Expert Tax Insights: Peter Ferrigno Analyzes the UK’s 2025 Tax Regime Shift
The UK’s 2025 tax reforms for non-domiciled individuals have sparked global concern, particularly among high-net-worth individuals (HNWIs) and ultra-high-net-worth individuals (UHNWIs). During the Hubbis Digital Dialogue on April 24, 2025, Peter Ferrigno, Director of Tax Services at Henley & Partners, delivered a comprehensive technical analysis of the UK’s foreign income and gains (FIG) tax regime, the overhaul of inheritance tax for non-doms, and the absence of a robust investment migration strategy.
With more than 25 years in international tax structuring, residency planning, and cross-border wealth management, Ferrigno labeled the reforms as “deeply flawed,” warning of unintended tax consequences for globally mobile families.
The UK Four-Year Foreign Income and Gains (FIG) Regime: A Short-Term Solution with Long-Term Costs
One of the headline features of the UK’s non-dom tax reform 2025 is the new four-year FIG exemption for new residents. This policy allows tax-free treatment of foreign income and gains for up to four years.
However, Ferrigno called the scheme “misleading” for globally mobile entrepreneurs. “Four years is too short for families establishing roots in the UK—by the time they settle, full UK worldwide tax obligations kick in,” he said.
Key issues include:
- Mandatory global income declaration despite temporary exemptions
- Exclusion of certain assets like life insurance gains
- High compliance costs and administrative complexity
Ferrigno emphasized that the UK’s complex tax reporting and lack of clarity would likely deter international business families from relocating
Lack of Incentives for Global Investors: A Missed Strategic Opportunity
Unlike Italy’s flat tax program for new residents or Switzerland’s lump-sum taxation, the UK has abolished the remittance basis without offering meaningful tax incentives. Ferrigno pointed out that the absence of a replacement investor-friendly visa—following the termination of the UK Investor Visa—is a significant misstep.
“The UK scrapped a viable system without designing a new one. They’re eliminating global wealth incentives while offering no real path for investors to contribute economically,” Ferrigno said.
This lack of a holistic UK tax and immigration strategy places the country at a competitive disadvantage for attracting international wealth and business relocation.
Inheritance Tax (IHT) in the UK: The Hidden Danger for Expat Families
Ferrigno referred to the revised UK inheritance tax rules for non-doms as the “silent killer.” Under the new residence-based IHT model, individuals residing in the UK for over 10 years will face a 40% IHT rate on worldwide assets—regardless of where those assets are held.
Key IHT Triggers:
- A 10-year IHT exposure after UK residency
- Up to 10 years of tax liability even after leaving the UK
- Lack of IHT treaties with many countries, creating double taxation risks
“Most families are unaware of the long-term IHT consequences. Without strategic estate planning, they risk losing generational wealth,” he warned.
Strategic Tax Relocation and Estate Planning: A Must for Global Families
Ferrigno concluded that families can no longer rely on outdated structures or assume static tax rules. The era of proactive cross-border tax planning is here. He stressed the importance of jurisdictions that offer:
- Legal certainty
- Tax-efficient structures
- Investor residency programs
Essential Tax Planning Considerations for HNWIs:
- Early-stage relocation planning
- Use of international trusts and holding structures
- Coordinated advice on multi-jurisdictional tax exposure
“Tax homes need to be adaptable. Advisors who provide real cross-border expertise will thrive; others will fall behind,” Ferrigno warned.
Final Thoughts: UK Risks Losing Global Wealth and Entrepreneurial Talent
Ferrigno’s analysis sends a clear message: the UK’s non-dom tax reforms 2025 may drive away the very entrepreneurs and investors who fuel economic growth. Without smart tax incentives, simplified compliance, and a renewed investor pathway, the UK risks undermining its long-standing reputation as a prime destination for international families.
