The UK non-dom regime, the cornerstone of UK tax planning for resident non-domiciled HNW for nearly two centuries, was abolished on 6 April 2025. The replacement Foreign Income and Gains (FIG) regime is materially less favourable for HNW who have been UK-resident for any meaningful period.

For UK-based asset managers and the HNW principals they serve, the abolition has triggered the single largest cross-border HNW relocation lane in modern memory. UAE migration has been the primary destination — reflecting the UAE's no-personal-income-tax position, the depth of family-office infrastructure, and the favourable corporate-tax regime for qualifying free-zone activity.

The new FIG regime.

The FIG regime offers:

  • A 4-year exemption for new UK arrivals on Foreign Income and Gains.
  • After 4 years, full UK tax on worldwide income and gains (subject to standard treaty and reliefs).
  • Transitional relief for existing non-doms with significant accrued offshore assets.
  • The end of the remittance basis — one of the most distinctive features of the old non-dom regime.

For long-resident UK non-doms (HNW who have been UK-resident for 7+ years on a remittance basis), the FIG regime is materially less attractive than the prior arrangement. The structural alternatives — principally migration — have moved from theoretical to active planning.

UAE migration: the practical pathway.

The UAE migration pathway typically involves:

  1. UK exit planning — managing the UK statutory residence test, the tax-domicile position, the exit timeline and the asset-by-asset capital-gains positioning.
  2. UAE residency — UAE Golden Visa (typically real-estate or business-investment pathway) or employment-residency through a UAE establishment.
  3. UAE establishment — family office structure (DIFC SFO, DIFC Prescribed Company, or ADGM equivalents) hosting the wealth.
  4. Ongoing UK source-rule discipline — managing any retained UK income (UK property, UK directorships, UK trust interests) under the post-exit framework.

For UK asset managers.

UK-based asset managers face a parallel inflection point. Two distinct paths:

Path 1: Establish a UAE-domiciled manager alongside the UK manager. The UAE manager (DFSA Cat 3C or FSRA equivalent) handles the UAE-resident LP base and provides UAE substance for the manager's tax positioning. The UK manager continues serving UK-resident LPs.

Path 2: Relocate the manager to the UAE. The principals and senior team relocate; the UK presence reduces to representative office or is wound down; the manager's primary substance is UAE-resident. This is the bigger structural decision and requires careful coordination across the UK manager's LP base, FCA authorisations, key-person provisions in LPAs, and tax planning for the transition.

The structural sequence.

  1. Asset manager Path 1 vs Path 2 decision.
  2. UAE manager licensing (DFSA Cat 3C or FSRA equivalent) — 8-12 months.
  3. UAE fund vehicle (Exempt Fund, QIF, or DIFC VCC umbrella).
  4. Family office and personal wealth structure for the principals.
  5. UK exit planning for the principals.
  6. Ongoing UK source-rule and CGT discipline.

The Cornwalls advantage.

Neo Legal is the UAE practice of Cornwalls, the Australian law firm established 1891 with offices in Melbourne, Sydney and Brisbane and ALFA International / Andersen Global memberships. For UK clients, Cornwalls' international network provides coordinated UK-side counsel through Andersen Global UK and the broader ALFA legal network. The single-engagement model — UAE establishment plus coordinated UK exit — reduces friction at one of the most demanding structuring moments in a HNW principal's life.

Conclusion.

The UK non-dom abolition has fundamentally changed the structural calculus for UK-resident HNW and UK-based asset managers. The UAE migration pathway is well-developed and well-supported, but requires disciplined coordination across UK exit, UAE establishment, manager licensing, family-office structuring and ongoing UK source-rule management. Neo Legal supports UK principals and asset managers through the full UAE establishment, working alongside trusted UK-side counsel through the Cornwalls network.