The remittance basis ended on 6 April 2025. Seventeen months on, nobody can say with authority how many wealthy people left because of it, while every rule that decides a client’s position is fixed and dated. The most quoted number, Henley & Partners’ forecast that the UK would lose 16,500 millionaires in 2025, was challenged in a forensic review by Tax Policy Associates, and in June 2026 Henley’s own new report published no migration figures at all. HMRC’s statistics of 30 July 2026 describe the last tax year before the reform, and the government has said, as Business Matters reported, that accurate estimates of how many people have left will not be available until 2027.
The dates are precise: four years of relief for new arrivals, an inheritance tax test of 10 years in 20 with a tail of three to ten years, and a 12 percent repatriation rate that expires on 5 April 2027. An adviser who repeats the exodus figure borrows a forecast its own publisher did not repeat in 2026. An adviser who publishes the calendar, client type by client type, and counts each client’s own years of residence, is selling something a family can act on this tax year.
A forecast its publisher did not repeat
Henley & Partners’ press release of 24 June 2025 said the UK was “forecast to lose” 16,500 millionaires in 2025, in a report produced with the wealth intelligence firm New World Wealth. Tax Policy Associates notes that the series has been “widely cited by politicians and newspapers across the political spectrum.”
On 27 July 2025 Tax Policy Associates published a statistical and forensic review of that series, and its findings are specific. In its words: “The report dropped all property wealth between 2023 and 2025, yet its millionaire counts barely moved.” The trailing digits of the centimillionaire counts cluster on 0 and 5 with almost no 1s, a pattern it puts at about one in 240,000 by chance. Against official data, it found UK millionaires overstated by almost 100 percent and UK centimillionaires understated by around 70 percent. Its conclusion: “Until an independent audit is carried out, the Wealth Migration Report should be treated as marketing material, not evidence.” In fairness to the publisher, the same review records that Henley & Partners said New World Wealth does not share the details of its methodology with them, and accepts that if there was fabrication, Henley was unaware of it.
Then the series changed. Henley’s 2026 report, released on 16 June 2026, replaced the headcount with a “Global Wealth Mobility Framework” and a score out of 100. The UK scored 68.3 and sits among the “Competitive Jurisdictions Under Pressure.” The methodology is explicit: “The framework does not seek to measure actual millionaire inflows or outflows, nor does it provide future migration forecasts.” Henley adds that the change does not preclude millionaire migration estimates in future editions. Tax Policy Associates’ update of the same date says Henley has dropped New World Wealth.
An adviser who still cites 16,500 is citing a one-year forecast, from a series whose method was publicly challenged, that its publisher did not repeat in its 2026 report. Clients who read the financial press may well know this. Repeating the number spends the adviser’s credibility on someone else’s estimate.
What HMRC’s July 2026 figures can carry
HMRC’s statistics, updated on 30 July 2026, count at least 81,900 non-domiciled and deemed domiciled taxpayers in 2024-25, down 1 percent from 83,100 the year before. Their combined tax and National Insurance liabilities were £13.6 billion, up 9 percent. The underlying table puts that at £13,592 million, the highest total in a series that starts at £10,406 million in 2018-19. The 2024-25 figures are marked provisional.
The commentary also reports flows. Around 9,000 taxpayers flowed out of the non-domiciled population in 2024-25, fewer than the 11,200 of the previous year, and around 8,600 new arrivals came in, down from 10,000. Two cautions apply before anyone calls that an exodus, or the absence of one. The population is defined by a claim of non-domiciled status on a Self Assessment return, so leaving it is not the same as leaving the country. And HMRC says plainly that “this release is for tax year ending 2025 which occurred prior to these policy changes being implemented.”
The post-reform count does not exist yet. HMRC calls this release “the final publication in its current form”, and the detailed breakdowns for 2024-25 it held back will come in “a final update to this publication series”, due in 2027. Business Matters, reporting the release on 4 August 2026, wrote: “The government has said accurate estimates of how many people have left since the regime changed will not be available until next year.” Even the Treasury’s costing of the reform, published with the Autumn Budget in October 2024, “accounts for behavioural responses including migration” and names the behavioral response among “the main uncertainties.”
The honest answer to “how many left?” is a date: 2027. It fits in one sentence, and it is true.
The calendar is fixed, and it is the product
Here are the rules as HMRC and the Treasury have published them.
New arrivals. A person who becomes UK tax resident after at least 10 consecutive tax years of non-residence can claim relief on foreign income and gains for their first four tax years of residence. The claim is made on the Self Assessment return and costs the income tax and capital gains tax allowances for each year claimed (HMRC guidance, 6 April 2025). Employees eligible for the regime may also be able to claim Overseas Workday Relief, capped each year at the lower of 30 percent of qualifying employment income or £300,000 (HMRC manual EIM43600).
Inheritance tax. Since 6 April 2025, non-UK assets are in scope for anyone resident for 10 of the previous 20 tax years. After departure the exposure continues for three tax years for someone resident 10 to 13 years, rising by one year for each further year of residence, up to ten (HMRC, “Inheritance Tax if you’re a long-term UK resident”; Technical Note, paragraph 164). Ten consecutive years of non-residence reset the test.
Repatriation and rebasing. Former remittance-basis users who are UK resident can designate foreign income and gains that arose before 6 April 2025 under the Temporary Repatriation Facility, at 12 percent for 2025-26 and 2026-27 and 15 percent for 2027-28 (HMRC manual RDRM73340). Once the charge is paid, the money can be brought in during a later year (Technical Note, paragraph 15). Current and past remittance-basis users can also rebase personally held foreign assets to 5 April 2017 on a disposal, where conditions are met (paragraph 12).
01 / 06
Former remittance-basis user, still UK resident, with unremitted pre-2025 foreign income or gains
Rule that governs
Temporary Repatriation Facility: 12% for 2025-26 and 2026-27, 15% for 2027-28, UK residence required
Date that belongs in the file
5 April 2027 ends the 12% rate; 5 April 2028 ends the facility
02 / 06
Arrival after 10 or more consecutive non-resident tax years
Rule that governs
Four-year foreign income and gains regime, claimed year by year
Date that belongs in the file
End of the fourth tax year of residence
03 / 06
Resident 10 or more of the last 20 years, planning to leave
Rule that governs
Inheritance tax tail of 3 to 10 tax years, set by years of residence
Date that belongs in the file
Departure plus the tail (15 years resident: 5 years)
04 / 06
Deemed domiciled on 30 October 2024, non-resident in 2025-26, not returning
Rule that governs
Transitional rule: long-term residence ends after 3 years of non-residence
Date that belongs in the file
Third year of non-residence
05 / 06
Past remittance-basis user selling foreign assets held personally
Rule that governs
Capital gains rebasing to 5 April 2017, where conditions are met
Date that belongs in the file
The disposal date
06 / 06
Former resident weighing a return
Rule that governs
Inheritance tax test and four-year regime both turn on 10 consecutive non-resident years
Date that belongs in the file
Tenth consecutive tax year abroad
| Client type | Rule that governs | Date that belongs in the file |
|---|---|---|
| Former remittance-basis user, still UK resident, with unremitted pre-2025 foreign income or gains | Temporary Repatriation Facility: 12% for 2025-26 and 2026-27, 15% for 2027-28, UK residence required | 5 April 2027 ends the 12% rate; 5 April 2028 ends the facility |
| Arrival after 10 or more consecutive non-resident tax years | Four-year foreign income and gains regime, claimed year by year | End of the fourth tax year of residence |
| Resident 10 or more of the last 20 years, planning to leave | Inheritance tax tail of 3 to 10 tax years, set by years of residence | Departure plus the tail (15 years resident: 5 years) |
| Deemed domiciled on 30 October 2024, non-resident in 2025-26, not returning | Transitional rule: long-term residence ends after 3 years of non-residence | Third year of non-residence |
| Past remittance-basis user selling foreign assets held personally | Capital gains rebasing to 5 April 2017, where conditions are met | The disposal date |
| Former resident weighing a return | Inheritance tax test and four-year regime both turn on 10 consecutive non-resident years | Tenth consecutive tax year abroad |
Sources: HMRC guidance and manuals cited above; HM Treasury and HMRC Technical Note, 30 October 2024. The 5 April dates are the ends of the UK tax years concerned.
Every row is a date a client can plan around, and none of them depends on how many other people left. The rows also interact. The repatriation facility is available only in a year of UK residence (Technical Note, paragraph 13), so a client who wants the 12 percent rate before leaving is working to 5 April 2027, and the inheritance tax tail starts counting from the departure that follows.
Known and unknown, as of September 2026
- Known: the rules, in force since 6 April 2025, each tied to a count of the client’s own tax years.
- Not known: how many people left after the reform. The government has said accurate estimates will not be available until 2027.
- Closing first: the 12 percent repatriation rate, on 5 April 2027.
Count the client’s years, not the country’s leavers
Every rule above runs on one input: the number of tax years this person was UK resident. That count is where the advice lives, and it is harder than it looks.
Residence for inheritance tax follows the income tax and capital gains tax position, which means the Statutory Residence Test from 2013-14 and the older rules before it. A split year counts as a full year of UK residence for inheritance tax (Technical Note, paragraph 168), and a split year inside the four-year window counts as a full year of that window (paragraph 30). For anyone aged 20 or younger, the inheritance tax test is different: whether they were UK resident for at least 50 percent of the tax years since birth (paragraph 169). A family that arrived together can therefore become long-term resident at different times.
So the first meeting should open with a residence history, not a destination. Twenty tax years, each marked resident, non-resident or split, with the evidence for each. The dates in the table fall out of that ledger: when the client crosses 10 years in 20, how long a tail a departure this year would carry compared with next year, whether a planned return would reset the clock. A client at nine years of residence faces a threshold that matters far more to them than any national headcount. A client resident 14 of the last 20 years who leaves now carries a four-year tail, and one more resident year can make it five.
Every row is a date a client can plan around, and none of them depends on how many other people left.
This dossier describes published rules and statistics. It is not tax, legal or investment advice, and each rule carries conditions that decide whether it applies to a given family.
The same discipline belongs in what a firm publishes. Every figure carries its date and its source, and a figure that cannot survive that treatment stays out. The strongest piece of content an adviser can put out this year is a decision timeline for a named client type, with its dates, plus one line saying what is not yet known and when it will be.
