Q&A: Impact of the abolition of the non-dom regime

What is the key Budget announcement?

The big news from Jeremy Hunt’s Spring Budget 2024 was the abolition of the non-dom tax regime and announcing a new modernised ‘tax holiday’ for individuals moving to the UK.

The non-dom tax regime dates back to when income tax was introduced in 1799 where residents were only taxed on income arising abroad to the extent that it was received in this country. This was the first incarnation of the remittance basis (RB) of taxation and was only modified in 1914 where the eligibility was restricted to residents who were not domiciled or not ordinarily resident in the UK.

The fundamental principles of the RB regime used by non-doms has broadly remained the same since the 1900s – that a non-dom is only taxed on their overseas income and capital gains to the extent the monies are brought to or used in...