Ben Keith writes for FT Adviser: “UK Wants Non-Dom's Commitment Not Just Capital” The article was first published in the FT Adviser on 18 August 2026.
In recent months I have seen families who would once have chosen London look instead at Milan or Cyprus as options on where to relocate. Others are questioning whether to relocate at all.
The abolition of the non-dom regime, the closure of the Tier 1 Investor visa, and continued immigration reform have changed the calculation for high-net-worth individuals who are considering Britain.
For many entrepreneurs and mobile families, the UK remains worth the trouble, but it now takes far more planning. It has, in effect, become a test of commitment.
Wealth alone is no longer enough
The closure of the Tier 1 Investor route in 2022 left no direct replacement; £10mn or £100mn to invest does not itself provide a route to UK residence.
Instead, wealthy individuals must fit within the wider system. The Innovator Founder visa can suit genuine entrepreneurs, with a potential three-year route to settlement, but it is not an investor visa by another name; rather it requires an endorsed business that is innovative, viable and scalable. Global Talent offers an alternative for leaders in fields such as science, technology and the arts.
The UK is no longer asking how much capital an individual can bring; it is asking what they intend to do here.
The proposed Earned Settlement reforms point the same way. The consultation closed in February 2026 and the home secretary has indicated the changes will apply retrospectively, with effect expected this autumn. The model rests on contribution and integration: a 10-year baseline for most migrants, with reductions for greater economic or social contribution.
The greater risk may be tax
Getting into Britain is often easier than staying, and the greater financial risk is usually tax.
The remittance basis was abolished in April 2025 and replaced by the foreign income and gains (Fig) regime. A qualifying new resident, after at least 10 consecutive tax years of non-UK residence, can claim relief on eligible foreign income and gains arising in their first four years here. Fig on which relief has been claimed can be brought into Britain without triggering the tax charge that a remittance would have carried under the old rules. This 10-year test measures absence: how long the client has been non-UK resident before arrival.
Many dismiss it as a poor relation of non-dom status; for some clients that is a mistake. Four years of relief, without the old restriction on bringing those funds to the UK, is a serious offer for a defined stay: a workable window for a founder, an executive on assignment or a family planning a few years in London.
The problem is the fifth year, when a client who remains here will generally be taxed like any other UK resident, on worldwide income and gains as they arise. The question is never just whether to move, but what to do before arrival, how to use the four years and how to plan for the cliff at the end.
Inheritance tax is the sharper long-term trap, and turns on a different 10-year test, which measures presence. Broadly, someone UK resident for at least 10 of the previous 20 tax years becomes a long-term UK resident, and overseas assets can then fall within the scope of UK IHT, subject to the usual exemptions, reliefs and treaty provisions. Leaving does not end the exposure immediately: depending on the length of UK residence, long-term resident status can continue for between three and 10 tax years after departure.
A visa mistake is expensive, but a tax mistake can cost far more.
Immigration and tax can no longer be separated
Traditionally the immigration lawyer obtains the visa and the tax adviser handles the consequences. For HNW clients, that division has broken down.
Immigration strategy may prioritise physical presence to build continuous residence towards settlement, while tax advice must weigh the statutory residence test and the consequences of becoming UK tax resident. Both are legitimate aims; problems arise when they are not co-ordinated.
The same is true of companies, trusts, disposals and family arrangements: decisions made around arrival can have consequences years later.
Advisers should work backwards from the client’s long-term objectives, with three moments in view: arrival; the end of the four-year Fig period; and the point at which long-term residence begins to affect IHT.
Why Britain is still worth the trouble
The wealthy do not choose where to live by comparing tax rates alone. When the LSE’s International Inequalities Institute interviewed 35 individuals in the UK’s top 1 per cent, it found reluctance to relocate purely for tax: London’s cultural life, private schools and social and professional ties kept people here. Tax weighs heavily, but it is rarely the only consideration.
For mobile families, education can be decisive: VAT has raised the cost of private school fees since January 2025, but Britain still offers some of the world’s best-known schools and universities. For entrepreneurs, London means capital, advisers, talent and commercial networks. For families from less stable jurisdictions, the rule of law, independent courts and protection of property rights carry real value.
For someone wanting minimum tax and passive investment migration, other jurisdictions may now be easier. For an entrepreneur who wants London’s ecosystem, or a family that values British education and legal stability, the balance looks very different.
Planning for uncertainty
Policy in this area does not sit still: since 2022 the Investor visa has gone, the non-dom regime has been abolished, IHT has been rebuilt around residence, and settlement is back in the frame. Families thinking in decades cannot plan around a single set of rules, and structures built for today’s regime may not survive the next Budget.
Rather than chasing jurisdictions, advisers should build in optionality at the outset: preserve residence rights or a base in a second jurisdiction where possible, keep structures treaty-compatible, and agree in advance what would prompt a change of course.
The adviser’s role has changed
The question I am asked has changed: not whether a client can move to Britain, but whether they should. Answering it requires immigration and tax advice to be joined up from the start; treating residence, Fig, IHT exposure, business interests and succession as one picture. Exit planning belongs in the same frame.
Britain no longer rewards capital on its own; it asks for commitment. For those who want what it still offers, that may be a price worth paying. The adviser’s job is to make sure the client understands the bargain before they commit.
Ben Keith is a leading barrister specialising in cross-border and international cases. He deals with all aspects of Extradition, Human Rights, Mutual Legal Assistance, Interpol, Financial crime and International Law including sanctions. He represents governments, political and military leaders, High Net Worth individuals, human rights defenders and business leaders in the most sensitive cases.
He is also a leading barrister in Immigration and Public law. He advises the Government Legal Department on a range of public law matters. He Specialises in complex asylum claims for politicians and High Net Worth individuals often linked to extradition proceedings and Interpol Red Notices.
