The hopes and fears driving global mobility in 2025

The fund manager being headhunted for an opportunity overseas. The non-domiciled resident affected by an unfavourable new tax regime. The devoted parents moving abroad to further their children’s education. The A-lister feeling disillusioned with their home country after a change of political direction. A multitude of hopes and fears are driving wealthy, successful and prominent people to reconsider their country of residence in 2025, and as the only global law firm with a focus on private capital, Withers’ teams are busy helping them to explore their options and arrange their affairs for a move.

Beyond the headlines

Reflecting on their conversations across three continents, the lawyers report a far more nuanced picture than that presented by newspaper headlines. 'One trend we’ve seen is an increasing number of Americans taking up C-suite positions in the UK,' says James Hockin, a partner in the London employment team who is dual qualified in New York and England & Wales.

The influx of Americans could be read as a response to the November US election, but James reports the phenomenon began some time beforehand. 'Actually, we think people are being brought over for their expertise, particularly in relation to hedge funds and private equity. Larger firms doing spinouts want specialists to come in and they are very focused on Americans.'

Meanwhile in New York, immigration partner Theda Fisher has been busy finalising paperwork for people who were anxious about the new administration’s anti-immigrant stance. However, says Theda, 'This is still very much the land of opportunity, and I don’t think that will change'.

There are certainly Americans who are seeking second passports as an insurance policy; Theda is currently helping one couple to ride out the political cycle on a yacht, without jeopardising the European partner’s US green card. 'But it’s more of an inflow than an outflow – partly driven by changes to the UK non-dom rules, and partly because of turmoil in Europe and the Middle East.'

Another factor driving a huge uptick in so-called EB5 cases (in which a foreign national obtains a green card by investing in a US commercial enterprise) is a trend for European students to remain after graduating from an American university. 'Previously, families wanted to go home after graduating, but now clients seem to feel there are more jobs here, more opportunities here in tech, more investment flowing if they want to start up a company.'

Typically, US-educated Generation Z clients already understand that they lack the experience to make the case for an employment-based visa, and arrive at Withers’ offices determined to pursue an investment visa. Theda notes that one recent graduate persuaded her middle-class parents to remortgage their home to help her meet the requirements, while another renounced her inheritance, intending to make her own way as a US citizen. 'We advise on what’s involved, including the tax consequences and the risk of losing their investment, but the younger generation are not incredibly concerned about preserving wealth for the long term; it’s more important to them to live in a place where they can see themselves growing professionally and personally.'

Considering options

One group of people who are keenly interested in tax rates are the tens of thousands of non-domiciled residents of the UK, whose status has been a hot topic since the Labour government’s first Budget in October 2024. Inheritance tax, in particular, has been a major concern, with some suggestions that the UK will tax estates of long-term residents up to ten years after the deceased left the country.

While the details are still being discussed, many long-term residents are reconsidering their options, says Mara Monte, a private client and tax partner based in the UK and frequently working with non-dom clients from across Europe: 'People are not necessarily against paying tax and supporting social systems, but there is a general aversion to paying 40% on what they’ve saved over their life.'

In addition to the changes to the new-dom regime, major reforms suggested to some long-standing reliefs such as business property relief has also prompted Brits with international businesses to consider whether they want to remain in the UK for the longer term. Brexit has significantly complicated things from an immigration perspective, though, making a move to another European country more expensive.

With 17 offices around the world, Withers is well placed to suggest more favourable regimes, or whether a tax treaty is in place with their home country that means UK inheritance tax may not apply. 'Clients are often keen to remain within Europe, and we can advise on different options, like Monaco, Italy or Greece, which has recently introduced a very attractive regime, based on the slightly older Italian flat tax regime, that is a simplified version of the UK’s remittance basis of taxation,' says Mara. Switzerland used to be high on European clients’ lists, however the prospect of a people’s referendum expected to take place in 2026 on the taxation of large estates has created uncertainty for the time being.

 Meanwhile in Asia, many clients are facing a similar dilemma since Singapore – once the go-to for families looking to diversify their assets within the continent – changed its rules to be less hospitable to foreigners. 'Even if you have an employment pass or work visa, it’s really difficult in terms of converting that to citizenship, so some wealthy families have come to Hong Kong instead,' explains Laurence Ho, a partner in the Hong Kong office whose practice covers international tax, trust and estate planning.

Those building a base further afield are looking for legal stability, security and a strong education system, says Laurence. 'Right now, we’re seeing huge interest in Australia, along with Canada, the US, and the UK. The Middle East is also popular and very recently, we’ve had three or four ultra high net worth clients tell us they are moving to Japan. It seems like it’s easy to get a work or investment visa; it’s close by, essentially in the same time zone; and it’s seen as secure.'

Balancing priorities 

As Laurence notes, however attractive a country may seem on paper, it’s important that it is a good fit in practice. The new location needs to feel like home for the whole family, which can bring a much broader range of cultural and practical factors into play, whether it’s the workplace or the weather.

 James’s team can help US executives to understand key differences in how the UK operates, from healthcare to financial regulations. 'On the regulatory front, the UK market is very heavily regulated and a lot of people come here and are asked to sign a contract that says they’re fully aware of the FCA framework. I tell them, ‘Have a chat for an hour with one of my regulatory colleagues’, because the rules are quite different from the US, and if you breach them, you’re not just going to lose your job – you’ll be unemployable in the UK market.'

 Feeling accepted is also important. For example, Laurence Ho reports that some of Withers’ Chinese clients have discovered a limit to the opportunities they can access in Silicon Valley. 'Almost all the people we see renounce US status do so because they’re involved in a space where there’s sensitive technology like 5G or AI. High-level executives are finding that because of their nationality there’s a glass ceiling, so they’re almost being forced out.'

 Conversely, the private client team in London are hearing from a surprising amount of non-dom clients who are trying to find a way to stay on after the rule changes. 'There are definitely people who are fed up with the UK and who are leaving, but there is a similarly strong desire in others to remain in the UK, especially for those who have a family and a social life here. So we are advising clients on a variety of planning options, particularly in relation to offshore structures as well as onshore assets, to enable them to remain,' says Mara.

 In the end, while nobody wants to feel they are paying over the odds, most people will not rearrange their entire lives around tax rates. 'Packing up and leaving is not an easy decision,' says Mara. 'You can’t just do it for tax reasons, you have to be mentally ready – otherwise it won't work and you won’t be happy.'