The combined tax and national insurance contribution (NIC) liabilities for non-domiciled and deemed domiciled taxpayers in the UK rose by 2 per cent year-on-year to £12bn in the tax year ending 2024.

HMRC’s latest statistics on non-dom taxpayers in the UK showed that around three quarters of liabilities were for income tax.

It estimated that there was a combined total of at least 83,000 non-dom and deemed domiciled taxpayers in 2023/24, with the vast majority being non-doms.

This represented a 1 per cent decline from the 83,900 non-dom and deemed domiciled taxpayers in 2022/23.

The fall of around 900 taxpayers reflected inflows of 9,100 non-dom taxpayers in 2023/24, down by 5,100 on the previous year, offset by 9,500 individuals no longer indicating non-dom status through self assessment and around 500 fewer deemed domiciles.

Income tax receipts from non-dom taxpayers increased by £521m year-on-year to £9bn in 2023/24, although this was partly offset by a £175m reduction in NICs and a £133m fall in capital gains tax (CGT) receipts.

Although the combined tax and national insurance contributions (NIC) liabilities for non-domiciled and deemed domiciled taxpayers increased in 2023/24, recent policy decisions have resulted in an exodus of non-doms from the UK.

“It is a shame that just as the UK was seeing strong evidence of a sharp recovery in the numbers of non-dom taxpayers since the height of the Covid-19 pandemic along with higher tax receipts from this community, the Conservatives announced the end of the non-dom regime and Labour subsequently removed inheritance tax (IHT) protections on the foreign assets of non-doms,” commenting Utmost Wealth Solutions global wealth specialist, Marc Acheson.

“Ever since the latter decision was announced in the Autumn Budget, the UK has seen non-doms exiting at an unprecedented rate.

“While the non-dom regime was imperfect, it drew people in for the long-term and resulted in significant tax receipts. Its replacement with the new four-year Foreign Income and Gains regime is short-term in nature and internationally uncompetitive.

“The exodus of wealth shows no signs of slowing down, and while it was recently reported that Chancellor, Rachel Reeves, was exploring reversing the decision to charge UK IHT on the global assets of non-doms, a lot of trust has already been lost.

“In the meantime, other jurisdictions such as Italy, Switzerland and the UAE with more attractive regimes are benefitting from the UK’s loss of this community.”

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