Where the non-doms went, and what they did when they got there

The question of where UK non-doms went, and what they did once they arrived, stopped being hypothetical sometime around mid-2025. The abolition of the remittance basis, confirmed in the Spring 2024 Budget and enacted from April 2025, triggered exactly the kind of wealth migration that critics warned about and supporters dismissed as bluffing. It wasn't bluffing. HMRC's own preliminary data, combined with reporting from wealth managers and immigration lawyers across Europe and the Gulf, paints a clear picture: a significant number of high-net-worth individuals left, and they did so with planning, purpose, and professional advice. The destinations weren't random. They were chosen based on tax efficiency, lifestyle compatibility, banking access, and long-term residency stability. Some choices have already proven smart. Others are looking shaky as host countries adjust their own rules in response to the influx. This is a look at where the money moved, what structures were set up, and which jurisdictions are actually delivering on their promises.

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The numbers behind the UK exodus

Precise figures remain contested, but the direction is not. The Office for Budget Responsibility estimated in late 2025 that approximately 10,600 individuals previously claiming non-dom status had either left the UK or restructured their affairs to reduce UK tax exposure. That number likely understates the reality, since it only captures those who filed self-assessment returns for the 2024-25 tax year and then failed to file for 2025-26.

Wealth advisory firms reported a 40-60% increase in relocation enquiries between Q2 2024 and Q1 2025. Oxford Economics estimated a capital outflow of between £8 billion and £12 billion in the 18 months following the announcement, though much of this was trust restructuring rather than physical cash leaving the country. The Statutory Residence Test became the critical mechanism: individuals needed to break UK tax residency cleanly, which meant fewer than 16 UK tie days or careful management of the automatic overseas test. Those who got the SRT wrong face years of HMRC scrutiny. Those who got it right are now tax resident elsewhere, and the UK has lost both their income tax and their spending.

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Italy's flat tax, and the 2026 increase

Italy's flat tax regime for new residents was, until recently, the most popular landing spot for departing UK non-doms. The scheme offered a fixed annual charge of €100,000 on all foreign-sourced income, regardless of amount. For someone earning £5 million annually from overseas investments, this was extraordinarily attractive: a sub-2% effective rate.

Then Rome raised it, twice. From January 2025, the flat tax rose to €200,000 for new applicants; existing participants were grandfathered at the original rate for the remainder of their 15-year window, creating a two-tier system. From 1 January 2026, the Italian Article 24-bis regime rose again, to €300,000 per year for anyone making a new election, plus €50,000 per year for each family member who joins. Individuals who elected before 1 January 2026 remain grandfathered at €200,000 for the remainder of their term.

At €300,000, the regime still works well for individuals with substantial foreign income. For those in the £1-2 million bracket, the numbers start to look less compelling compared to alternatives. Italy's appeal was never purely fiscal, though. Milan and the Italian lakes offer a genuine lifestyle proposition, and the country's bilateral treaty network is extensive. The real risk is political: Italy's regime has survived multiple governments, but the populist left has repeatedly called for its abolition. Anyone relying on a 15-year window should consider what happens if the window closes at year six.

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Switzerland's forfait, and who still qualifies

Switzerland's lump-sum taxation, known as the forfait fiscal, remains the gold standard for wealth preservation, but access has narrowed considerably. Several cantons abolished the regime following a 2014 federal referendum, and those that retained it imposed minimum taxable bases that have risen steadily. In 2026, the typical minimum deemed expenditure sits between CHF 400,000 and CHF 600,000 depending on the canton, with Vaud and Valais remaining the most accessible. The Swiss Federal Tax Administration publishes canton-by-canton guidance for new applicants.

The critical requirement is that forfait residents cannot work in Switzerland. This suits retirees and passive investors but excludes active entrepreneurs. The application process itself has become more demanding: cantonal tax authorities now routinely request three years of global income documentation before agreeing terms. Banking is straightforward, with UBS and Lombard Odier both experienced in onboarding forfait clients. Schooling options are world-class, particularly around Lake Geneva. The downside is cost of living: Geneva consistently ranks among the three most expensive cities globally. For families with children in international schools and staff to house, annual non-tax living costs can easily exceed CHF 500,000. Switzerland works brilliantly for the genuinely wealthy. For those worth £5-10 million rather than £50 million, it can feel like an expensive way to save tax.

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The UAE: tax position, residency and the substance question

Dubai absorbed the largest single cohort of departing UK non-doms, and it's easy to see why. Zero personal income tax, zero capital gains tax, and a residency visa obtainable through property investment starting at AED 750,000. The Golden Visa programme, offering 10-year residency for property investments of AED 2 million or more, became the preferred route for families seeking stability.

But the UAE's tax-free status comes with a substance requirement that many new arrivals underestimate. The introduction of UAE corporate tax at 9% in June 2023 changed the game for anyone running business activities through a UAE entity. HMRC, in particular, has become aggressive about challenging the tax residency of UAE-based structures where decision-making still happens in London. If you're sitting in a WeWork in DIFC taking calls from your UK-based team, your company's central management and control may well remain in the UK. The UAE FTA has also begun auditing more actively, looking for inconsistencies between VAT filings and corporate tax returns.

The smart relocators established genuine commercial substance: physical offices, local employees, documented board meetings held in the UAE, and bespoke intercompany agreements drafted by qualified advisers rather than pulled from template libraries. Those who treated Dubai as a postal address with sunshine are the ones now receiving enquiry letters from HMRC. What that substance actually looks like in practice is often more demanding than the headline marketing suggests, and founders who relocated without understanding it are exposed. For those coming specifically from the UK, there is a detailed playbook on what European founders should do before moving to the UAE that covers the sequencing and documentation most advisers skip.

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Cyprus, Greece and the EU residual options

Cyprus and Greece emerged as strong alternatives for those wanting EU residency without Italian price tags or Swiss exclusivity. Cyprus offers a non-dom regime of its own: 60-day tax residency is achievable, and foreign dividend and interest income is exempt from personal tax for 17 years. The corporate tax rate of 12.5% and an extensive double tax treaty network make it attractive for holding structures. The catch is that Cyprus's banking sector, while recovered from its 2013 crisis, still lacks the depth of Swiss or UK private banking. Opening accounts for complex structures takes time, and compliance departments are cautious with UK-connected wealth.

Greece introduced a flat tax of €100,000 on foreign income for new residents in 2020, directly modelled on the Italian scheme. Take-up has been slower, partly because Athens lacks the infrastructure that Milan or Geneva offers for international families. Schooling options are limited outside a handful of international schools, and the Greek bureaucracy remains genuinely difficult to work with. For retirees, Greece offers a separate 7% flat tax on foreign pension income, which has attracted a steady flow of UK pensioners with defined benefit schemes. Both countries offer EU residency rights, which matters for those wanting freedom of movement across the bloc, something the UK passport no longer provides.

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Banking, schooling and the lifestyle calls that decide it

Tax rates fill spreadsheets, but families make decisions based on daily life. The three factors that most frequently determine where UK non-dom relocators actually settle are banking access, school quality, and spousal happiness. That last one sounds flippant. It isn't. Wealth advisers consistently report that the single biggest cause of failed relocations is a spouse who can't build a life in the new jurisdiction.

Banking deserves specific attention. Opening accounts in Switzerland or the UAE is generally straightforward for individuals with clean source-of-wealth documentation. Cyprus and Greece are harder. Multi-jurisdictional structures involving trusts, BVI companies, and nominee arrangements trigger enhanced due diligence that can take six months or longer. The OECD's Common Reporting Standard now means that financial information flows automatically between over 100 jurisdictions, so the quality of compliance documentation matters as much as the account itself.

Schools vary enormously. Switzerland and the UAE offer established international curricula with IB and A-level tracks. Italy has strong options in Milan and Rome but fewer choices elsewhere. Cyprus has a small number of adequate international schools, mostly in Limassol and Nicosia, but nothing comparable to the depth available in London. The lifestyle question extends to healthcare, travel connectivity, and social infrastructure. Dubai offers year-round sun but brutal summers. Geneva offers culture and safety but can feel isolating. Milan offers energy and food but Italian bureaucracy. There is no perfect answer, only the least imperfect fit for each family's priorities.

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A decision matrix for the next ten years of residence

Choosing where to relocate isn't a one-year decision. It's a ten-year commitment, minimum. The families who planned well asked three questions before moving: what does the tax regime look like in 2026, what is the political risk of it changing by 2030, and can I actually live here happily for a decade?

The strongest positions belong to those who secured Italian flat tax at the grandfathered €200,000 rate, or Swiss forfait in a stable canton with a long track record. The riskiest positions belong to those who moved to Dubai without establishing genuine substance, or who chose a jurisdiction based purely on headline tax rates without considering treaty access, banking friction, or HMRC's increasingly data-driven approach to challenging overseas residency claims.

One category of risk that is underappreciated is the exit tax exposure many relocators carried out of the UK. The UK currently imposes no general exit charge, which is one reason the Tax Policy Associates analysis of the Revolut founder's departure attracted such attention. However, the temporary non-residence rules mean that gains realised within five years of departure on assets held when leaving can be brought back into UK tax on return. Founders who plan to return to the UK within that window need to account for this, and anyone relocating with substantial unrealised gains should read the full picture on what it costs to leave before you sell.

For anyone still weighing their options, the window for clean planning hasn't closed, but it has narrowed. The UK's new regime offers a four-year transitional period for genuinely new arrivals, which may suit some. For those already gone, the priority is documenting substance, maintaining clean SRT records, and ensuring that intercompany agreements and trust structures are professionally drafted rather than assembled from generic templates. The non-dom era is over. The question now is whether the alternatives chosen will hold up under scrutiny for the years ahead. Cosmos works with founders and family offices on the structure, substance and ongoing compliance across all of the jurisdictions covered here.