Switzerland lies in “pole position” to gain from changes to the UK tax system which could encourage high net worth individuals living there to consider moving, according to a leading tax expert, John Huber.

However, Malta should be doing more to attract a share of them, he said.

“Chancellor George Osborne stated in last week’s summer Budget that persons born of British parents residing in the UK or those that have been residents in the UK for more than 15 of the last 20 years shall lose their permanent non-domicile status – which effectively means that they shall start to be taxed on their worldwide income.

“Whether that shall lead to an exodus of high or ultra high net worth individuals from the UK especially London is still to be seen,” he said.

“I believe that Switzerland would be in pole position to attract such individuals. However, Malta would indeed do well to attract a number as residents. They have always proven to be highly beneficial to our economy.

“I believe that our present residence programmes cater well for such persons. However, having the right legislation in place is not anywhere close enough to attract theses individuals. The whole set-up for residence must be akin to that of the Individual Investor Programme,” he cautioned.

Bethell Codrington, the global head for international pensions at the TMF Group, added that returning UK domiciles would no longer receive favourable treatment in relation to any offshore trusts which they may have settled while they were non-UK domiciled and not resident in the UK.

“They will be subject to UK income tax, capital gains tax and inheritance tax in relation to offshore trusts in the same way as any other UK resident and UK domiciled individual on their return to the UK,” he explained.

Mr Codrington was convinced that there would be an increase in individuals that would reconsider their options once the new regime came into force in April 2017.

“They will be looking at whether remaining in UK over 15 years is in their best interest financially and whether they should be moving to Malta and taking advantage of the various programmes on offer – which vary from global residence, individual investor, retirement and permanent residence – all of which look enticing.

“It is not just the non-domiciles who may look at moving to Malta, but also those affected by the new swinging taxes on dividend income.

“For those relying on income from investment portfolios, if the portfolio is over £140,000, their tax bill is due to increase substantially,” he said.

Chris Casapinta, the country executive for Alter Domus Malta, also believes that Malta could be an option for the high net worth individuals, many of whom have already started to look at alternative locations.

“This being said there are a number of challenges in the current environment... There is a significant drive for the tax authorities around Europe to collect as many taxes as possible.

“High profile individuals will definitely be closely looked at for possible sources of tax revenue. So in general the appetite for tax planning could be very much reduced in the coming years to come, resulting in less business moving to our shores,” he warned.

Identify Malta declined to comment.

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