• The UK’s non-dom tax regime, established over 200 years ago, is under scrutiny as this, and the previous government, have proposed its abolition;

• It is expected that inheritance tax will be charged on the foreign income, gains, and trusts held by current non-doms, resulting in a likely exodus of those under this regime;

• If the expected abolition to the status goes ahead in its current form, it would present a number of legally and fiscally frustrating scenarios. These include dead settlor events, confusions around the value of trusts and inheritances, withholding complications, and issues for transient residents (such as students);

• Changes to inheritance taxes’ scope may also create a ‘tail’ effect, wherein emigres who die within 9 years of leaving the country (even if they have not returned in that period) would be in-scope for the tax. This could put off individuals becoming UK resident in the future;

• The current non-dom system is confusing and requires urgent, simplifying reforms to increase tax revenues, bolster investment and economic growth, and deliver a more effective legal playing field;

• In order to solve these problems and indeed, attract non-doms to the country, we recommend:

1. Introducing a £150,000 flat-tax for non-doms.

2. Considering a Swiss-style forfait system.

3. Creating a reduced-tax temporary worker status.

4. Offering incentives for non-doms to invest in UK assets.

5. Returning to a lower tax economy

6. Simplifying the UK tax system to reduce complexity and costs.