AUTUMN BUDGET 2024 – A BOON FOR LONG TERM EXPATS?

Andy Wood • November 27, 2024

Introduction

A city skyline overlooking a body of water at sunset.
The UK’s March 2024 Budget introduced sweeping reforms to the taxation of “non-doms,” with confirmation from the new Labour Government in the Autumn Budget that these changes would proceed in largely the same form.
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However, there has been less discussion about how these changes will affect individuals with a UK background, particularly British ex-pats. 


The proposed changes, set to come into effect on 6 April 2025, present opportunities for British ex-pats living around the world. 


While some technical details could still evolve, the draft legislation released on 30 October provides clarity on the framework. This note explores the implications for British ex-pats under the new regime. 


Key Features of the New Regime for British Ex-Pats (Effective 6 April 2025) 

Special Four-Year Tax Regime for Returning Residents 

Qualifying individuals will be exempt from UK tax on their foreign income and gains for their first four years of residence, regardless of whether such income is remitted to the UK. 

Eligibility applies to anyone who becomes UK resident after at least ten tax years of non-UK residence, irrespective of their domicile. 

New Residence-Based Test for Inheritance Tax (IHT) 

Domicile will no longer determine liability for IHT. Instead, individuals will be subject to IHT on worldwide assets after being UK resident for 10 out of the previous 20 tax years. 

If they subsequently leave the UK, their estates will remain subject to IHT for a “tail period” of 3–10 years, depending on their duration of UK residence. 

Favourable Transitional Rules for Current Non-Residents 

Individuals who are non-UK resident during the current tax year and were not UK domiciled on 30 October 2024 can benefit from transitional provisions that shorten the IHT “tail.” 

Planning Points for British Ex-Pats 

Returning to the UK 

Under the current regime, individuals born in the UK with a UK domicile of origin are immediately deemed UK domiciled upon becoming UK resident, making their worldwide income and gains subject to UK tax. 

The new rules change this dynamic: 

  • Those returning to the UK after ten years of absence can take advantage of the special four-year tax regime, exempting non-UK income and gains from tax. 
  • This presents a favourable window for British ex-pats to return temporarily—for example, to care for elderly parents, settle children in UK schools, or manage tax planning in another jurisdiction. 

The UK’s statutory residence test, while complex, offers clear guidance on residence status, enabling individuals to determine their first year of residence and plan their eventual departure if desired. 

Increased Certainty Around IHT 

The current system ties IHT liability to domicile, which can be difficult for globally mobile individuals to establish. Even after decades of living abroad, a UK domicile of origin can persist if the individual has not formed a permanent intention to remain elsewhere. 

The new residence-based IHT test provides clarity: 

  • Individuals who have been non-UK resident for 10 years by 6 April 2025 can benefit from the change immediately, gaining certainty over the IHT treatment of their non-UK assets. 
  • Those non-UK resident for less than 10 years by that date will face transitional uncertainty, as the new rules apply only to those with a non-UK domicile on 30 October 2024. 

Opportunities to Create Trusts and Structures 

The new IHT regime has significant implications for trust creation and other estate planning structures: 

  • Under current rules, transferring assets to a trust by a UK-domiciled individual triggers immediate and ongoing IHT liabilities, creating risks for ex-pats with uncertain domicile status. 
  • From 6 April 2025, certainty around IHT treatment will enable non-UK residents to create trusts and similar structures without the risk of upfront IHT charges, supporting succession planning and asset protection. 

However, ongoing IHT risks remain: 

  • Trusts established outside the scope of IHT may later fall within it if the settlor resumes UK residence and meets the 10/20 residence test. Careful monitoring will be required. 

Need for Expert Advice 

While the proposed regime simplifies certain aspects of the tax rules, expert advice remains essential for individuals returning to the UK. 

The new rules bring potential tax implications for corporate, trust, and other structures, making pre-arrival planning crucial. 

It is also important to note that UK-based assets and assets linked to UK residential property will remain within the scope of IHT, regardless of residence status. 

Conclusion 
The new regime introduces welcome clarity and opportunities for British ex-pats, particularly in terms of temporary UK returns and estate planning. 

However, careful planning is necessary to maximise benefits and mitigate risks under the new rules. 

Final Thoughts 
If you have any queries about this article on the new UK tax regime for ex-pats or tax matters more generally, then please get in touch.


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The 4 Best Countries To Move To From The UK in 2026 (HNWI Guide)

By Amie Roberts • January 27, 2026
Introduction More wealthy UK residents are exploring life overseas ahead of the 2026/27 tax year. Higher UK taxes, political uncertainty and a desire for a different way of living are all pushing people to look at alternatives. Four destinations stand out for high-net-worth UK individuals as at late 2025: 1. United Arab Emirates (Dubai) 2. Portugal 3. Switzerland 4. Malta Each offers a different blend of tax advantages, residency options and lifestyle. United Arab Emirates (Dubai) - Dubai is now the default choice for many UK entrepreneurs and professionals. Tax For individuals, there is currently no personal income tax on salaries, bonuses or most investment income, and no local capital gains or inheritance tax regime for individuals. There is VAT and a developing corporate tax regime, but personal tax remains far lighter than in the UK. The UK–UAE double tax treaty helps reduce the risk of the same income being taxed twice and needs to be considered alongside UK residence rules. Residency Common routes for UK nationals include: Employer- or company-sponsored residence visas Remote-worker visas for those employed or self-employed abroad Long-term “golden” style visas linked to investment, property or professional status Retirement options for over-55s. (All require private health insurance and periodic renewal.) Lifestyle Dubai offers a high standard of living, excellent connectivity and a large, well-established British community. Housing and schooling are expensive and the lifestyle can encourage overspending, but for many the tax position and opportunity outweigh the costs. Best for: Maximising net income and building or scaling a business in a dynamic, international city. Portugal - Portugal appeals to those who want EU residency, a milder climate and a slower pace of life. Tax The old NHR regime has closed to new applicants and been replaced by a newer incentive framework (often referred to as IFICI) aimed at certain professionals and activities. The UK–Portugal tax treaty reduces double taxation, and Portugal does not operate a classic wealth tax, though property-related charges can apply. (It's signed and ratified but not yet fully in force as of early 2026, which may slightly affect immediate tax planning). Residency Post-Brexit, common routes for UK nationals include: D7 visa – for those with sufficient passive income (pensions, investments, rentals). D8 / Digital Nomad visa – for remote workers with qualifying income from abroad. Work and other residence visas tied to employment or specific skills. These can lead to long-term residence and, ultimately, citizenship if physical presence and integration tests are met. Lifestyle Cost of living is generally below the UK (though higher in central Lisbon and the Algarve), English is widely spoken in cities, and the public and private healthcare systems are well regarded. There are large British and wider international communities. Best for: Those wanting EU residence, good quality of life and a balance of tax and lifestyle advantages. Switzerland - Switzerland attracts UK families who prioritise security, discretion and top-tier services. Tax Tax is set at federal, cantonal and communal level, so overall rates vary widely by canton. Well-chosen cantons can be very competitive for both individuals and companies. Private capital gains are not generally taxed, but there is an annual wealth tax on net assets, with rules depending on location. For suitable non-working individuals, some cantons still offer lump-sum (forfait) taxation, where tax is based on living costs rather than worldwide income, subject to minimum levels and conditions. Residency As non-EU nationals, UK citizens use: B permits – time-limited residence, often linked to work L permits – short-term residence for specific assignments C permits – longer-term settlement after sustained residence and integration Wealthy retirees and non-working individuals may be able to obtain residence based on financial self-sufficiency and, in some cantons, lump-sum taxation. Lifestyle High costs are offset by excellent infrastructure, schools and healthcare (with compulsory private health insurance). International communities are strong in Zurich, Geneva and other cities, though social life can feel more formal than Southern Europe. Best for: Those seeking stability, discretion and first-class public services and education, rather than the lowest day-to-day costs. Malta - Malta is a compact EU state with a very familiar feel for UK nationals: English is an official language and the legal and business environment is comfortable for British professionals. Tax Malta’s tax system and UK–Malta treaty can be particularly attractive where you hold significant foreign-source income. Under the Global Residence Programme, qualifying individuals can pay a favourable flat rate on foreign income remitted to Malta, while foreign capital gains kept offshore are generally not taxed in Malta. There is no separate wealth tax and no classic inheritance tax, though duties may apply to certain Maltese assets. The separate “golden passport” (citizenship by investment) route has been struck down by the EU’s top court, but residence programmes remain available. Residency Options for UK citizens include: Employer-sponsored Single Permits combining work and residence The Global Residence Programme for financially self-sufficient individuals meeting property and minimum tax thresholds Digital-nomad-style visas for remote workers Long-term residence after several years of compliant stay Lifestyle Costs (especially rent and property) are typically lower than in the UK outside the most fashionable areas. English is widely used in government and business, healthcare is solid, and London is only a short flight away. Best for: Those wanting an English-speaking EU base with favourable treatment of foreign-source income and a tight-knit expat community. How to decide & next steps - All four countries can work extremely well for UK high-net-worth individuals, but for different profiles: Choose Dubai if your priority is low personal tax on active income and you are comfortable with a high-energy city. Choose Portugal if EU residency, climate and lifestyle matter as much as tax. Choose Switzerland if stability, education and healthcare are at the top of your list. Choose Malta if you want an English-speaking EU base with flexible options for foreign income. The right answer depends on your overall wealth, income mix, family plans and how tied you remain to the UK. If you would like bespoke, confidential advice on whether remaining UK-resident or relocating to Dubai, Portugal, Switzerland or Malta is the better strategy for your situation, you are welcome to get in touch to explore your options in detail.

Maximising Wealth While Staying in the UK: 10 Strategic Moves Every HNWI Should Consider

January 12, 2026
Discover smart strategies to maximise wealth while staying in the UK. Expert wealth management UK guidance and financial advice UK for high-net-worth individuals.
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