As of July 2025, the UK remains a major hub for high-net-worth individuals, entrepreneurs and global families. Yet this year has already brought seismic changes to the tax landscape, particularly through UK tax changes for non-doms and high earners in 2025 that are reshaping long-term planning.
From the phasing out of the non-domicile (non-dom) regime to a wave of measures targeting higher earners and offshore structures, those with significant wealth now face a new level of complexity in navigating their financial affairs.
This article outlines the most important developments in UK taxation affecting UHNW individuals this year, focusing on the dismantling of the non-dom system and the additional pressures on high-income residents.
The end of the traditional non-dom regime
In one of the most radical tax reforms in decades, the UK government confirmed that the longstanding non-dom regime is ending as of April 2025. For years, this system allowed individuals domiciled overseas to use the remittance basis of taxation, shielding foreign income and gains unless brought into the UK. That era is over.
Key features of the reform include:
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From April 2025, new arrivals to the UK benefit from a transitional four-year regime during which foreign income and gains remain tax-free even if remitted.
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After this four-year window, all worldwide income and gains become fully taxable for UK residents.
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Existing non-doms lose access to the remittance basis as of April 2025.
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Transitional reliefs may be available including for those restructuring offshore trusts or repatriating assets but the rules remain subject to clarification.
What does this mean for you?
If you currently rely on non-dom status or are planning a move to the UK immediate strategic planning is essential. Offshore income, legacy trusts and foreign-held assets could become subject to full UK taxation. Reviewing residency status, restructuring trusts and evaluating new holding vehicles must now be done with urgency.
These UK tax changes for non-doms and high earners in 2025 may also carry unintended consequences. With a shorter-term exemption period and fewer planning tools available, the UK risks losing its appeal as a long-term base for internationally mobile wealth. Compared to more stable or favourable jurisdictions such as Italy, the UAE or Portugal, the UK’s new tax approach may appear short-sighted to some global families. Strategic relocations may increase, particularly among those concerned about the evolving tax treatment of offshore trusts and succession plans.
New pressure on high earners: the surcharge on very high income
In addition to the non-dom reforms, 2025 has seen a new tax measure introduced: a « Super Rate » surcharge for individuals with annual income exceeding £500,000. The surcharge applies a 2% levy on top of the existing 45% income tax rate, effectively creating a new marginal rate of 47% for top earners.
This move, framed as a measure to support public services, has added another layer of scrutiny for high-income professionals, investors and business owners. Combined with the tightening of allowances and thresholds, the UK is becoming increasingly demanding from a personal tax perspective.
Greater transparency and reporting obligations
The UK continues to align itself with international transparency frameworks and 2025 has brought further updates:
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Enhanced powers for HMRC to investigate overseas income and capital
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Expansion of mandatory disclosure rules (DAC6, OECD CRS and UK DOTAS equivalents)
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Broader responsibilities for UK-resident settlors, trustees and beneficiaries of offshore trusts
In this environment, proactive compliance and detailed documentation are vital. Family offices, fiduciaries and legal advisors must remain vigilant and prepared.
Capital gains and income tax: what’s in effect now
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The CGT annual exemption has now dropped to £3,000
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Dividend income allowance is at a historic low of £500
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The effective 45% income tax threshold begins at £125,140 with pension tapering and loss of personal allowance kicking in at lower thresholds
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The new 47% marginal rate applies to those earning above £500,000
These UK tax changes for non-doms and high earners in 2025 have made personal tax planning more important than ever particularly for those with mixed income from employment, dividends and investments.
Inheritance tax: stability for now but reform still looms
No major changes to IHT have been enacted as of July 2025. The nil-rate band remains £325,000 and the residence nil-rate band is £175,000. However, political debate continues and the next fiscal cycle may bring renewed focus on simplifying or reforming IHT particularly in light of growing public interest in wealth redistribution.
For global families with UK ties the exposure of UK residential property to IHT remains in place regardless of ownership structure.
Recommended actions for UHNW individuals in 2025
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Immediately review non-dom exposure and assess your eligibility for the new four-year residence regime
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Evaluate international structures in light of new reporting and tax implications
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Prepare for the 47% super rate if your income is above the new threshold
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Seek legal and fiduciary reviews for existing trusts and holding vehicles
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Remain flexible in your residency and holding strategy as reforms continue to evolve
A full spectrum of complementary services
As these tax reforms unfold, it becomes increasingly clear that managing wealth today requires more than legal advice alone. Financing, accounting, architectural support, family office structuring and lifestyle management now play a key role in supporting modern UHNW individuals.
At Orion, we offer a curated network of professionals who can support every aspect of your international life. Whether you are renovating a prime residence in London, redesigning a villa in the South of France or seeking clarity on financial structures, we can connect you to the right people.
Our clients benefit from a full range of services encompassing legal, tax, financing, accounting, architectural and design expertise. This integrated approach ensures your personal and professional assets are managed seamlessly and with foresight.
How Orion can help
Orion’s international network connects clients to the most trusted names in private client law, tax planning and cross-border structuring. We can ensure you are supported by the best advisors in the field, with a deep understanding of your lifestyle, investment and privacy requirements.
Whether you are reevaluating your UK presence, seeking to protect multi-generational wealth or searching for properties that align with your new strategy, Orion stands beside you with discretion, insight and long-term vision.
If your circumstances lead you to relocate outside the UK, Orion can also support your transition through our global network. From establishing residence in new jurisdictions to sourcing primary or secondary homes in key locations such as Portugal, France, Italy or the UAE, our role is to ensure continuity, comfort and confidence wherever life leads you.
To learn more or be introduced to one of our trusted tax and service specialists, please contact our team in confidence.