The number of people claiming non-domiciled or deemed domiciled tax status in the UK fell in the final year before the long-standing regime was abolished, although the group’s overall tax contributions increased significantly, according to new figures published by HM Revenue and Customs (HMRC).
The data, covering the tax year ending 5 April 2025, shows that 81,900 individuals claimed either non-domiciled or deemed domiciled status, around 1,200 fewer than the previous year. The figures relate to the final year before the remittance basis of taxation was replaced on 6 April 2025 with a residence-based tax system.
HMRC said 73,400 people claimed non-domiciled status during the year, a decline of approximately 400, or 0.5%, from the previous tax year. The number of deemed domiciled taxpayers, who were previously non-domiciled but became subject to UK income and capital gains tax after long-term residence, also fell by around 800 to 8,500.
Despite the decline in taxpayer numbers, the group’s combined income tax, capital gains tax and National Insurance liabilities rose by 9% to £13.6 billion.
Income tax accounted for almost three-quarters of the total tax paid and reached its highest level since the 2017 tax year. HMRC also reported a 58% increase in capital gains tax liabilities, reflecting a wider rise in capital gains tax receipts ahead of changes announced in the Autumn Budget 2024.
The data also showed fewer people entering and leaving the non-dom system. Around 8,600 newly arrived taxpayers claimed non-domiciled status, down from 10,000 a year earlier, while approximately 9,000 individuals left the regime compared with 11,200 in the previous year.
HMRC’s report included figures on Business Investment Relief, which allows overseas funds to be brought into the UK without tax if invested in qualifying trading businesses. Around 400 individuals used the relief during the 2024 tax year, investing £1.7 billion in UK companies. That represented an increase of £679 million from the previous year and the highest investment level recorded since the relief was introduced.
The tax authority said this would be the final publication of non-dom statistics in their current format, with more detailed data expected in 2027. The government has previously indicated it will not have reliable estimates of how many former non-doms have left the UK under the new tax regime until next year.
Under the replacement system, new arrivals can receive relief from UK tax on foreign income and gains for their first four years of residence. After that period, they are taxed in the same way as other UK residents, while overseas assets are brought within the scope of inheritance tax.
The figures have renewed debate over the UK’s reliance on a relatively small number of high-income taxpayers. Separate analysis obtained through a Freedom of Information request by investment firm Wealth Club found the top 1% of taxpayers contributed £93.8 billion in income tax and capital gains tax during 2023-24, accounting for one-third of total receipts from those taxes.
At the same time, countries including Italy, Abu Dhabi and Cyprus have continued efforts to attract internationally mobile wealthy individuals, while London remained the centre of the UK’s non-dom population, accounting for 57% of claimants and 73% of their combined tax liabilities in the latest available figures.
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