The demand for private client services has never been higher, with family businesses and non-doms wanting to understand how the Autumn Statement 2024 is going to impact them.
But there is also a new emerging trend: international entrepreneurs looking to move to the UK to prepare for their exit event and benefiting from the new foreign income and gains regime. Could this make London the next exit capital of the world?

From April 6 2025 individuals who move to the UK can claim the new Fig regime, provided that they have not been resident in the UK in any of the previous 10 years. For those young entrepreneurs who studied in London, they will just need to check that they qualify. Qualifying individuals are exempt from UK tax on most sources of income and gains for the first four years of living in the UK.

The current remittance basis regime was essentially a deferral mechanism as the income or gains were exempt in the year that it arose (if it was during a remittance basis year), but there would be UK tax when the funds were remitted to the UK. Under the new Fig regime, this is a permanent exemption, so no UK tax when the income or gains arise but also no UK tax when the funds are brought to the UK in the future.
Also, unlike the current remittance basis rules (or indeed other international regimes such as Italy), there is no ‘fee’ for the Fig regime. You simply claim the exemption on your personal tax return, and it applies for the first four years.

The hidden cost for the taxpayer is that they will need to disclose all of their worldwide income and gains to the UK tax authorities during those first four years in order to claim the exemption.

For the majority of taxpayers that will be a price worth paying. For those with complex offshore structures it may not be so straightforward, but seeking UK tax advice in advance of arriving should help.

As an example, an international entrepreneur may be looking to exit their business in the next year or so. They could come to the UK after April 6 2025 and, provided that they qualify for the Fig regime, they could sell their overseas business during the first four years of arrival in the UK and pay no UK tax on the gain even if they brought the money to the UK now or in the future.

There is the question of the overseas jurisdiction and whether they would seek to tax the gain but there are a number of countries that do not tax non-residents, plus there are various double tax treaties that the UK has with other countries that could also be helpful here.

When you combine the Fig regime with good schools, cultural diversity and vibrant London atmosphere, you can see why international entrepreneurs are looking closely at the UK as a destination to exit their business.
In my view there are ways in which the Fig regime could be improved to make the UK even more attractive. Declaring worldwide income and gains to HMRC is likely to put some people off and although I am sure that the tax authorities would find the data insightful, it is not relevant to collecting the right amount of tax for the first four years, so I do not think that it should be a requirement.

The length of the Fig regime is also too short as the year of arrival and departure is included within the first four years. For example, if someone arrives in March 2026, they have already used up one of their four years even though they have only been in the UK for one month out of the first tax year.

I am already seeing it with the behaviours of the international entrepreneurs who are considering coming to the UK. Their outlook is very temporary, staying in the UK for a couple of years, whereas previously non-doms would often be considering staying for a longer period (sometimes 10 or 15 years) while their children finished their education.

As those benefiting from the Fig regime will have a little or no UK tax liability for those first four years, I would have thought that the additional tax revenue through spending while in the UK would not be enough and therefore keeping them in the UK after four years was key.

Let’s hope that we continue to see the influx of international entrepreneurs coming to the UK and that once they are here, they decide to stay even after the Fig regime has run out.