The multi-millionaire owners of an English castle are exiting the UK after the government scrapped non-dom tax status.
Ann Kaplan Mulholland and her husband Stephen Mulholland are relocating to Italy, as it “doesn’t make any sense” for the entrepreneurs to stay living in the UK following the clampdown.
“We have no other options. As a business decision, it doesn’t make any sense to stay as a resident in the UK,” Ann Mulholland told MoneyWeek.
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The couple are among the tens of thousands millionaires who are said to be leaving the UK because of the tax changes.
The UK lost a net 10,800 millionaires to migration in 2024, a 157% increase compared to the year before (net loss of 4,200 in 2023), according to the Henley Wealth Migration Dashboard.
The figures, compiled by global analytics firm New World Wealth and investment migration advisors Henley & Partners, refer to individuals who have liquid wealth of at least USD 1 million.
The abolition of the non-dom tax status could cost the UK up to £111 billion by 2035, and 44,415 jobs by 2030, according to analysis by the Adam Smith Institute in April 2025.
The economics think tank forecasts the UK could face up to £14.2 billion of lost growth each year by 2035.
An HM Treasury spokesperson said: “We do not recognise these figures. The independent OBR has confirmed that the changes to the regime will raise £33.8 billion over the next five years.
“Replacing the outdated non-dom tax regime with a new internationally competitive residence-based system addresses unfairness in our tax system, attracts the best talent and investment to the UK, and ensures everyone who is a long-term resident in the UK pays their taxes here.”
How have non-dom tax rules changed?
A non-dom is a UK resident whose permanent home, or domicile, for tax purposes is outside of the UK.
Previously, non-doms only had to pay UK tax on the money they earn in the UK, unless money made elsewhere in the world was paid into a UK bank account.
Under the old rules, some non-doms had to pay an annual charge if they did not pay UK tax on foreign income or gains and had been resident in the UK for a certain amount of time.
This was known as the “remittance basis” and annual fees stood at either:
- £30,000 if the person had been living in the UK for at least seven of the previous nine tax years
- £60,000 for at least 12 of the previous 14 tax years
In March 2024, the then Conservative chancellor Jeremy Hunt announced plans to phase out the non-dom tax regime. He said non-doms who moved to the UK from April 2025 would be exempt from paying tax on the money earned overseas for the first four years. They would then be taxed on these earnings if they remained living in the UK after this time. Existing non-doms were granted a two-year transition period.
Chancellor Rachel Reeves announced a new tax regime, based on residence, in the 2024 Autumn Budget, which was introduced on 6 April 2025. She went further, ending the use of offshore trusts to shelter assets from inheritance tax and abolishing the planned 50% tax reduction for foreign income in the first year of the new regime.
Reeves extended the transition period – giving the wealthy three years to bring foreign income into the UK at a low tax rate.
Now, new arrivals to the UK don't have to pay tax on foreign income and gains in their first four years of tax residence – provided they haven't been a UK tax resident in any of the past 10 years prior to their arrival. After that, all foreign income and gains will be taxable at the corresponding marginal rate.
The Treasury estimates the further reforms to the non-dom tax regime, announced in Reeves' 2024 Autumn Budget, will raise £12.7 billion over the next five financial years.
Though a report by the economic consultancy Centre for Economics and Business Research (CEBR) estimates that if 25% of non-dom remittance basis taxpayers left the UK, the net gain to the Treasury would be zero.
The net losses to the Treasury in the first year of the scheme would rise to £2.4 billion, if 50% left, CEBR's report said.
Millionaires are "very mobile" – "leaving the UK is very easy"
For the mega-rich, upping and leaving the country tends to be relatively “easy”, Ann says: “I'm very sad to leave, because I absolutely feel at home here, but leaving is very easy. We're all very mobile, except for some of us with young children – who have to make a few bigger decisions. But for us, it's very easy to go.”
Ann believes the expected exodus of high net worth non-domicile residents will have a “massive impact” on the UK economy.
“My concern is, really, the state of the nation that is left without the income and without the opportunity of keeping people like us here,” she says.
“With us leaving, we're taking the taxes we pay within the UK with us – we're not going to be paying those anymore.
“The government thought that we were going to pay tax on our worldwide income, and the projections they had is that we would continue to pay the tax we're currently paying in the country, plus on our worldwide assets.”
The serial entrepreneur and her self-made husband moved from Canada to England three years ago when their youngest son flew the nest.
Relocating to the country felt like a “natural” choice, says Ann, explaining her mother is from England, and she had visited and gone to school in the country. Her husband, Stephen, is of Irish descent, “so the ancestry part was attractive”, Ann adds.
Ann Kaplan Mulholland and her husband will relocate to Italy following the abolition of the non-dom tax status in the UK.
They were drawn to the UK for many reasons – “the culture, the restaurants, the history” and the Royal Family to name a few.
"Everything about it was something that, [made me think] 'Yes, this is where I want to live over any other country,” Ann says.
The non-dom tax rules also played a part in the decision.
“We chose a place where it wouldn't affect our other existing businesses and investments, because we still have an ongoing insurance company and other real estate holdings that are income earning holdings. So, England was a natural choice out of the many choices we had,” Ann says, adding that they weren’t just considering “where do we want to live”, but “where do we want to live, that’s a preferable country to live in, given whatever businesses we're operating.”
The couple bought Lympne Castle in Kent for £5.5 million in 2023, and have also purchased other properties in the UK. Since then, they’ve restored it, reportedly spending £25 million. It has been transformed into a fully operating business – the castle can be hired out for weddings and events.
Ann says they now employ almost 100 people at the castle, and plans to transform it into a Medieval tourist destination in the south east of England.
Ann Kaplan Mulholland and Stephen Mulholland (pictured) bought Lympne Castle in Kent in 2023.
Leaving the UK following the abolishment of the non-dom tax status
Following the abolishment of the non-dom tax status, the couple are now in the process of relocating to Italy.
Ann intends to continue running the business from overseas, visiting the historic site when she can.
Italy charges overseas ultra-rich millionaires who transfer their tax residence to the country a yearly flat tax of 200,000 euros, plus a 25,000 euro flat-rate per person for a spouse or child.
It’s a price the Mulhollands are willing to pay.
While the cogs are in motion for the move, Ann isn’t against the idea of staying in the UK – even if it means paying a hefty flat-rate of tax to do so.
Given the abolishment was first announced by the conservative government, Ann suggested Labour could offer a temporary pause, allowing them to reflect on the impact HNWIs leaving the UK could have on the economy.
She adds: “Reeves could take a look at it and say, ‘Hey, maybe this isn't a good idea. We didn't know everyone was going to leave.’ That [a review of the rule changes] might be a smart thing to do for the economy.”
Ann argued it would make more sense for the economy if the government had instead introduced “big” fees for non-domicile millionaires, or a requirement to invest a certain amount into UK infrastructure.
“The government should be saying, ‘We're going to charge you the fees if you want to stay. Let's not touch your worldwide assets – that doesn't make sense – but pay to stay and invest in your infrastructure as well’,” she says.
Ann points to the rules that exist in other countries, such as the British Virgin Islands: “They want us to invest with them. They roll out the red carpet to invite money in, to invest in the countries where else they're going to get it, if they can't get it within their own country.”
The entrepreneur isn’t opposed to a wealth tax. “A wealth tax would be a lot easier to be more palatable than it would be for a worldwide asset tax,” she says.
“I don't have an issue with them charging us more.”
Read more: The rich are already being hit by huge wealth taxes, say Merryn Somerset Webb
She adds: “Have us invest in your country that will create more jobs – it creates more investments, creates more wealth.
“But why make it for wealthy individuals to leave?
“It's not really fair to those consumers and the residents that are maybe not as aware of the impact of the loss it's going to be.”
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