Latest Cover Story | The Great Migration of Global Billionaires (AI Translation)
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文｜财新周刊 岳跃
By Yue Yue, Caixin Weekly
文｜财新周刊 岳跃
By Caixin Weekly's Yue Yue
要是英国国王查尔斯三世收到这封来信，他可能会有点摸不着头脑。写信的是旅居英国多年的加拿大女富商安·卡普兰·穆赫兰（Ann Kaplan Mulholland）。现年64岁的穆赫兰曾是消费金融公司创始人、真人秀节目明星，据称身家5亿英镑。几年前，她和丈夫花了550万英镑买下一座亨利八世住过的英国乡间城堡，开始了中世纪般的生活。
If King Charles III of the United Kingdom were to receive this letter, he might find himself a bit perplexed. The letter is from Ann Kaplan Mulholland, a Canadian businesswoman who has lived in the UK for many years. At 64, Mulholland is known as the founder of a consumer finance company and a reality TV star, reportedly with a net worth of £500 million. Several years ago, she and her husband spent £5.5 million purchasing a country castle in England, once inhabited by Henry VIII, ushering in a medieval style of living.
她在信中请求查尔斯国王，允许她在庄园城堡之上建立自己的国家，理由是英国即将实行的新税政会让她背负高额的税款。穆赫兰认为，若古堡变成一个国家，那么她和丈夫就不算住在英国，他们在全球其他地方拥有的14处房产和大量资产，就不会被英国征税，更不会有高达40%的遗产税。
In her letter, she requested King Charles to allow her to establish her own country over the manor castle, citing new tax policies to be implemented in the UK that would impose hefty tax burdens on her. Laughlin argued that if the castle became a country, she and her husband would technically not reside in the UK, thereby avoiding being taxed on their 14 properties and considerable assets worldwide, and eluding high inheritance taxes, which could reach up to 40%.
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- The UK plans to abolish the Non-Dom tax status by April 6, 2025, impacting 74,000 residents by taxing global income after four years of residency and generating £2.7 billion yearly.
- In response, many wealthy individuals consider relocating, with 10,800 millionaires already leaving the UK by 2024, marking a 157% increase.
- Ann Kaplan Mulholland, facing new tax burdens, initially sought to form her own country to avoid UK taxes but now plans to move to Italy instead.
[para. 1] Ann Kaplan Mulholland, a Canadian businesswoman with a net worth of £500 million, proposed a whimsical plan to King Charles III to declare her newly purchased country castle as an independent country in order to bypass hefty UK tax policies, particularly targeting Non-Domiciled Individuals’ tax privileges. Mulholland's proposal has been a topic among London's legal circles despite slim chances of success.
[para. 2] The UK plans to eliminate Non-Domiciled (Non-Dom) tax status by April 6, 2025, which has long attracted wealthy individuals. Non-Dom status allows residents to only pay UK taxes on income generated within the country, avoiding taxes on overseas income and assets for up to 15 years unless money is brought to the UK. The UK Treasury expects generating an additional £2.7 billion annually from scrapping Non-Dom status, despite possible reductions in investments and job losses.
[para. 3] As abolition of the Non-Dom status becomes imminent, there's a notable increase in wealthy individuals leaving the UK. In 2024, over 10,800 high-net-worth individuals departed, marking a significant increase compared to previous years. Shen Fengshang from Vialto Partners highlights that a profound change in UK's tax policy requires wealthy individuals to reevaluate their planning due to substantial tax changes on overseas income.
[para. 4] The abolition of Non-Dom status signals a global movement of wealthy individuals seeking low-tax regions, such as the UAE, which attracted the most high-net-worth individuals in 2024. The US and Singapore follow closely. The UAE's appeal lies in its strategic global hubs offering virtually no personal income tax.
[para. 5] Wealth migration showcases a broader shift, as emphasized by Henley & Partners, highlighting shifting global wealth and power dynamics. The UBS survey reveals significant concern among the wealthy over potential economic recession and higher taxes. Zhou Bo of KPMG China underscores the tightening global tax environment, pushing high-net-worth individuals toward compliance.
[para. 6] Historically, the Non-Dom status in the UK provided a tax avoidance route for high-income individuals since 1799, offering significant benefits in return for an annual fee. This benefited sectors like banking and oil industries. Inheritance tax is another critical concern for wealthy individuals in these changes, highlighted by the example of Akshata Murty, wife of former Prime Minister Rishi Sunak.
[para. 7] To address growing tax pressures, wealthy individuals and families, as suggested by Shen Fengshang, must take advantage of transitional periods while reassessing asset allocation and understanding regional tax laws carefully. Real estate, traditionally a high-value asset, is becoming a less central concern compared to financial assets like stocks and bonds.
[para. 8] Finally, increased global tax regulation and transparency, with initiatives like the OECD's Common Reporting Standard, further pressurize the wealthy, limiting evasive maneuvers previously accessible. The UK’s tax reforms are a preamble to widespread, significant global tax transformations requiring strategic planning by high-net-worth individuals.
- PricewaterhouseCoopers
- PricewaterhouseCoopers (PwC) is mentioned in the context of Vialto Partners, which was formerly part of PwC and now operates independently. Vialto Partners is a global tax and immigration consultancy, with a tax consulting director, Shen Fengshang, commenting on the impact of UK's tax reforms. The firm provides insights on tax planning for high net worth individuals amidst changing global tax regulations.
- Vialto Partners
- Vialto Partners is a global tax and immigration consultancy firm that was formerly part of PwC. It provides services such as tax advisory and planning for high-net-worth individuals. Vialto Partners' tax consulting director, Shen Fengshang, commented on the significant tax reforms in the UK impacting non-domiciled individuals, highlighting the need for re-evaluation of tax planning for those affected by the changes.
- Infosys
- Infosys is an Indian IT giant, and Akshata Murty, wife of former UK Prime Minister Rishi Sunak, holds at least £700 million worth of shares in the company. Her status as a Non-Dom in the UK allowed her to avoid paying UK tax on these earnings, a detail of significance given her public profile and connections.
- Henley & Partners
- Henley & Partners is an international investment immigration advisory firm mentioned in the article. They provide insights into global high-net-worth individual migration trends. Their data indicates that over 10,800 high-net-worth individuals left the UK in 2024 due to the cancellation of Non-Dom tax privileges, and 6,700 moved to the UAE, highlighting its position as a top destination for wealthy individuals.
- DLA Piper
- DLA Piper is a law firm mentioned in the article, which provides analysis regarding the potential impact of the termination of the US-China bilateral tax treaty. The firm notes that such a termination could lead to significant tax implications for cross-border investments, including issues related to dual residency, permanent establishment recognition, and cross-border transactions, potentially resulting in additional tax burdens for affected enterprises.
- UBS
- UBS conducted a survey revealing that over 53% of high-net-worth individuals are concerned about a global economic recession, while 46% see higher taxes as a significant threat. Additionally, UBS collected investment outlooks from 320 global single-family offices, finding a notable shift toward developed-market fixed-income investments and a reduced interest in commercial real estate, with many planning to increase asset allocations in North America and Asia-Pacific regions.
- KPMG
- The article mentions that Zhou Bo, a tax partner at KPMG China, highlights that worldwide countries are experiencing funding shortages, and the revision of the UK's Non-Dom tax policy aligns with the tightening global tax scrutiny. Zhou notes that tax compliance has become essential for high-net-worth individuals as enhanced transparency and AI technology improve tax regulation precision, reducing tax evasion opportunities.
- Ernst & Young
- Ernst & Young (EY) is mentioned in the article in relation to Wang Wenhui, who is identified as the Greater China Leader for Business Tax Services, the Co-Leader for Private Enterprise Tax, and the Leader for Family Enterprise in Greater China. Wang Wenhui comments on the implications of tax policy changes, such as the cancellation of the UK's Non-Dom scheme, highlighting the importance of adjusting tax residency to manage tax liabilities effectively.
- 2023：
- UK HM Revenue & Customs data shows 74,000 people declared themselves as non-domiciled residents.
- 2023：
- 4,200 high-net-worth individuals left the UK.
- 2024：
- 10,800 high-net-worth individuals are predicted to leave the UK.
- 2024：
- 6,700 high-net-worth individuals relocated to the United Arab Emirates.
- By July 2024：
- After the conclusion of the UK general election, the new Labour government announced the abolition of the Non-Dom regime.
- By December 31, 2024：
- The Dubai International Financial Centre (DIFC) had attracted 120 families and wealthy individuals, with global assets amounting to $1.2 trillion.
- February 18, 2025：
- A briefing by the Dubai Government Media Office revealed financial center statistics up to the end of 2024.
- February 25, 2025：
- U.S. President Donald Trump announced the "Golden Card" immigration plan.
- By 2025：
- Henley & Partners predicts 135,000 high-net-worth individuals will have relocated globally.
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