The arguments over whether higher taxes on wealthy UK-based people are about fairness, or self-harming, are put into fresh perspective with the publication of an annual report listing the richest Britons.

Arguments about whether UK tax policy is driving HNW individuals away, or a necessary and “patriotic” way of raising revenue, have taken another twist with the Sunday Times’ annual “Rich List” showing that a significant number of such people are no longer living in the UK.

The 38th edition of the rankings shows that the UK’s 350 most affluent individuals and families share combined wealth of £784 billion ($1.04 billion), rising 1.4 per cent on last year and a sum equivalent to a quarter of UK gross domestic product.

Figures show that there are 157 billionaires – one more than in 2025 but 20 fewer than the peak level of four years ago. The qualifying figure for being included on the Rich List has fallen by £10 million to £340 million.

In her first autumn budget, UK finance minister Rachel Reeves scrapped the UK’s resident non-domicile system which put non-doms’ worldwide assets into the inheritance tax net – a step that some had warned would trigger an exodus. Reeves also introduced a new residential system under which those who have lived outside the UK for at least 10 years can escape tax on foreign income and gains for four years. The previous Conservative government also said it intended to phase out the non-dom system. 

Coupled with Reeves widening inheritance tax on family businesses, including farms, the “fiscal drag” of freezing tax thresholds, and a move towards wealth taxes, critics say the UK has become an unwelcome place for HNW people. According to the Adam Smith Institute, a think tank, the share of the population who are millionaires will fall by 20 per cent by 2028. At the core of the argument is that if higher taxes deter HNW individuals from living in the UK, it squeezes the country’s tax base, leaving those on lower incomes having to pick up the tab.

Defenders of such policies say the non-dom regime was unfair and antiquated. A number of figures in the private client area have called for it to be reformed or replaced (see articles here and here).

“The changes to the non-dom regime from April 2025 mark a real shift in how internationally mobile individuals are taxed in the UK. For many long-term residents, it means their worldwide income and gains are now fully within scope for the first time,” Louise Lewis, partner and head of trusts, estates and tax at law firm Freeths, said in a note. 

“We’re already seeing people take stock, looking again at how they hold their wealth and, in some cases, whether the UK still works for them compared to other jurisdictions offering more certainty or lighter tax regimes.

“There are still planning opportunities, but the window is narrowing. Many individuals have been reviewing their structures ahead of the changes, from bringing forward distributions or asset sales to reassessing offshore trusts. At the same time, globally mobile families are increasingly weighing up relocation, whether short term to benefit from the new four-year regime or longer term,” Lewis said.

James Quarmby, founding partner, private wealth at Stephenson Harwood, has regularly criticised government policy on tax. 

“The Times Rich List confirms what we advisors have known for ages – the super-rich are abandoning the UK at an alarming rate,” Quarmby said in a note on his LinkedIn page. (He is also a member of this news service’s editorial board.)

“Nearly a third (111) of the UK citizens who appear in the main list of 350 individuals no longer live on the British mainland. At least 15 foreign nationals who appeared in last year’s Rich List have been removed because they now live elsewhere,” he wrote.

“What is even more alarming is the number of Brits who have left the UK – a total of 111 out of 350 have left in two years. Again, this bears out what we advisors have been seeing,” Quarmby wrote.

An issue for governments is that, unless capital controls are introduced – and they could backfire by hitting investment – HNW individuals can take capital to new jurisdictions. 

Jurisdictions such as the United Arab Emirates, Portugal, Malta, Switzerland, Singapore and Italy compete to attract affluent people with a variety of schemes.

Patriotic millionaires
The group Patriotic Millionaires, which campaigns in favour of higher taxes on HNW individuals to reduce wealth inequality and raise revenues, said on its website that its polling evidence shows support for higher levies on this group. 

“Our 2026 survey tells a good news story including: 88 per cent of UK millionaires are proud to live in the UK; 75 per cent of UK millionaires say they are willing to pay more tax to ensure the UK is a place they are proud to live in; 79 per cent of UK millionaires would be willing to pay more tax to create opportunities for young people, and 43 per cent of UK millionaires are concerned about doctors leaving the UK – whilst only 9 per cent think millionaires leaving is a concern,” it said.

Quarmby said he is unimpressed by the group’s statement. “What is the point of clinging on to delusions like this when it is obvious what’s actually happening?”

Freeths’ Lewis said data also raised questions about the competitiveness of the UK economy.

“High net worth individuals don’t just bring wealth, they drive investment into businesses, property and emerging sectors. If that capital is directed elsewhere, there’s a risk the UK misses out on growth in areas like technology, infrastructure and green investment,” she said.

No longer what it was
“The fact of the matter is that the UK is no longer seen as an attractive jurisdiction for wealth and is driving wealth creators away – both foreign and now domestic. Ever since the abolition of the non-dom regime and the inclusion of previously excluded property trusts within the scope of IHT announced at the Autumn 2024 Budget, wealthy non-UK nationals have been leaving in significant numbers," Marc Acheson, global wealth specialist at Utmost, a provider of insurance-based wealth solutions, said.

“The UK is now experiencing a second wave of departures comprising long-term nationals, entrepreneurs and business owners, driven primarily by the application of inheritance tax to family businesses. Other planned measures, including unused pension pots due to be brought within the scope of inheritance tax from April 2027, alongside the 'Mansion Tax', are also damaging the UK’s appeal among this group. 

“This all matters because the economy cannot afford to lose these individuals, who are the largest contributors to the tax base, and once this cohort leaves it is very hard to replace them," Acheson added.

Daniel Lewin, tax partner at Katten Muchin Rosenman, said: "The systematic dismantling of the non-dom regime, ironically started by the Tories, eventually came home to roost. The final straw – or perhaps death knell – for many of the super-rich living in the UK was the imposition of worldwide inheritance tax on non-UK assets after 10 years’ residency in the UK; 40 per cent tax is a huge amount.

"The numbers published in the Times today are painful reading – almost a third of UK citizens who were previously on the list no longer live in the UK or at least don’t have the UK as their main residence. Those at the very top of the list often have homes in multiple jurisdictions so that switching primary residence may have been comparatively painless. The problem actually runs much deeper than the Rich List, it’s the significant number of emerging successful asset managers, entrepreneurs and investors who came to the UK but decided to relocate to places such as Dubai, Zurich and Milan that offer very attractive tax regimes (including no tax in Dubai).

"The new FIG regime introduced to ‘replace’ the non-dom regime and exempting non-UK income and gains from UK tax altogether works well, but is limited to four years from arrival – more than enough time for a secondment or stint in the UK, but no match for the loss of non-dom status and certainly not an incentive for foreign families to grow proper roots in the UK.  

"Perhaps the most striking aspect of the Rich List is that it proves that the predictions about wealthy foreigners (and UK nationals) leaving the UK for other shores were not hype; they are reality. That said, not all is bleak – London remains Europe’s financial centre, is a highly attractive city to live in with exceptional culture, restaurants and diversity. Tax is not everything, but while the government has been promising growth, the evidence points the other way, at least for non-doms," Lewin added.