Lawyers say they are working “flat out” for non-doms who need to restructure their tax affairs because they plan to stay in the UK, despite the abolition of their special status.
“The people who are staying are creating more work than those who are leaving,” said Ceri Vokes, a partner at law firm Withers.
“Leaving can be very simple for some clients — it switches off most of the UK tax exposure — whereas staying means a restructuring needs to be undertaken,” she said.
Middle-aged people with children in school and entrepreneurs focused on building a business are among those who have chosen not to leave the UK, according to lawyers who work to help the global wealthy organise their affairs.
Bryony Cove, a partner at Farrer & Co, said the firm’s private client team was “probably at least a third busier” so far this year compared with 2024: “Everybody is completely flat-out.”
From April 6 the non-dom status — which allows UK residents who declare their permanent home as being overseas to avoid paying UK tax on foreign income — will be abolished.
Many non-doms left after then-chancellor Jeremy Hunt announced in March 2024 that he intended to close down the regime.
Rachel Reeves, the Labour chancellor, confirmed the changes in her October Budget and also removed the tax benefits of holding assets in non-UK trusts.
Those who decided to stay will see their worldwide assets potentially subjected to UK inheritance tax at 40 per cent. Lawyers are now rushing to restructure these global estates ahead of the deadline.
There are “huge amounts of work to be done to take certain steps”, said Vokes, such as restructuring trusts, taking income or capital out of trusts or selling down assets. “It’s going to be a busy 18 months. This is the busiest we’ve been in my nearly 20 years at Withers.”
Christopher Groves, also a partner at Withers, said there were several types of non-doms who were staying, including those with children in schools, and those who had recently arrived who would benefit from a new four-year tax-free foreign income and gains regime.
The work required was “mostly massive overhauls because it’s a very dramatic change”, he said.
Sangna Chauhan, a partner at Charles Russell Speechlys, said her workload “feels a little bit more measured but that’s most probably because half the people have gone and we’re only restructuring for the other half”.
Beyond non-doms, some lawyers reported UK business owners and farmers requiring significant replanning because the chancellor also reformed agricultural property relief and business property relief. This means estates, previously exempt, will pay inheritance tax at 20 per cent on assets above £1mn from April 2026.
