The Move

Sir Jim Ratcliffe, founder of the Ineos petrochemicals empire, formerly relocated from the UK to Monaco reportedly around 2019-2020. Various reports estimated the annual UK tax saving at £4 billion+ every year over multiple years; potentially more in light of his global business empire and the 2025 non-dom reforms (essentially meaning UK residents now pay normal UK tax on all global business interests outside the UK).

Ratcliffe’s move used standard UK Statutory Residence Test (SRT) mechanics:

1. Meeting automatic non-residence tests

2. Genuine severance of UK ties (though he retains substantial UK business interests)

3. Managing “sufficient ties” tests carefully

4. Physical presence appropriate to non-resident claim

The Post-2025 UK Context

Ratcliffe’s move preceded the 2025 non-dom reform. Pre-2025, wealthy non-doms could remain UK-resident while claiming remittance basis on foreign income. Post-2025, that regime is largely gone.

Result: many more UK High Net Worth families and individuals now consider emigration outright rather than non-dom claims, and the UK’s largest ever exodus of millionaires is well underway.

Common destinations in 2026:

• Monaco (like Ratcliffe) if they’re ultra high net worth (Monaco is very expensive);

• UAE (Dubai particularly)

• Caribbean destinations (Panama, BVIs, Caymans, etc.)

• Switzerland (lump-sum in favourable cantons)

• Italy (€100K flat-tax)

• Portugal (though NHR reform reduced appeal)

• Greece (€100K non-dom regime)

• Cyprus, Malta (non-dom + EU access)

The Statutory Residence Test Reality

UK non-residence under SRT requires satisfying either:

• Automatic non-residence (varies by circumstances), OR

• No automatic residence AND insufficient UK ties

For someone with substantial UK business interests (like Ratcliffe with Ineos), managing “work ties” and “family ties” is complex.

Genuine, defensible non-residence requires:

1. Not spending too many days in UK

2. Not having UK employment/self-employment above thresholds

3. Not having dependant family (spouse, children, etc.) UK-based - note that non-dependants such as adult children living independently, extended family, etc. aren’t generally included in this

4. Not having available UK accommodation used substantially (i.e. not maintaining a permanent place of residence for visits - you’d need to either sell or lease out the family home)

The Modern Playbook

For wealthy Brits considering emigration in 2026:

1. Choose destination first (fit for lifestyle + tax)

2. Structure UK exit properly under SRT

3. Consider split-year treatment for transition year

4. Manage temporary non-residence rules (5-year sticky period for certain income)

5. Address inheritance tax positioning (UK deemed domicile can persist)

6. Coordinate with destination-country tax setup

The Not-Yet-Left Alternatives

For wealthy Brits not ready to emigrate, consider:

• FIG regime (4-year exemption for genuinely new UK residents - narrow applicability)

• Trust and gifting strategies (post-2025 rules)

• Charitable structuring

• Business Property Relief planning

• Offshore structuring for overseas or location independent (i.e. virtual services/online sales) income sources