New Zealand in Post Non-Dom UK Planning
Tax, Residency and Capital Strategy
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From 6 April 2025, the United Kingdom abolished its non domicile tax regime. The Finance Act 2025 ended the remittance basis of taxation and replaced it with a residence based system. For wealth managers and tax advisers, this is the most significant structural change to UK international tax in a generation.
The practical effect is material. Most formerly non domiciled UK residents are now fully within the UK tax system on a worldwide basis. Offshore trust protections have been removed for those outside the new four year Foreign Income and Gains (FIG) regime. Inheritance tax has moved from a domicile based test to a residence based one.
This is not a technical adjustment. It is a change in exposure for clients and for advisers.
Key fact
The non dom regime operated for over 200 years. Its abolition from 6 April 2025 means that UK resident individuals who do not qualify for the four year FIG relief are now taxed on worldwide income and gains as they arise, in full, with no remittance basis available.
An estimated 9,300 individuals are directly affected by the removal of preferential treatment, according to HMRC’s own impact assessment.
What Has Changed for UK Clients
The new regime has three distinct components that advisers need to address with clients.
Income and Capital Gains Tax
From 6 April 2025, the remittance basis is no longer available for current or future foreign income and gains. All UK residents regardless of domicile are now taxed on worldwide income and gains as they arise, unless they qualify for the four year FIG regime.
The four year FIG regime provides 100% relief on foreign income and gains for new arrivals who have been non UK resident for the previous ten consecutive tax years. Critically, claiming the FIG relief requires giving up the UK personal allowance and the annual CGT exempt amount for those years. The relief is available once only.
Clients who became UK resident between 2022 and 2025 after a qualifying period of non-residence may claim the FIG regime for any remaining years of their four year window. Those who were already fully within the system having passed the deemed domicile threshold under the old rules or having been resident for longer than four years are taxed on worldwide income from 6 April 2025 with no transitional relief beyond the rebasing provisions.
Trust Structures
This is the area of greatest immediate exposure for many clients. From 6 April 2025, the protection from tax on income and gains within settlor interested offshore trust structures has been removed for all individuals who do not qualify for the four year FIG regime.
Foreign income and gains arising within these structures are now treated as accruing directly to the UK resident settlor in the year they arise. The use of excluded property trusts to keep assets outside the scope of UK inheritance tax has also been abolished.
A Temporary Repatriation Facility (TRF) is available for individuals who previously claimed the remittance basis. Pre 6 April 2025 foreign income and gains can be designated and remitted at a reduced rate of 12% for the first two tax years (2025-26 and 2026-27) and 15% in the final year (2027-28). The TRF closes on 5 April 2028.
Inheritance Tax
IHT has moved from a domicile-based to a residence based system. Non UK assets are now within the scope of UK IHT if an individual has been resident in the UK for 10 or more of the previous 20 tax years. The IHT exposure tail the period during which non UK assets remain in scope after leaving the UK is up to 10 years, depending on length of prior residence.
This creates a fundamentally new dynamic for clients with offshore assets who are approaching or have passed the 10 year residence threshold, and for those considering departure from the UK.
| Area | Position from 6 April 2025 |
| Remittance basis | Abolished. No longer available for any new foreign income or gains. |
| Four year FIG regime | 100% relief on foreign income and gains for qualifying new arrivals. Requires non-residence for prior 10 years. Personal allowance forfeited during claim years. |
| Offshore trust protections | Removed for those outside FIG regime. Trust income and gains taxed on settlor as they arise. |
| Temporary Repatriation Facility | Pre April 2025 foreign income and gains remittable at 12% (2025-26 and 2026-27) or 15% (2027-28). Closes 5 April 2028. |
| CGT rebasing | Foreign assets held on 5 April 2017 rebased to market value at that date for eligible former remittance basis users. |
| Inheritance tax | Residence based from 6 April 2025. Non UK assets in scope after 10 of prior 20 years of UK residence. IHT tail up to 10 years after departure. |
Global Trends Amplifying the Exposure
The UK changes do not sit in isolation. Three parallel developments are compressing the options available to internationally mobile clients.
Expansion of Transparency Frameworks
The OECD Common Reporting Standard (CRS) is now active across over 100 jurisdictions. The Crypto Asset Reporting Framework (CARF), agreed at OECD level, is being implemented across key financial centres from 2026 onwards, extending automatic reporting into digital assets, stablecoins, and tokenised securities. The practical effect is that offshore capital is increasingly visible to home-country tax authorities regardless of structure.
Strengthening Exit Tax Regimes in Europe
A number of European jurisdictions have tightened exit tax provisions in the past two years. Under current EU Anti Tax Avoidance Directive (ATAD) requirements, member states must apply exit taxation on unrealised gains at the time an individual ceases to be a tax resident. Several jurisdictions have extended these rules further. The consequence is that capital movement now carries a tax cost that was not present in earlier planning cycles.
Increased Scrutiny of Capital Flows
The IMF’s 2023 Institutional View on capital flow measures acknowledged the legitimacy of broader use of capital controls in defined circumstances. Several OECD member states have introduced or strengthened beneficial ownership registers, real property foreign ownership restrictions, and financial intelligence reporting obligations. These measures create friction in capital movement that was not present five years ago.
The direction of travel is consistent across all three:
Greater visibility of offshore assets. Higher cost of capital movement. Reduced structural flexibility.
Clients who relied on structural separation between their UK tax position and their offshore wealth are now operating in a materially different environment.
The Shift in Advisory Focus
The non-dom abolition and the global transparency trends described above are changing the nature of client conversations.
The question is no longer: How do I optimise my tax position?
It is: How exposed am I and what control do I retain?
| Previous advisory focus | Current client priority |
| Tax efficiency and remittance structuring | Exposure management and certainty |
| Offshore structure maintenance | Capital mobility and unobstructed movement |
| Product selection and yield | Jurisdiction stability and rule of law |
| Domicile planning and IHT mitigation | Second jurisdiction residency and long term optionality |
Advisers who can address cross border exposure and capital mobility, not just tax efficiency are better positioned to retain and attract clients navigating this environment.
Why Jurisdiction Strategy Is Now Central
A significant number of formerly non domiciled clients are now evaluating their long term position in the UK. The relevant questions are no longer about which structures to use within the UK system. They are about where capital should be held, how it moves, and what legal system provides the most reliable framework.
Three factors now dominate client conversations on jurisdiction:
- Capital mobility. The ability to move capital without restriction is a core planning variable. Jurisdictions that impose capital controls, beneficial ownership disclosure requirements, or asset freeze powers create friction that was absent in prior planning cycles.
- Rule stability. Clients are asking which jurisdictions have a track record of legislative stability not just what the current rules are, but how confident they can be that the rules remain consistent over 5 to 10 years.
- Legal system independence. Common law systems with independent judiciaries provide structural protections for property rights that are materially different from civil law frameworks. This distinction is increasingly relevant to clients reviewing single jurisdiction concentration.
These three factors point toward a secondary jurisdiction, not as a replacement for the UK base or primary domicile, but as a structurally separate anchor in a different legal system, geopolitical bloc, and banking infrastructure.
New Zealand: A Factual Assessment
New Zealand is emerging as a jurisdiction of material interest in post non dom planning discussions. Its relevance is not primarily tax driven. It is structural.
Tax Position (verified April 2026)
| Tax feature | Position (2025-26 tax year) |
| Inheritance tax | None. No estate duty, gift duty or death duties under NZ law. |
| Wealth tax | None. |
| Capital gains tax | No broad CGT. Bright line test applies to residential property sold within 2 years of acquisition only (reduced from 10 years from 1 July 2024). |
| Foreign income exemption | Transitional Residency Exemption: 48 months on most foreign sourced income (dividends, interest, rents, CFC and FIF income) for qualifying new arrivals. Available once in a lifetime. |
| Tax competitiveness | Ranked 3rd globally on the Tax Foundation International Tax Competitiveness Index 2025. |
| FIF modernisation | Revenue Account Method proposed for qualifying new migrants: tax on dividends and 70% of realised gains rather than notional returns. Legislation expected by March 2026. |
From February 2026, AIP resident visa holders based offshore are also permitted to purchase or build one residential property in New Zealand with a minimum value of NZD 5 million. Relevant legislation is expected to be passed before the end of 2026.
Legal System and Institutional Framework
- Legal system. Westminster common law, independent of all civil law treaty blocs. No history of capital controls or foreign asset freezes.
- FATF status. OECD member. Ranked 3rd globally on the Tax Foundation International Tax Competitiveness Index 2025.
- Passport. Ranked 6th globally on the Henley Passport Index 2026. Visa free or visa on arrival access to 189 destinations. Dual citizenship permitted.
- Capital controls. No restrictions on inbound or outbound capital movement.
- Property rights. Strong statutory and common law protection. Stable policy environment with no material changes to investor protections over the past two decades.
New Zealand in Post Non Dom Planning
For clients whose UK tax position has materially changed since April 2025, New Zealand offers a set of structural characteristics that are directly relevant to the questions they are now asking.
| Client situation | NZ relevance | |
| 1 | Client now taxed on worldwide income. Significant offshore income portfolio. | 48 month Transitional Residency Exemption on most foreign income for qualifying new NZ residents. |
| 2 | Client approaching 10 year UK residence threshold. IHT exposure expanding. | NZ has no inheritance tax, no estate duty, no gift duty. Holding assets in NZ does not attract IHT. |
| 3 | Offshore trust structure now exposed. Considering restructure or departure. | NZ foreign trust disclosure regime is legislated and transparent. Trust income tax-transparent during transitional residency period. |
| 4 | Client has NZD 5M+ investable capital. Seeking permanent residency option with low physical presence. | AIP Growth: NZD 5M, 21 days over 3 years, no language test, average 35 working days to approval. PR pathway included. |
| 5 | Client seeking legal system independence from UK and EU civil law frameworks. | Westminster common law judiciary. No capital controls. No history of foreign asset restrictions. Structurally independent of all civil law blocs. |
Conclusion
The abolition of the UK non dom regime marks the end of a planning framework that shaped UK international tax practice for over two centuries. The replacement system is more transparent, more uniform, and more aligned with global reporting standards, but it significantly increases the exposure of clients with offshore income, offshore structures, and offshore assets.
At the same time, OECD transparency frameworks are extending into new asset classes, European exit tax rules are tightening, and capital movement is under closer scrutiny than at any point in the modern era.
The client conversation has therefore shifted from optimisation to control. The relevant advisory question is no longer how to structure around the UK system, but how exposed the client is and what options exist for managing that exposure over the long term.
Jurisdiction strategy is now central to that discussion. New Zealand, with no inheritance tax, no wealth tax, no broad CGT, a 48 month foreign income exemption for new arrivals, a common law judiciary, and a residency pathway that requires 21 days of physical presence over three years, addresses each of the core questions that post non dom clients are asking.
New Zealand is not a replacement for the UK. It is a structurally distinct second jurisdiction in a separate geopolitical bloc, operating an independent legal system, with a transparent and stable tax framework and a residency pathway that is currently among the least friction intensive in the developed world.
This briefing is prepared by Safe Haven NZ for professional advisers only. It is based on publicly available information verified as at April 2026 and does not constitute legal or tax advice. UK tax information is sourced from HM Treasury, HMRC, and Finance Act 2025. New Zealand information is sourced from Immigration New Zealand, Inland Revenue NZ, the Tax Foundation, and the Henley Passport Index. Clients should obtain independent legal and tax advice in their jurisdiction of residence before making any decisions. Safe Haven NZ is a New Zealand investor visa specialist and does not provide UK legal or tax advice.