United Kingdom: Are the ultra-wealthy foreigners leaving?
In March, the former Conservative government announced a significant tax reform, which the new Labour government is poised to implement. The Labour Party had previously urged the Sunak government to adopt this reform to effectively tackle tax loopholes and evasion. Starting April 2025, this major tax overhaul aims to generate nearly 3 billion pounds annually, which the government plans to reinvest in the critically strained education and health sectors.
Amidst growing public dissatisfaction with declining purchasing power, the government is appealing to millionaires to bolster the national economy, framing the tax reform as a stride toward social justice. This reform is part of the inheritance tax legislation.
However, critics argue that the reform targets wealthy expatriates, potentially making them the primary "losers" in the new tax framework. Slated for April 2025, the reform seeks to eliminate the non-domiciled (non-dom) tax system, an arrangement that has been in effect since 1799. Originally established to benefit colonists who amassed fortunes overseas, the system exempted them from UK taxes unless they brought their wealth back to the country. Over the years, this regime has evolved to favor wealthy foreign nationals. Currently, the non-dom status allows British residents who have lived in the UK for under 15 years and whose main residence is in another country to avoid taxes on foreign income. Approximately 70,000 residents are estimated to benefit from this status.
Millionaires departing from the United Kingdom: Social justice or wealth hunt?
As the United Kingdom grapples with the aftermath of Brexit, the debate intensifies over achieving social justice without alienating the wealthy. The impending tax reform has only heightened these tensions. A 2023 Henley & Partners study reported that since 2017, approximately 12,000 "wealthy individuals" have emigrated, with 1,500 leaving in 2022 alone. These departures are attributed to a combination of stricter immigration and tax regulations, alongside growing uncertainties about the "soft Brexit" promised by various British administrations. From 2017 to 2023, the UK saw over 16,000 millionaires leave, and projections suggest at least 9,500 more may leave this year in anticipation of the new tax changes. Popular relocation destinations include France, Germany, Switzerland, Italy, the United States, Australia, the UAE, and Canada.
Critics of the tax reform argue that it will further harm the British economy by reducing tax revenue from the wealthiest, potentially nullifying any fiscal benefits the Labour Party anticipates. Skeptics caution about the long-term economic impacts, predicting that many wealthy expatriates may never return. In contrast, reform proponents envision a transformative shift in the financial landscape, particularly affecting the real estate market. Wealthy neighborhoods could see significant changes, potentially opening doors for new investors like Americans who are accustomed to global taxation.
While surveys indicate a high likelihood of departure among non-doms if the reform is enacted (over 90% expressing intentions to leave), other studies suggest that many wealthy expatriates are committed to staying in the UK. The full impact of the reform will become clearer after its implementation in April 2025.
United States: Trump's proposal to end double taxation for American expats
As part of his electoral campaign, Donald Trump has pledged to eliminate double taxation for American citizens living abroad, a measure aimed at easing the tax burden on these individuals. Currently, the US operates on a global taxation system, requiring American expatriates to file tax returns in both the US and their host country, potentially leading to taxation in both locales if their annual income exceeds $126,500.
Trump argues that his proposed tax cuts, which would see wealthy American expatriates taxed solely in their host countries, are about fairness—aligning US policy with countries that do not impose global taxation and providing relief to Americans who feel overwhelmed by dual tax obligations. However, questions arise about whether this promise is a genuine commitment or merely a strategic electoral claim. Approximately 4.4 million Americans live abroad, with around 2.8 million eligible voters, making this a significant electoral demographic.
Trump's policy would also affect "accidental Americans"—those born in the US but who have lived most of their lives elsewhere, numbering over 300,000 in Europe alone. These individuals often face complicated tax situations, having to engage with the US tax authority despite often not owing taxes in the United States. The impact of Trump's proposal extends beyond just those actively choosing to live abroad, potentially simplifying a long-standing bureaucratic challenge for many.
Thailand: New tax reform raises concerns among expats
Since January 1, 2024, a significant change has taken effect for expatriates in Thailand: foreigners who reside in the country for at least 180 days a year are now required to declare and pay taxes on income that is repatriated to Thailand, such as retirement pensions. However, income that remains in foreign accounts does not fall under this taxable income. The 180-day residency requirement can be met either continuously or cumulatively throughout the year, and only income earned from January 1, 2024, onwards is considered taxable. Income earned before this date but transferred after December 31, 2023, is exempt, provided the expatriate can demonstrate the timing of the income.
The introduction of this tax reform has stirred concerns among expatriates, particularly over the risk of double taxation, despite Thailand having several tax treaties intended to prevent such issues. Interpretations of these agreements can vary, adding to the uncertainty. Following the reform's announcement, the Thai government has made efforts to clarify key aspects for expatriates, especially retirees, many of whom may not have sufficient income to manage the additional tax burden effectively.
To address some of these concerns, the government has exempted certain groups of foreign residents, including holders of the Long-Term Resident (LTR) visa. To qualify for this visa, however, one must meet substantial financial requirements: receiving a minimum annual pension of $80,000 and investing at least $250,000 in the Thai economy. This policy has implications not just for current expatriates but also for those considering Thailand as a potential retirement destination.
Thailand contemplates tax on global income
Thailand is considering a significant shift in its taxation policy that could impact expatriates: the introduction of a tax on global income. This proposal, which is still under review, would require individuals residing in Thailand to pay taxes on all foreign income, aligning with the principle of global taxation. This principle mandates that all incomes, regardless of where they were earned, should be taxable in the individual's country of residence.
This potential law would build upon the tax reform implemented on January 1, intensifying the tax obligations for expatriates in Thailand. There is ongoing uncertainty, particularly about whether foreigners who are tax-exempt in their home countries will enjoy the same exemptions in Thailand. As of mid-September, there has been notable opposition from a consortium of lawyers who argue that such a tax measure could be counterproductive. They caution that imposing global income taxation could deter foreign investors, whom Thailand actively seeks to attract, potentially harming the country's economic interests.
Tax reforms and their impact on expats' life projects
While tax reforms often appear to target wealthy expatriates, their effects ripple across the entire expat community, influencing life plans abroad. In the United Kingdom, despite the tax reform specifically targeting the most affluent, many expatriates who are not directly affected still express concerns. Post-Brexit socio-economic changes have left many feeling disconnected from a country they once felt at home in, and there is an apprehensive expectation of potentially stricter immigration policies under the Starmer government, which seeks to reduce net immigration.
Similarly, in Thailand—often idealized as a haven for expatriates with modest incomes from their home countries, offering a higher standard of living—there is growing anxiety. The Thai government's proposed reforms are perceived as a threat to their comfortable lifestyles, stirring fears of diminished affordability and increased financial strain.
Tax reforms fundamentally alter the landscape for expatriates, directly impacting their life projects abroad. Those currently residing in foreign territories are strongly encouraged to seek advice from tax professionals to navigate these changes. Decisions vary among expatriates; some choose to remain and adapt to the new regulations, while others consider returning to their home countries or relocating to more tax-friendly environments.
For anyone contemplating life abroad, it is crucial to thoroughly understand the tax implications in the host country. Anticipating potential shifts in tax policy and having contingency plans is advisable. Consulting with an expatriation expert can provide crucial insights, particularly regarding income management under new tax regimes, ensuring that one's international aspirations remain viable in the face of evolving fiscal landscapes.
