Last month, the UK ended its non-domiciled tax regime. This change had been announced in 2024, but its effective date was April 2025. The way this program worked was that if you lived in the UK but were "domiciled" somewhere else, you could limit the amount of taxes that you had to pay in the UK.
Only income and gains earned in the UK and foreign income and gains brought into the UK were taxed. If foreign income stayed abroad, it was not taxed. There was still an annual charge for long-term residents of the UK, but at a high level, this is how the tax regime worked.
The advantage for a rich people is that they could decide to reside in the UK because, hey, London is pretty cool, but at the same time they could nominate a lower-tax country as their domicile. For non-rich people, this became a controversial program, and so it was swapped for tax regime based on residency.
The reason I mention this is because it seems to be having a direct impact on Milan's real estate market. Since 2017, Italy has had a flat tax regime that allows new residents to pay a fixed annual tax rate of €200,000, regardless of how much money they earn abroad.
This has proven to be attractive among rich people and, between 2017 to 2022, the program attracted 2,730 individuals according to the Financial Times. But then the UK made its change and so Italy decided to colloquially rebrand its program to "svuota Londra", which translates to "empty London" in Italian.
It became about taking direct advantage of what the UK had done. And it seems to be working even better. In 2024, approximately 2,200 high-net-worth individuals relocated from the UK to Italy, with Milan being the primary destination. This has created a notable uptick in the luxury property market — more transactions and higher prices.
Whether you agree with these policy decisions or not, they will have an impact on the fortunes of London and Milan going forward. In 2023 alone, it is estimated that individuals holding "non-dom" status in the UK paid almost £9 billion in taxes and contributed to the creation of some 44,000 jobs.
Part of this is now flowing south to Milan.
Note: None of this is tax advice.
Cover photo by ANASTASIIA BUCHINSKAIA on Unsplash
