In the UK, Prime Minister Keir Starmer’s Labour government is planning to abolish the non-dom regime. In France, the left-wing alliance (Nouveau Front Populaire) – following its (relative) victory in the French parliamantary elections – is also intending to subject HNWI to higher (income and inheritance) taxes.

The new tax landscape in France and the UK is however still unclear. Macron should appoint a Prime minister mid-August. In the UK, the new government’s budget may be delivered as early as mid-September. That Budget will hopefully bring further clarity as to what the fine detail of the proposed changes to the non-dom regime will look like. It is not impossible that the new Government in the UK may seek to enact retroactive tax measures against non-doms. In the same vain, French tax experts have warned for the potential retroactive effect of new tax rules in France (e.g., the abolition of the flat tax).

In her excellent article published in Bloomberg, Tara Patel describes the pros and cons of various top destinations for rich Brits and French, e.g. Belgium, Monaco, Switzerland (e.g. in the German speaking areas Schwyz and Zug), Singapour, Abu Dhabi and Dubai in the UAE, the US (Florida), etc.

I had the honour of being quoted with respect to the tax incentives that Belgium can offer to wealthy French individuals: “Belgium is a mini tax haven for high-net-worth individuals,” said Denis-Emmanuel Philippe, a Brussels-based co- founder and partner at Bloom law firm. I added that the country retains its allure partly because of the exemption of capital gains on shares, the absence of a wealth tax other than a levy on securities accounts, the large array of estate planning schemes leading to low gift and inheritance taxes, etc. One could add the possibility to subscribe to low-taxed financial (e.g., shares in equity funds of the capitalisation type) and insurance products (e.g., unit linked -class 23- insurance products), low income tax on rental income, the possibility to realise tax-free capital gains upon disposal of real estate, etc.

A relocation may not be improvised. A lot of tax and non-tax issues need to be considered. And it is ill-advised to move to Belgium (or any other country) without intention / desire to live there with one’s toothbrush, slippers and pipe😉!

Denis-Emmanuel Philippe