Official Statistics

Statistical commentary on non-domiciled taxpayers in the UK

Updated 17 July 2025

1.   Summary of key statistics for tax year 2023 to 2024

Key findings from this year’s publication are:

• the combined tax and National Insurance Contributions (NICs) liabilities for all non-domiciled and deemed domiciled taxpayers in tax year ending 2024 was £12 billion, a 2% increase on tax year ending 2023, around three-quarters of liabilities are for Income Tax

• we estimate a combined total of at least 83,000 non-domiciled and deemed domiciled taxpayers as indicated in Self Assessment tax returns in the year ending 2024, with the overwhelming majority being non-domiciles, this represents a marginal decline (1%) from 83,900 taxpayers in the previous year

• this net change of around 900 taxpayers reflects flows of around 9,100 newly arrived non-domiciled taxpayers (down 5,100 year-on-year), offset by 9,500 individuals no longer indicating non-domiciled status through Self Assessment (compared with 9,800 in 2023) and around 500 fewer deemed domiciles

• the number of new arrivals in year ending 2023 exceeded those pre-pandemic (in tax year ending 2020) by 25%, so this part-slowing of inflows this year may be a levelling off from that sharp post-pandemic recovery

2.   About this release

This publication is the annual update of statistics on individuals who were non-domiciled or deemed domiciled for tax purposes. From 6 April 2025 the remittance basis of taxation, which is based on domicile status, was replaced with a new tax regime based on residence; this release is for tax year ending 2024 which occurred prior to these policy changes. The statistics for tax year ending 2025 will be published in 2026 and will be the final publication in its current form.

To qualify as a non-domiciled taxpayer in the years covered by this publication, an individual must have had their permanent home, their ‘domicile’, outside the UK. They must also have claimed non-domiciled status in the UK for tax purposes on their UK Self Assessment tax returns. Deemed domiciles are formerly non-domiciled taxpayers indicating on their UK Self Assessment tax returns that they are now treated as domiciled in the UK for the purposes of Income and Capital Gains Tax (CGT). This is following the 2017 change to end permanent non-domiciled taxpayer status in the UK for two groups:

  1. non-domiciles who were either born in the UK and UK resident since tax year ending 2018 (Condition A), or

  2. UK resident for at least 15 of the 20 tax years immediately before the relevant tax year (Condition B).

This means it is important to consider both non-domiciles and deemed domiciles together when looking at trends over time.

Figures for tax years ending 2022, 2023 and 2024 are provisional (subject to future updates). All other figures are final (they will not be further updated).

Data for the tax year ending 2024 are included for figures and tables 1 to 4 and table 13, data for the three most recent tax years published may be revised in the future. From figure 5 and for tables 5 to 12, data will only be included up to tax year 2023. Further breakdown of the figures for the current year are not included as the source data is not considered reliable (particularly where two successive years’ data points are close together) and will be included in next year’s publication when the data is more settled.

From 6 April 2020, individuals, trustees and personal representatives of deceased persons who sell or otherwise dispose of UK residential property where CGT is due on all or part of the gain have had to report the disposal to HMRC within 30 days of completing the disposal. At the same time they must make a payment on account of the CGT due. These statistics also include tax liabilities reported using the new CGT on UK property service for tax year ending 2021 onwards. We have found that the inclusion of this data increases annual tax liabilities by less than £10 million per tax year.

The historic data and tables remain available in the Government Web Archive.

3. Non-domiciled and deemed domicile taxpayers and taxes combined

Figure 1: Aggregated numbers and liabilities for both non-domiciled and deemed domicile taxpayers

The combined tax and NICs liabilities for all non-domiciled and deemed domiciled taxpayers in tax year ending 2024 was £12.5 billion, a 2% increase on tax year ending 2023, as outlined in Figure 1.

We estimate a combined total of at least 83,000 non-domiciled and deemed domiciled taxpayers as indicated in Self Assessment tax returns in the year ending 2024. This represents a marginal decline (1%) from 83,900 taxpayers in the previous year, returning to but not yet reaching pre-pandemic levels. This net change of around 900 reflects around 9,100 newly arrived non-domiciled taxpayers (down 5,100 year-on-year), offset by 9,500 individuals no longer indicating non-domiciled status through Self Assessment (compared with 9,800 in 2023), alongside 500 fewer deemed domiciles.

At around £9.0 billion, the Income Tax revenue from non-domiciled taxpayers is £531 million (or 6%) higher than in tax year ending 2023 and is at its highest level since tax year ending 2017. This is partially offset by a reduction of £175 million (6%) in NICs and a £133 million (14%) reduction in CGT.

Noting that it is important to combine the populations of non-domicile and deemed domicile taxpayers to get the complete picture, we now turn to the separate populations in more detail.

4. Non-domiciled taxpayers and taxes

Figure 2: Non-domiciled taxpayer numbers, Income Tax, CGT and NICs

Figure 2 looks at non-domiciled taxpayers  — around three-quarters of the combined population — we estimate that there were 73,700 individuals claiming non-domiciled taxpayer status in the UK in the tax year ending 2024, down 400 year-on-year (or 0.5%). This follows steady year-on-year increases from the tax year ending 2021 to tax year ending 2023, partly driven by a recovery in new arrivals numbers and higher retention rates. The number of non-domiciled taxpayers in tax year ending 2024 stands 3,900 below that in tax year ending 2020.

In the tax year ending 2024, the amount of UK Income Tax, CGT and NICs liable by all non-domiciled taxpayers was £9.0 billion, as shown in Figure 2. Despite the small decrease in the number of non-domiciled taxpayers since tax year ending 2023, the total amount of tax and NICs liabilities has increased by £107 million.

That £107 million year-on-year rise reflects Income Tax paid being up by around 4% (to its highest level since 2017) partly offset by lower NICs (down around 5%) and lower CGT liabilities (down around 3%).

Figure 3: Number of non-domiciled taxpayers who have arrived into the UK in the previous five tax years

In the tax year ending 2024, there were around 9,100 newly arrived non-domiciled taxpayers (down 5,100 year-on-year), offset by 9,500 individuals no longer indicating non-domiciled status through Self Assessment (compared with 9,800 in 2023) as outlined in Figure 3 (and Table 13).

The number of new arrivals in year ending 2023 exceeded pre-pandemic new arrivals in tax year ending 2020 by 25%, so this part-slowing of inflows may be a levelling off following that sharp post-pandemic recovery.

The majority of non-domiciled taxpayers in the tax year ending 2024 indicated UK residence as in previous years.

5. Deemed domicile reforms

Figure 4: Deemed domiciled taxpayer numbers, Income Tax, CGT and NICs

Figure 4 shows 9,300 individuals indicated deemed domiciled taxpayer status in the UK on their Self Assessment tax returns in the tax year ending 2024. This is a reduction of around 500 year-on-year following a smaller drop of around 100 in tax year ending 2022.

In the tax year ending 2024, deemed domiciles paid £3.5 billion of UK Income Tax, CGT and NICs on worldwide income and liable gains. This is an increase from last year’s estimate of £3.4 billion. While Income Tax receipts increased from 2023, NICs and CGT both fell.

6. Non-domiciled UK resident taxpayers, remittance basis and arising basis

Figure 5: Number of non-domiciled UK residents claiming the remittance basis or the arising basis of taxation

The vast majority of non-domiciled taxpayers are UK-resident. As outlined in Figure 5 for the tax year ending 2023, the number of UK-resident non-domiciled taxpayers increased from 56,000 to 60,800. This may be a continued recovery from COVID-19 pandemic travel restrictions.

The UK-resident non-domiciled group is taxed on two bases: a remittance basis or an arising basis. Individuals who are UK-resident are normally taxed on the arising basis of taxation, where all of an individual’s worldwide income and gains are taxable in the UK as they arise. Prior to the current tax year ending 2026, some non-domiciled taxpayers who were UK-resident could choose to be taxed on the remittance basis, meaning that any foreign income and gains will only be taxed if they are brought, or remitted, into the UK, even if that remittance occurs in a later tax year. For non-domiciled taxpayers who opt to be taxed on the remittance basis, any foreign income and gains that are not remitted to the UK are not subject to UK tax.

The number of non-domiciled taxpayers on the remittance basis was broadly stable from tax years ending 2019 to 2020 but dropped in tax year ending 2021 before recovering by 2023. This likely reflects the end of COVID-19 travel restrictions hitting then unwinding, though not yet returning to pre-pandemic levels. In tax year ending 2023 there were 42,300 non-domiciled taxpayers on the remittance basis (up 11% year-on-year) liable for a total of £7 billion in taxes and NICs (up 8% year-on-year) (Figure 5).

The number of non-domiciled taxpayers on the arising basis has been broadly stable since 2019. In tax year ending 2022 there were 17,900 non-domiciled taxpayers on the arising basis liable for a total of £1.9 billion in taxes and NICs, compared to 18,500 non-domiciled taxpayers on the arising basis liable (up 3% year-on-year) for a total of £1.8 billion in taxes and NICs in tax year ending 2023 (down 7% year-on-year) (Table 6).

7. Remittance basis and the remittance basis charge

The number of non-domiciled taxpayers paying on the remittance basis was 42,300 in the tax year ending 2023. We expect to revise this in future years due to a small number of late filers.

Figure 6 shows an increase of around 4,100 in the number of remittance basis claimants in tax year ending 2023. The number of those paying the remittance basis charge (RBC), the number of those on the remittance basis who have less than £2,000 of unremitted overseas income, and the number those on the remittance basis but not paying the RBC due to residence period have all increased.

Table 7 shows that only a minority of the taxpayers who are using the remittance basis are liable to pay the RBC. This is because the RBC is only levied when a remittance basis user has been UK-resident for at least 7 of the previous 9 tax years immediately before the relevant tax year. It is also not payable where a taxpayer using the remittance basis has less than £2,000 of unremitted non-UK income or gains. We have provided a breakdown for this group in Table 8.

7.1 Remittance basis claimants and taxes

Figure 6: Number of non-domiciled UK resident taxpayers taxed on the remittance basis and their Income Tax, CGT and NICs

Non-domiciled taxpayers on the remittance basis in the tax year ending 2023 are liable to pay £7 billion in Income Tax, CGT and NICs as outlined in Figure 6 (and Table 5). This is an increase from tax year ending 2022 of £524 million and £618 million above the pre-pandemic level of tax year ending 2020. A large majority of this increase can be explained by the sub-group population of non-domiciled taxpayers who are on the remittance basis but do not pay the remittance basis charge due to their period of residence. By comparison, the increases in tax and NICs paid by those paying the remittance basis charge and those on the remittance basis with less than £2,000 of unremitted income were relatively small.

As set out above, higher tax and NICs liabilities from deemed domiciled taxpayers more than offset the decrease in remittance basis user liabilities that followed the tax year ending 2017.

8. Remittance basis charge revenue

Figure 7: Non-domiciled UK resident taxpayers liable to pay the remittance basis charge and UK Income Tax, CGT, NICs and remittance basis charge revenue

Figure 7 shows the number of taxpayers who were liable to pay the RBC rose from 1,800 in the tax year ending 2018 to 2,600 in the tax year ending 2023. The total amount to be paid by taxpayers in Income Tax, CGT, NICs and the RBC also rose from £838 million from those who were liable to pay the RBC in the tax year ending 2018 to £1.4 billion in the tax year ending 2023.

The accompanying background quality report provides more details on the remittance basis charge and deemed domicile changes.

9. Non-domiciled taxpayers by region

9.1 Regional observations

London continued to have the largest non-domiciled taxpayer population in the tax year ending 2023, with 58% of non-domiciled taxpayers in the UK located in that region and 74% of non-domiciled UK Income Tax, CGT and NICs coming from that region (Table 11). London also had the largest population of UK-resident non-domiciled taxpayers.

10. Business Investment Relief (BIR) in the UK

Figure 8: Value of BIR and number of claimants

Figure 8 shows that in the tax year ending 2023, the cumulative value of investments in UK businesses on which BIR has been claimed is £9.2 billion. In the tax year ending 2023, £971 million was invested in the UK from 400 taxpayers which is down by around £189 million from the previous year.