Global Tax Shifts for HNWIs: The End of the UK Res Non-Dom and Evolving International Approaches

This article examines the United Kingdom’s transition from the long-standing “Res Non-Dom” regime to the new Foreign Income and Gains (FIG) regime, effective 6 April 2025. It explores the impact on high-net-worth individuals (HNWIs), the implications for trusts and inheritance tax and transitional measures introduced to ease the shift. Additionally, the article compares the United Kingdom’s evolving tax landscape with alternative regimes in Finland, Hong Kong, Italy, Malta, Switzerland and the United Arab Emirates, offering insights into the response of HNWIs to these changes. Notably, Italy has retained a favourable inheritance and gift tax framework, with relatively low rates and a territorial scope that remains attractive compared to other Member States. However, important changes will take effect 1 January 2025, including a shift to self-assessment and updates to compliance deadlines, while key exemptions – such as those for business and shareholding transfers – have been maintained to support generational continuity.