The UK’s proposals for non-doms and their structures – as of 10 March 2025

The Autumn Budget confirmed that the UK’s non-dom regime is being replaced with effect from 6 April 2025 and also set out various other changes relevant to individuals and structures with an international connection. We have since had two rounds of amendments to the draft legislation implementing these changes and individuals and trustees who are impacted should be acting now to prepare accordingly.

The UK’s tax regime for non-domiciled individuals and their structures will change from 6 April 2025 and be replaced by a new regime based on residence rather than domicile. At the same time, significant changes will be made to inheritance tax and to the taxation of trusts.

This article summarises where the proposed changes stand as of 10 March 2025. It is an updated version of our summary from October 2024 and takes into account both changes made to the draft legislation since then and the additional analysis which we have carried out in the meantime.

Whilst the proposals remain in draft form at the date of publication, the Finance Bill implementing them has passed the report stage in Parliament and so is likely to be enacted in its current form.

Read the full guide for more information, and don’t hesitate to get in touch if you have any questions.