Since the Autumn Budget and the Chancellor’s decision to abolish the non‑dom tax status, Britain’s data deserts have been filled by a rush of anecdotes, commissioned surveys and early payroll figures — each side of the debate selecting the numbers that best suit its case. Initial analysis of HMRC payroll data, reported by the Financial Times and briefed to City A.M., suggests the most apocalyptic predictions of a mass non‑dom exodus have not materialised in PAYE records and that departures to date are broadly in line with Office for Budget Responsibility expectations. Yet experts caution that payroll snapshots capture only part of the population at risk and that the full picture will not be visible until tax‑return‑based statistics are available after the 2025–26 filings are concluded in January 2027.

Those caveats matter because PAYE inherently favours visibility of salaried workers. Dominic Lawrance, a partner at Charles Russell Speechlys, told City A.M. that the payroll‑based analysis “needs to be carefully questioned” since many economically significant non‑doms are not captured by PAYE. Private client practitioners — including Kate Johnson at Wedlake Bell — echoed that point, noting business owners, trust beneficiaries and those whose income is overseas or capital‑based will often fall outside payroll data. Academic research from the University of Warwick supports the broader contention that around four in five remittance‑basis users have some employment income and thereby appear in PAYE, but it also underlines the existence of an important minority who do not and whose mobility can still materially affect revenues and investment patterns.

Beyond statistics, there is real‑world movement that payroll raw counts may understate. City A.M. has reported a series of high‑profile relocations — most notably Goldman Sachs international boss Richard Gnodde’s move to Milan — and a series of agents and advisers point to a marked rise in luxury‑home sales and a thinning market for certain domestic services in London’s super‑prime neighbourhoods. For some sellers and service providers, these departures are existential: as one buying agent told City A.M., “almost all the sellers in luxury London property are non‑doms looking to leave.” Such anecdotes, while necessarily selective, have been persuasive to a number of observers who argue that measuring mobility requires looking beyond employment registers to asset flows, property transactions and the behavioural responses of ultra‑high‑net‑worth individuals.

That divergence — between measurable PAYE movements and broader signs of departure — is one reason the debate is so fractious. Lobby group Foreign Investors for Britain has published Oxford Economics‑commissioned surveys suggesting a sizeable share of affected foreign investors would leave absent a tiered alternative, warning of hits to inward investment, VAT and stamp duty receipts. By contrast, independent commentators and some policy academics point to anonymised HMRC data analyses showing the pre‑reform reliefs primarily benefited a narrow, wealthy group and that abolishing the regime should raise substantial revenue with only limited emigration. Henley & Partners’ Private Wealth Migration Report, widely cited for claims about millionaire flows, has itself been criticised for relying on indirect proxies such as LinkedIn locations and not clearly distinguishing temporary moves from permanent migration — a reminder that methodology drives conclusions.

The government’s timetable and statutory changes are now settled and offer a touchstone for evaluating outcomes. Official guidance sets out the move to a residence‑based taxation regime, with the removal of domicile as a tax concept and the new rules coming into force on 6 April 2025. The Treasury and HMRC have emphasised implementation detail, while independent forecasters and journalists have been explicit that definitive fiscal and migration impacts will only be measurable once return‑based data becomes available — the earliest comprehensive figures are therefore not expected until after the January 2027 filing season. In the meantime, ministers argue the reforms correct long‑standing distortions in the tax base; critics counter that near‑term behavioural responses by wealthy, mobile taxpayers will damage London’s competitiveness and tax receipts alike.

Practical policy responses have been floated from both sides of the argument. Foreign Investors for Britain has urged a tiered tax regime as a compromise that might retain capital and talent while increasing contributions to public finances; some advisers and firms have advanced variants designed to preserve investment while curbing avoidance. Academics who supported reform have stressed that most non‑dom taxpayers already appear in PAYE, and so the projected revenue gains remain plausible even allowing for movement. Ultimately, whether a compromise is politically achievable will depend on how sharp the observable effects become over the next two years and on the balance between short‑term capital flight and longer‑term economic contributions.

For now the evidence is mixed. Early PAYE data tempers the scale of the exodus feared by some, but it does not negate the departures visible in ultra‑prime property markets and the loss of a small number of highly connected individuals whose mobility is both easier and more economically consequential. As Arun Advani and other researchers have noted, the key uncertainty lies with the smaller cohort that falls outside payroll registers but commands outsized economic weight; as one private advisor told City A.M., wealthy clients with few UK ties are “much more likely to leave.” Policymakers and markets alike would do well to treat current figures as provisional — useful for setting expectations, not for closing the book — and to await the fuller HMRC and OBR data that will allow a measured assessment of whether Britain’s wealthy are voting with their feet or merely shopping around.

In the meantime, the argument over interpretation continues to be shaped as much by methodology as by movement. As Jeff Bezos quipped in 2023, when anecdotes and datasets clash the anecdotes often point to what is being missed by conventional measures — a cautionary observation for anyone intent on declaring either a rout or a reprieve on the basis of partial numbers.

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Source: Noah Wire Services