Cover Story: The Great Wealth Migration: Why the Ultra-Rich Are Fleeing Britain

By Yue Yue and Denise Jia

Ann Kaplan Mulholland had an audacious plan. The 64-year-old Canadian businesswoman, worth an estimated £500 million ($646 million), had spent years living in Britain. She and her husband even bought a £5.5 million castle once occupied by Henry VIII, embracing a medieval lifestyle.

But when she learned about Britain’s sweeping new tax reforms, she hatched an unconventional idea — turn her castle into an independent country.

Her logic? If her estate became a sovereign nation, she and her husband would no longer be U.K. residents, shielding their vast global assets from the country’s hefty tax rates — including a looming 40% inheritance tax. She even drafted a letter to King Charles III asking permission.

The proposal, unsurprisingly, went nowhere. But it did spark a frenzy among London’s elite tax lawyers, who saw it as a symbol of a much larger trend: Britain’s wealthy are running out of tax loopholes, and they are leaving in droves.

Globally, tax havens are vanishing as countries crack down on tax avoidance by the wealthy. As compliance tightens, the rich are not just relocating but rethinking their entire financial playbook.

End of tax heaven

At the heart of this exodus is a landmark policy change. Starting on April 6, 2025, the U.K. will abolish its Non-Domiciled Individuals (non-dom) tax status, a regime that has allowed the super-rich to avoid paying tax on overseas income for up to 15 years.

The non-dom system, which dates back to 1799, originally shielded foreign property owners from taxation as the government raised money to fight the Napoleonic wars. Over time, it evolved into a modern tax shelter, allowing the wealthy who live in Britain but are legally considered to have a “permanent home” elsewhere to pay tax only on their U.K. earnings. Instead of paying taxes like everyone else, they could pay a fixed annual fee — £30,000 for those living in Britain. for seven years out of the past nine years, £60,000 for those there for 12 out of the past 14 years.

The arrangement has long made Britain a haven for international billionaires. A 2022 study from the London School of Economics and the University of Warwick found that one in five top U.K. bankers had claimed non-dom tax breaks. In the oil industry, 40% of the top 1% of earners —those making over £125,000 a year — had done the same. Among high-earning athletes and entertainers, one in six had used the system to shield their multimillion-pound incomes.

One of the most high-profile cases was Akshata Murty, wife of former prime minister Rishi Sunak. As an Indian citizen, she held a £700 million stake in Infosys, the IT giant founded by her father. Her non-dom status allowed her to avoid £2.1 million in U.K. taxes each year and potentially bypass £280 million in inheritance taxes.

The backlash against such tax privileges had been brewing for years. With mounting economic pressures and public calls for tax fairness, Prime Minister Keir Starmer’s newly elected Labour government is pulling the plug.

Now, the non-dom regime is being replaced with a four-year exemption. Under the new rules, new U.K. residents will be exempt from foreign income taxes for their first four years in the country. After that, all global earnings will be taxed like any other U.K. resident.

For the ultra-wealthy, the message is clear: the party is over.

The impact is immediate and seismic. British Treasury estimates suggest the reform could generate an additional £2.7 billion in annual tax revenue. But critics warn of unintended consequences. The Adam Smith Institute, a U.K. think tank, predicts that the move could shrink investment and spending, wiping out 23,000 jobs over the next six years.

Voting with their feet

Faced with higher taxes, many of Britain’s richest residents aren’t sticking around to pay up. Henley & Partners, a global investment migration consultancy, estimate that more than 10,800 high-net-worth individuals — defined as those with at least $1 million in liquid asset — left Britain in 2024, a staggering 157% increase from 2023. That translates to one millionaire departing every 48 minutes. Henley & Partners predicts that 135,000 high-net-worth individuals will relocate in 2025.

“As the world grapples with a perfect storm of geopolitical tensions, economic uncertainty and social upheaval, millionaires are voting with their feet in record numbers, seeking greener pastures and safer harbors for their assets and family interests,” the firm noted in a recent report. “This great millionaire migration is a canary in the coal mine, signaling a profound shift in the global landscape and tectonic plates of wealth and power.”

Where are they going? The United Arab Emirates (UAE) tops the list, with 6,700 high-net-worth individuals relocating there in 2024. The U.S. follows with 3,800, while Singapore takes third place with 3,500, according to Henley & Partners.

The Middle East, led by the UAE and Saudi Arabia, has aggressively positioned itself as an investment and residency hub with zero personal income tax, low corporate tax and a strategic location that connects Europe, Asia and Africa, said Shen Fengshang, tax advisory director at Vialto Partners, a globally independent tax and immigration consulting firm.

Elite institutions are already adapting to this shift. Harrow School, one of Britain’s most prestigious boarding schools, recently announced plans to open campuses in Dubai and Abu Dhabi in 2026 — widely seen as a response to the wealth migration trend.

Some high-net-worth individuals hesitate due to concerns about climate, healthcare and education. For them, a middle-ground approach — relocating to places such as Ireland or Italy — offers a better balance. Italy, for instance, has a flat tax of 200,000 euros a year on global income — recently increased from 100,000 euros — making it an attractive option for the ultra-wealthy who want to keep international earnings shielded from local taxation.

Mulholland herself ultimately abandoned her “castle nation” plan. Realizing it was legally impossible, she scrapped her letter to the King and set her sights on Milan, seeking Italian residency.

Meanwhile, Hong Kong and Singapore remain popular among Asia’s elite. Both have introduced new incentives to attract family offices and high-net-worth talent, successfully drawing in some of the world’s wealthiest families.

Reallocating global assets

Britain isn’t the only country tightening its grip on the wealthy. Governments worldwide are cracking down on tax avoidance, forcing billionaires to rethink their strategies.

“It’s less about ‘fleeing’ the U.K. and more about strategically reducing time spent there,” said Wang Chuanqi, lawyer at Mishcon de Reya, one of London’s elite law firms. “The goal is to avoid becoming a U.K. tax resident while maintaining a global asset footprint.”

London may be losing some of its tax advantages, but for many of the wealthiest, the decision isn’t purely financial.

Some ultra-high-net-worth clients, after all the calculations, decide that paying the tax is simply the cost of doing business in the U.K., said Wang. They are here for the environment and investment opportunities. For them, the tax bill is just another expense.

For those who want to stay in Britain, the first challenge is how to allocate their global wealth to lower the tax bill. Countries such as the United States, Australia, Canada and China already enforce worldwide income tax for their residents. While personal income tax rates tend to be lower in parts of Asia than in the West, the global trend is clear: tax loopholes are disappearing.

“With governments worldwide enforcing global asset taxation, the space for maneuvering is shrinking,” said Shen Fengshang, tax advisory director at Vialto Partners, a globally independent tax and immigration consulting firm.

Shen advised his wealthy clients to make full use of the U.K.’s four-year transition period under the new rules. That means understanding new reporting requirements, delaying tax liabilities where possible and maximizing any remaining advantages before global taxation kicks in.

Some are turning to another common strategy — leveraging double taxation treaties. If income is taxed in one country, another jurisdiction can typically only tax the difference, not the full amount. However, these agreements are subject to constant renegotiation, and governments are actively closing loopholes.

Others are rethinking their entire asset allocation. Selling British property and reinvesting in low-tax countries is one approach. A tax lawyer working with high-net-worth clients notes that he is seeing an increasing number of ultra-wealthy individuals offloading luxury London real estate. “Some of these homes are incredibly expensive, and they’re not easy to sell overnight,” he said.

While high in net asset value, real estate is often just a fraction of an ultra-wealthy investor’s portfolio. Instead, financial assets — stocks, bonds, and private equity — tend to dominate. Asset allocation, Shen argued, must be recalibrated on a much broader scale.

According to Chun-Lai Wu, head of Asia Asset Allocation at UBS Global Wealth Management’s Chief Investment Office, family offices have long favored diversification, with more than half of their portfolios in traditional assets like stocks and bonds. In its latest survey of 320 family offices managing an average of $2.6 billion each, UBS found that their strategic asset allocation is undergoing its most significant shift in five years. More than a third of respondents plan to increase their investments in North America and Asia-Pacific — excluding Greater China — over the next five years.

Most family offices still see North America as a strong investment destination, said Wu. After the Federal Reserve’s aggressive rate hikes in 2022 and 2023, market opportunities are starting to emerge. Meanwhile, the rapid expansion of U.S. tech — particularly in AI — continues to attract significant capital. With inflation stabilizing, investor confidence in North America is on the rise, Wu said.

Cryptocurrencies and virtual assets were once seen as a convenient escape hatch, prized for their decentralized nature, anonymity and cross-border liquidity. Some speculated that the sector’s meteoric rise was fueled in part by demand from the ultra-wealthy seeking tax havens. But when it comes to family offices, the reality is different.

Most family offices prefer exposure to the underlying technology of crypto rather than holding digital assets themselves, Hu said.

A corporate lawyer who has advised numerous publicly traded company founders echoed that sentiment. “The wealthier they are, the less they gamble on volatile assets. At that level, wealth is just numbers on a screen. Their priority is stability, not chasing high-risk returns.”

Crackdown on hidden wealth

For years, the world’s ultra-rich have relied on complex offshore structures, obscure tax havens, and investment-based residency schemes to keep their wealth out of reach. But as global tax authorities close loopholes, a new reality is setting in: hiding assets is getting harder than ever.

At the center of this transformation is the Common Reporting Standard (CRS), a global financial transparency framework spearheaded by the OECD. Under the CRS, financial institutions must identify and report foreign tax residents’ financial accounts to their home countries. This means banks are no longer bound by secrecy; they must now disclose account holders’ names, tax IDs, addresses, account balances, interest, dividends and capital gains. Tax agencies then exchange this data across jurisdictions, allowing governments to track cross-border assets with unprecedented precision.

As of 2024, some 111 jurisdictions — including traditional tax havens like the British Virgin Islands, Cayman Islands, Bermuda, Monaco and Panama — have committed to the CRS. In 2023 alone, more than 134 million financial accounts were automatically exchanged, covering nearly 12 trillion euros in assets. Since the CRS launched in 2017, tax authorities have recovered more than 130 billion euros in unpaid taxes, interest and penalties.

China joined the CRS in 2018 and now exchanges financial data with 80 tax authorities worldwide. While Beijing has not publicly disclosed the number of accounts shared, Australian tax records provide a glimpse into the scale of the system. In 2022, Australia reported 1.015 million Chinese tax residents’ accounts to China, with a combined balance of A$32.3 billion ($20.4 billion).

Notably absent from the CRS is the United States, which operates under its own system — the Foreign Account Tax Compliance Act (FATCA). Enacted in 2010, the act requires foreign financial institutions to report accounts held by U.S. citizens, residents, or entities. While both FATCA and CRS share similar disclosure principles, FATCA is unilateral — designed to benefit Washington — whereas the CRS is a reciprocal, multilateral system. China signed a FATCA agreement with the United States in 2014.

Some wealthy individuals sought to bypass both systems through “golden visas” and “investment passports” — buying citizenship or residency in non-CRS countries while keeping their real lives and assets elsewhere. However, tax authorities have caught on. The OECD has tightened scrutiny, flagging jurisdictions that fail to properly enforce the CRS, and warning that noncompliance could hurt international credibility. In its most recent review, one in three participating countries received red flags for weak enforcement.

Meanwhile, geopolitical tensions could further upend global tax structures. Donald Trump signed a presidential memorandum last month, directing a review of the 1984 U.S.-China tax treaty, which prevents double taxation by allowing tax credits between the two countries.

If the treaty is revoked, it could dramatically affect cross-border investment. U.S. businesses in China would lose their ability to offset Chinese taxes against their U.S. liabilities, while Chinese investors in the U.S. would face dual taxation, significantly increasing their tax burdens. DLA Piper, the global law firm, warned that the change could disrupt corporate tax planning and reduce incentives for capital flows between the two nations.

Tian Yuan Law Firm further noted that terminating the treaty could complicate corporate residency rules, permanent establishment definitions, cross-border royalties, interest payments and M&A transactions. Some companies could face a combined corporate tax rate exceeding 50%, severely straining their finances.

There are also concerns about FATCA’s enforcement. The U.S.-China tax treaty underpins FATCA’s information-sharing mechanisms. If the treaty is scrapped, Beijing could argue that it is no longer obligated to provide the U.S. with data on the Chinese financial accounts of American tax residents.

However, a presidential memorandum is not an executive order. While it signals intent, it lacks binding authority and would require further legal action to be implemented.

Global tax enforcement is tightening, and the UK’s tax overhaul is just the beginning. “This isn’t just about Britain — other countries will follow,” says Wang Wenhui, head of business tax services for Greater China at EY. “The world’s tax landscape is shifting toward greater transparency and stricter compliance. High-net-worth individuals face growing risks, pushing them to reassess their financial structures and explore new tax planning strategies.”

Contact reporter Denise Jia (huijuanjia@caixin.com)

caixinglobal.com is the English-language online news portal of Chinese financial and business news media group Caixin. Global Neighbours is authorized to reprint this article.

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