In today’s shifting international tax environment, wealthy individuals and business owners are increasingly reviewing their financial footprints — and in many cases, redrawing them entirely.
At Fusion Consulting Group, our international tax team — including leading experts, like myself — are helping clients adapt to a wave of global tax reforms that are changing the rules of wealth management. From the UK’s scrapping of the non-domicile regime to growing uncertainty in traditional financial hubs like Switzerland, tax planning is no longer a static exercise. It’s strategic, international, and fast-evolving.
UK: A New Era for Non-Doms
One of the most headline-grabbing announcements came in the UK’s Spring Budget 2024: the abolition of the long-standing non-dom regime from April 2025.
The current system allows individuals with non-UK domicile status to limit their UK tax liability by only paying UK tax on foreign income and gains if and when they are remitted to the UK. From 2025, this will be replaced by a new residence-based system. Foreign income and gains will become taxable after just four years of UK tax residency, with no consideration of domicile.
While transitional reliefs have been proposed — including a four-year exemption for new arrivals and a temporary 12% repatriation facility — the changes represent a material shift in the UK’s attractiveness to globally mobile high-net-worth individuals.
Inheritance Tax: Political Pressure Mounts
Simultaneously, inheritance tax (IHT) remains under scrutiny. Despite calls for reform or abolition from within the UK’s Conservative party, the system remains intact. The nil-rate band has been frozen at £325,000 since 2009, and the residence nil-rate band remains subject to complex tapering.
In Europe, the pressure is even greater. In Switzerland, a country long considered a haven for family offices and private wealth, political discourse around a potential 50% inheritance and gift tax has caused alarm. Though voters are expected to reject the proposal, the reputational damage and perceived risk have already prompted some families to look elsewhere — particularly to Dubai, where disclosure requirements are more relaxed and regulation around family offices remains light.
Property Taxes in the Spotlight
Cross-border property ownership is also drawing greater scrutiny. In the UK, changes to capital gains tax for non-residents, increased stamp duty surcharges, and ongoing consultations around the transparency of ownership structures have increased the tax burden and complexity for overseas investors.
In jurisdictions such as the UAE, by contrast, no capital gains tax and no property inheritance tax are proving attractive — particularly as UK property continues to be a key asset class for international investors.
Strategic Wealth is Becoming Borderless
As tax laws grow more complex and political sentiment shifts, international tax planning is no longer the domain of the ultra-wealthy alone. Entrepreneurs, senior executives, and family business owners are increasingly seeking advice on how to structure their affairs globally.
Our international tax team at Fusion is helping clients navigate this change — from identifying jurisdictional risks, to optimising cross-border income, to preparing for major life events like exits or succession planning.
One thing is clear: tax is no longer just local. And staying ahead requires more than compliance — it demands insight, agility, and a global mindset.
To speak with one of our international tax specialists, or explore what the 2025 tax changes mean for you or your business, get in touch today.
