UK Non-Dom Reform and Swiss Relocation Alternatives

Executive Summary

The reform of the UK non-dom regime has changed the planning landscape for internationally mobile individuals, families and entrepreneurs with foreign income, foreign gains or international wealth structures.

From a Swiss perspective, the key question is not whether Switzerland is a generic alternative to the United Kingdom, but whether a relocation to Switzerland is coherent with the individual’s residence position, family situation, wealth structure, source of income, immigration status and long-term objectives.

Why It Matters

Internationally mobile individuals should not assess relocation only through headline tax rates or special regimes. A move from or to the United Kingdom may require a structured review of:

• UK residence status under the Statutory Residence Test;
• pre- and post-6 April 2025 foreign income and gains;
• transitional rules and historical unremitted income or gains;
• family location and centre of life;
• existing companies, trusts or investment structures;
• Swiss residence permits and immigration position;
• ordinary Swiss taxation or possible taxation according to expenditure;
• banking, reporting and compliance implications.

Key Legal and Practical Points

• The UK non-dom reform introduced a residence-based approach for new foreign income and gains relief.
• The UK Statutory Residence Test remains central when assessing whether an individual is UK resident for a tax year.
• Switzerland should be assessed through a coordinated immigration, tax and compliance review before any relocation step is taken.
• Swiss taxation according to expenditure may be relevant for certain foreign individuals who become resident in Switzerland and do not exercise gainful activity in Switzerland, subject to federal and cantonal requirements.
• Existing trusts, companies, investment portfolios and real estate holdings should be reviewed before relocation.
• A relocation strategy should align tax position, documentary evidence, banking profile and family facts.

TCC Perspective

For private clients considering Switzerland after the UK non-dom reform, the correct starting point is a structured relocation profile rather than an isolated comparison of regimes.

A preliminary TCC review should normally cover:

1. 01current and expected residence status
2. 02family and lifestyle relocation facts
3. 03source and timing of foreign income and gains
4. 04trusts, companies, investment structures and real estate
5. 05Swiss immigration pathway
6. 06Swiss ordinary taxation versus possible special regimes
7. 07banking, fiduciary and compliance implications
8. 08documentation and timing before implementation