[Weekly Preview] Cover Story: The Great Wealth Migration: Why the Ultra-Rich Are Fleeing Britain (AI Translation)
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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 received this letter, he might find himself a bit puzzled. The sender of the letter is Ann Kaplan Mulholland, a wealthy Canadian businesswoman who has been residing in the UK for many years. At 64, Mulholland was previously the founder of a consumer finance company and a reality TV star, reportedly with a net worth of £500 million. A few years ago, she and her husband purchased a British country castle once inhabited by Henry VIII for £5.5 million, embarking on a medieval-style life.
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 atop the estate castle, arguing that the impending new tax policy in the UK would burden her with high taxes. Mulholland contends that if the ancient castle became a country, she and her husband would not be considered residents of the UK, and thus their 14 properties and substantial assets held globally would not be subject to UK taxes, particularly the 40% inheritance tax.
这一异想天开的计划，近日在伦敦专门为高净值人群服务的事务律师圈成为谈资，显然几乎没有任何实现的可能。但穆赫兰还是公开表示，“欢迎所有受到此次税政变化影响的人都来到我的王国”。
This fanciful plan has recently become a topic of conversation among solicitors in London who cater specifically to high-net-worth individuals. Clearly, the plan has almost no chance of becoming a reality. However, Mulholland publicly stated, "We welcome all those affected by these tax policy changes to come to my kingdom."
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- Ann Kaplan Mulholland, a wealthy Canadian businesswoman, considered creating her own country in the UK to avoid taxes after purchasing a historic castle, but ultimately shifted to applying for Italian residency.
- The UK's abolition of the Non-Dom tax status in 2025 led to a significant increase in wealthy individuals leaving the UK, as evidenced by a 157% increase in departures in 2024.
- The Global Migration trend shows high-net-worth individuals relocating to areas with lower tax rates, with the UAE, the US, and Singapore being top destinations.
[para. 1] King Charles III might be perplexed upon receiving a letter from Ann Kaplan Mulholland, a wealthy Canadian businesswoman in the UK, who proposed to establish her own nation to avoid looming UK tax changes. Mulholland and her husband, who purchased a historic castle, aim to evade the UK's 40% inheritance tax by declaring the castle a sovereign entity. Her idea, though fanciful, echoes concerns among the wealthy over the UK's evolving tax landscape.
[para. 3] The UK's tax policy change, effective April 2025, abolishes the Non-Domiciled (Non-Dom) status previously allowing UK residents with a foreign domicile to avoid taxes on overseas income for up to 15 years. The move, aimed at generating £2.7 billion annually for the UK Treasury, reflects a shift towards rigorous taxation amidst domestic economic and political pressures. Previously, 74,000 individuals were registered as non-UK domiciled residents, retaining significant tax advantages.
[para. 3] Non-Dom status offered tax sheltering for high-income individuals, allowing them to enjoy eased tax obligations on foreign income. Critics and the Labor government view its abolition as a step towards tax equity. Nonetheless, think tanks argue these changes could deter investment, spelling job losses and prompting wealth individuals' relocation, thereby weakening the economic landscape.
[para. 4] Ann Kaplan Mulholland opted for Italian residency over her UK kingdom plan due to legal barriers. Her decision reflects a larger trend of affluent individuals seeking foreign residency. The consultancy Henley & Partners anticipates substantial outflows from the UK, estimating over 10,800 wealthy departures in 2024 alone. This shift underscores anxieties over the tax overhaul and its implications for asset management.
[para. 5] Wealth migration is not a novel phenomenon. Businesses and individuals are responding to global tax reforms by repositioning their assets to minimize liabilities. Offering favorable climates, the Middle East emerges as a new hub, with 6,700 high-net-worth individuals migrating there in 2024 alone. In contrast, U.S. policy shifts, like President Trump's "Gold Card" proposal for permanent residency, may also attract affluent expatriates.
[para. 8] Responses to tax policy changes require strategic adaptations. New residence regulations, like the UK's upcoming "4-year Foreign Income and Gains Regime," compel wealth reassessments for global assets. The timeline reduction from 15 years to four for tax-exempt status prompts calls for nuanced planning among investors, alongside potential employment of global tax agreements to mitigate impacts.
[para. 12] Hong Kong and Singapore offer attractive tax climates, drawing family offices and investments with comparatively lower tax burdens. These locations provide an appealing regulatory environment amidst growing global transparency and tax compliance demands. The shift emphasizes a significant recalibration of high-net-worth individuals' strategy towards tax efficiency without sacrificing compliance integrity.
[para. 20] The OECD's Global Transparency Initiative, exemplified by the Common Reporting Standard (CRS), demands greater disclosure from banks about offshore accounts, significantly narrowing tax avoidance avenues. The surge of implemented CRS regulations calls for compliance, revealing transfer practices of wealth. Consequently, asset arrangements adjust to comply with increasingly detailed disclosures and evolving global standards.
[para. 24] Global asset realignments among the wealthy consider not only tax efficiency but also regulatory environments. Selling UK properties is one response to tax challenges; however, more attention focuses on diversified asset structures across financial assets and international locations. Family offices tend to emphasize this strategic diversification, balancing exposure across varied assets in emerging markets and established economies.
Overall, the recent global tax trends signify a marked shift in operating environments for high-net-worth individuals. Tax reforms, like abolishing the UK's Non-Dom status, prompt realignments in asset holdings, unravel long-held tax shelters, and emphasize compliance in a changing tax landscape. These shifts portray a need for proactive planning, innovative financial strategies, and openness to migration among global elites.
- Infosys
印孚瑟斯 - Infosys is an Indian IT giant co-founded by the father of Akshata Murty, who is the wife of former UK Prime Minister Rishi Sunak. Murty, an Indian citizen, holds shares in Infosys valued at £700 million. Her status as a "Non-Dom" resident in the UK has allowed her to avoid British taxes on her overseas income, which has been a point of public debate.
- UBS
瑞银 - UBS conducted a survey revealing that over half of high-net-worth individuals are concerned about a potential global economic recession in the next five years, with 46% viewing higher taxes as the greatest threat. UBS's analysis also indicates that family offices tend to focus on diversified investments, with significant allocations in traditional assets like stocks and bonds. Additionally, a report highlights increasing asset allocation in North America and Asia-Pacific regions in the coming years.
- KPMG
毕马威 - The article mentions Zhou Bo, a tax partner at KPMG China, stating that global tax systems are tightening, reflecting a trend towards stricter and more transparent global tax regulation. He notes that, historically, there might have been tax avoidance practices due to low information transparency. However, with advances in AI technology, tax compliance has become an inevitable choice for high-net-worth individuals.
- PwC
普华永道 - The article mentions that Vialto Partners was once part of PwC (PricewaterhouseCoopers) before becoming an independent global tax and immigration consultancy. It does not provide further specific information about PwC itself.
- Vialto Partners
纬迩拓 - Vialto Partners is a global tax and immigration consultancy firm that was formerly part of PwC before becoming independent. The article mentions that Vialto Partners’ tax consultancy director, Shen Fengshang, commented on the UK's tax reform, noting the significant impact on high net worth individuals due to changes in tax responsibilities for overseas income and assets.
- DLA Piper
欧华律师事务所 - DLA Piper is a law firm that analyzed the potential impacts of the U.S. possibly canceling its 1984 tax treaty with China. The firm suggests that canceling this treaty could hinder U.S. taxpayers' investments in China by preventing tax credits for taxes paid there, leading to double taxation. Conversely, it might also deter Chinese investments in the U.S.
- Tian Yuan Law Firm
天元律师事务所 - Tian Yuan Law Firm analyzed the potential impact of terminating the China-U.S. bilateral tax treaty. They suggest that such a move could lead to significant changes in cross-border investment tax environments, potentially increasing tax burdens and complicating business arrangements between the two countries, with combined tax burdens potentially exceeding 50%.
- Henley & Partners
恒理 - Henley & Partners is an international investment migration consultancy. They provided data indicating that the impending cancellation of the UK's Non-Dom tax regime led to a significant increase in high-net-worth individuals leaving the UK, with over 10,800 departing in 2024. Their data also highlighted that the UAE emerged as the top destination for high-net-worth individuals, with 6,700 moving there in 2024.
- 2024：
- Over 10,800 high-net-worth individuals left the United Kingdom, marking a significant increase compared to 2023.
- 2024：
- A total of 6,700 high-net-worth individuals relocated to the United Arab Emirates, making it the leading destination globally.
- July 2024：
- The UK general election took place, and the new Labor government announced the abolition of Non-Dom status.
- February 18, 2025：
- The Dubai Government Media Office revealed that the DIFC had attracted 120 families with global assets.
- February 25, 2025：
- U.S. President Donald Trump announced a 'Gold Card' immigration plan for obtaining permanent residency in the United States.
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