you access support in your new location. Our network of Partner firms currently covers 10 tax jurisdictions and counting. You can navigate and connect with an advisor through our website. 

Leaving the UK in the wake of these sweeping tax changes is a complex and weighty decision that demands more than just a new address. Your strategy should be resilient enough to accommodate return visits, dual presence, or further regulatory shifts. 

With the right advisors and systems, such as automated day counting and robust record-keeping, you can make confident moves, stay compliant, and protect your long-term interests. These tools, supported by an expert advisory team, help you navigate relocation from the UK now or in the coming years.

We recommend starting with our Tax Residence Risk Assessment if you’re unsure where you stand today. It’s a fast, confidential way to get a clearer view of your exposure and options.

Take our Tax Residency Risk Assessment.