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When the UK ended its non-domicile tax regime in April 2025, the change was more than just a technical tax reform, it was a signal that the country's relationship with global wealth had fundamentally shifted. For over a century, the non-dom rules allowed internationally mobile individuals to limit their UK tax exposure; that framework has now gone.
The New Residence-Based Reality
The UK now taxes residents on a worldwide basis. The moment you become UK resident, your global income and gains are subject to UK tax, and after a certain period, your worldwide assets may also be liable for inheritance tax.
This shift does not just affect the ultra-wealthy; it affects anyone with assets abroad, property back home, or business interests overseas. Transitional measures exist, but they are temporary.
Why Your Will Matters More Now
In the non-dom era, estate planning often relied on trusts, offshore structures, or the remittance basis to manage exposure. Today, those tools are more limited. That makes the Will more than a formality but a central tool in making sure your wealth is passed on according to your wishes.
The Three Essential Functions of a Will Today
In the post-non-dom UK, a Will does three things:
- It defines the narrative of your estate in a way the law cannot: who inherits what, in which jurisdiction, and under what conditions.
- It gives your executors the framework to navigate cross-border probate and the complexities of conflicting inheritance laws.
- Perhaps most importantly, it allows you to respond directly to the new tax environment, such as structuring bequests, timing disposals, and integrating reliefs so that value passes as intended, not as dictated by the blunt force of intestacy rules.
The reality is that HMRC now has a much broader claim on the wealth of UK residents. Without a Will, that claim will be exercised with maximum inefficiency and minimum alignment to personal wishes. The state decides how your estate is divided, often in ways that are inefficient and misaligned with your wishes.
We are entering a period where private wealth structuring will need to be far more deliberate. Those with international ties will have to think globally but act locally, drafting Wills that respect multiple legal systems, anticipating not just the tax burden but the human dynamics of succession. In this context, the Will is no longer the final step in managing your affairs; it is the foundation.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
