Winners and losers under the non-dom reforms

Wholesale reforms to the non-dom rules have been proposed by both the Conservative and Labour parties with effect from April 2025. There is a good case for reforming the current non-dom regime: not only is it complex with inconsistencies between the income tax and CGT rules but it can be difficult to establish domicile and it discourages investment into the UK. While there are some winners under the proposals – such as new arrivers benefitting from the new regime for foreign income and gains at least for the first four tax years and those already domiciled here with unremitted foreign income and gains who can take advantage of the temporary repatriation facility – there are of course many losers too most obviously including remittance basis users who have been UK resident for longer than four tax years settlors who are UK resident from 2025/26 and are...