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“And where do you come from?” I asked the could be German/Greek/Italian aristocrat seated next to me at a 60th birthday party recently. Dressed in a La DoubleJ kaftan with half a dozen curated gold pendants hanging from her thin, Botoxed neck, she could have been 35 or 65.
“It is so diiiiificuult,” she replied wistfully. “I now live between Monaco, Lisbon and Verbier, though I used to live in London.” A wave of sadness crossed her smoothed-out face. “I love London, all my friends live here, but … you know.”
The other guests assembled — who lived between Geneva, Milan and Luxembourg — nodded in sympathy. It is all so diiiiificuult, they chimed. My husband (ex-banker) and I (writer) later worked out that we were the only non-non-residents at the table, clearly the only taxpayers and by far the poorest of the lot.
• The magic loopholes that let you earn £26,000 a year tax-free
“You know” was a reference to the recent tax assault on the foreign super-rich. Jeremy Hunt, the chancellor of the exchequer until last month, took away their privileges when he effectively banned the longstanding non-dom tax loopholes (where non-residents only pay tax on what they earn in the UK).
It wasn’t just European and Russian billionaires that he upset. According to a London School of Economics report in 2022, one in five bankers earning more than £125,000 were claiming non-dom status. (One in four are probably trying to relocate to an island off Malta as we speak.) A non-resident (N-Res), otherwise known as a nowhere person, is someone who has no fixed residence because to do so is to incur tax somewhere.
N-Reses — all of whom seem to possess MBA degrees — originally came to London from Europe and beyond (India, Russia) for professional or social reasons (Turin and Hamburg being frightfully dull after two years at Stanford business school). London’s we-don’t-look-very-carefully-at-your-financial-situation ethos suited their family office’s accountants so they bought houses using shell companies and adopted London as their spiritual home.
Famous N-Reses include Akshata Murty (who met Rishi Sunak at Stanford), the steel magnate billionaire Lakshmi Mittal, Roman Abramovich and Sir Philip Green. Clever N-Reses went to work for international banks; the intellectually challenged went to parties in Chelsea.
When the British weren’t looking, they boasted about not paying tax (been there, heard it), how useful they were to the economy and how sad London would be without their contribution. N-Res children attended the best of the British private boarding schools (“the French lycée is for peasants” was the thinking) but only ever holidayed at their château, villa or boat in St Tropez, Ibiza or the German island of Sylt.
• ‘I’m better off than in the UK’: the taxes luring non-doms to Italy
We have many N-Reses in our social circle. They are educated, rich and refined, though rather cagey about where the money really comes from (some Gibraltarian trust, I assume). They tend to have other N-Res friends only — because Americans, for example, pay worldwide tax and call them globotrash. Technically they can afford Gucci, though they favour designs made by chums such as Muriel Brandolini and Luisa Beccaria. The only things an N-Res ever pays for at the full rate are accountants and lawyers, several of whom are on the payroll.
The N-Res is allergic to British country life (so duullll) unless they grew up killing Wildschwein (wild boar), at which point they were regulars at Blenheim. Those were the days. Now that the taxman is on their case, they have had to move to the next tax shelter (they complain that Switzerland is too expensive).
Some have kept their children in British schools, accruing many “medical absences” to pass Heathrow airport immigration before their allotted 46 days in the country are up. An N-Res can’t go home, of course, because home also has taxes, so now they float.
We may be seeing a lot more of this drifting stateless group because the big fear now is that Sir Keir Starmer will come after rich British residents with any one of several feared wealth taxes. Hence the busy signal at the end of many wealth advisers’ phones. Although many countries now offer fiscal sanctuary to N-Reses (Dubai, Malta, Singapore etc), the schemes are not always to be trusted.
For example, Italy recently offered N-Reses a flat €100,000 tax bill regardless of earnings, then swiftly doubled it. “Portugal also did it,” says Nick Day, an accountant at Tax Innovations. “They offered a golden visa to those who bought property then swiftly took it back when the locals complained they had nowhere to live.” Day says many people are, indeed, relocating.
• Italy has doubled tax for foreigners — where will rich Brits move to now?
“We are seeing British remote workers on £50,000-£100,000 a year moving to Dubai where they pay no tax at all,” he says, admitting that the cost of rentals then comes as a shock (and that’s before you mention the social life). Many firms, he says, are willing to go along with it though, adding that none of this is “at all straightforward”. Or joyful.
Rhymer Rigby is a writer who studies N-Reses. “We’re back to the whole living in Jersey or Monaco for tax reasons, feeling so clever for it when in fact it pisses everyone off. No one wants to hear what an N-Res thinks. Nobody cares. They’ve alienated their friends and family. Wouldn’t it be better to live in one place and pay tax?”
Also known as the new homeless because many have no real abode, N-Reses are at once a problem and an opportunity. Schools such as Copperfield in Verbier now offer a hybrid model of education where children can come and go seasonally (according to their parents’ visas).
Charles Bonas, an educational consultant, has seen a rise in what he calls “snowbirds” who spend winters in Verbier, summers on yachts and spring in London, where some schools are all too happy to have them. Some N-Res children don’t have a mother tongue, apart from Portuguese, which is what the housekeeper speaks. “What troubles me,” Bonas says, “is that these are rootless young people, not émigrés who elected to live in countries and really contributed to the culture.”
N-Reses are GPOs (garden party only), meaning they are only ever invited to village activities and never inside a posh local’s home. When tax avoidance is the only motivating factor, admiration is thin on the ground. It’s hard to cure cancer in 46 days or run for office, unless it’s your own private one.
• The T-word casts a cloud over Dubai
The rise of the N-Res comes at a time when longevity studies show that what makes people live longer (and lead happier lives in general) is being part of a community, having close friends, pottering in your (one) garden, none of which is possible when your main domicile is Zug (a canton in Switzerland where all the locals have in common is tax avoidance and a love of the local airport).
My neighbour at dinner cut a pitiful and lonely figure. She was, as the French say, “déracinée”. Verbier, she complained, is “sooo boring” off season and Lisbon so provincial (tears came to my eyes). Her children lived in New York, she said, and her husband rarely left Monaco.
Perhaps in the future a country will be created exclusively for displaced N-Reses. In the meantime, they are about as popular worldwide as this summer’s slugs. “In evolution, we had to be part of the community to survive,” Bonas says. “Those who didn’t contribute got kicked out.”