Ben Keith on Non-Dom Abolition and UK Residency

Ben Keith, barrister and co-founder of IHR Advisors, has written in FT Adviser on what the abolition of the UK non-dom regime means for internationally mobile families weighing UK residency. He identifies three changes that have reset the calculation: the replacement of the remittance basis with the four-year foreign income and gains (FIG) regime in April 2025, the closure of the Tier 1 Investor visa without a direct successor, and the proposed Earned Settlement model.

Families who would once have chosen London are looking at Dubai, Milan and Switzerland instead. His argument is that UK immigration and tax planning can no longer be run as separate exercises.

Wealth alone no longer buys a route to UK residence

The Tier 1 Investor visa closed to new applicants in February 2022 and has no direct replacement. Capital on its own no longer secures a route to UK residence. Wealthy applicants have to fit within the ordinary immigration system, which in practice means one of two routes.

The Innovator Founder visa requires a business that is innovative, viable and scalable, endorsed by an approved body and then monitored. Global Talent is open to leaders and potential leaders in fields including academia and research, arts and culture, and digital technology. It turns on peer recognition rather than net worth.

The proposed Earned Settlement model points the same way. It rests on contribution and integration, with a ten-year baseline for most migrants, reductions for higher earners and for those in shortage roles, and extensions where an applicant has claimed public funds or entered unlawfully. Rules are expected in autumn 2026 with effect in 2027, and the proposals reach people already in the UK who do not yet hold indefinite leave to remain. Anyone currently building towards settlement is planning against a moving target.

The greater risk is usually tax

The four-year FIG regime, which replaced the remittance basis on 6 April 2025, gives four years of relief on foreign income and gains to individuals who have been non-UK resident for the previous ten tax years. Ben is more positive about it than many. Four years of relief, without the old restriction on bringing those funds into the UK, is in his words ‘a serious offer for a defined stay’.

The difficulty is the fifth year. A client who stays beyond the window is taxed on worldwide income and gains as they arise, with no transitional relief. The regime rewards a planned and time-limited stay. It punishes drift.

Inheritance tax has moved further still. From 6 April 2025, IHT on worldwide assets turns on long-term residence rather than domicile, catching anyone resident in the UK for at least ten of the previous twenty tax years. Exposure does not end on departure. A tail of continuing worldwide liability runs for between three and ten years, scaling with the length of the preceding residence. For families who think in generations rather than tax years, that is the provision needing the earliest attention.

What the UK still offers high-net-worth families

Tax rates are rarely decisive. Ben cites LSE research interviewing individuals in the UK’s top 1 per cent, which found real reluctance to relocate for tax reasons alone. Cultural life, schools and professional ties kept them in London.

For entrepreneurs the draw is the concentration of capital, advisers and talent. For families from less stable jurisdictions the value lies elsewhere: ‘the rule of law, independent courts and protection of property rights carry real value’. Legal certainty is part of the offer, and it is the part most easily taken for granted.

Because policy does not sit still, Ben advises building in optionality from the outset. That means preserving residence rights or a base in a second jurisdiction, keeping structures treaty-compatible, and agreeing in advance what change of law would prompt a change of course. The question he is now asked has shifted from whether a client can move to Britain to whether they should.

With thanks to FT Adviser, where the article first appeared. Read it in full: UK wants non-dom’s commitment not just capital.

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