Lord Sugar’s Attempt to Become a Tax Exile

In a surprising revelation published by The Sunday Times, it has been reported that Lord Alan Sugar attempted to become a tax exile by moving to Australia, hoping to escape a significant sum of £186 million in UK tax on his substantial dividends. However, what Lord Sugar and his team failed to realize is that the UK law prohibits members of the House of Lords from becoming non-residents for tax purposes. An article by Tax Policy Associates explores why Lord Sugar’s tax avoidance plan failed and delves into the broader issue of why the UK tax system makes it so easy for individuals to become tax exiles.

The Concept of Tax Exile

Tax exiles are individuals who relocate to countries with lower tax rates or tax havens to minimize their tax liability. They become non-residents for tax purposes in their home country, allowing them to avoid or reduce taxation on their income, dividends, and capital gains. It is estimated that one in seven British billionaires now resides in tax havens, such as Monaco, Australia, Portugal, and Israel.

Becoming a Tax Exile

The process of becoming a tax exile is relatively straightforward. Individuals are only taxed by the country they reside in, referred to as their tax residence. For example, a French citizen residing in Paris would not be subject to UK tax on dividends from UK companies. However, if they were to move to the UK, they would become UK tax residents and be liable to pay tax on that income. Conversely, a British person living in London would be subject to UK tax on their UK dividends. By leaving the UK and moving to a country that does not tax capital gains, individuals can escape taxation on significant profits when selling a business or receiving a large dividend.

The Need for Exit Taxes

Exit taxes, imposed by many countries, are designed to prevent or limit the tax avoidance strategies utilized by tax exiles. These taxes typically require individuals leaving the country to be deemed to sell their assets at the prevailing market value, triggering immediate tax liability on any capital gains. However, some countries allow deferral of taxes until the assets are actually sold or dividends received. Additionally, if the new home country taxes the eventual sale, the original country usually provides a credit against the exit tax.

Lack of Exit Tax in the UK

Despite countries implementing exit taxes, the UK has yet to introduce a general exit tax for individuals. This is partly due to historical factors, as the UK did not have capital gains tax until 1965. Moreover, complying with EU law complicated the implementation of exit taxes, as unconditional interest-free deferrals of exit tax until actual disposal of assets were required. Germany’s recent attempt to disregard these EU regulations may have significant consequences.

Potential Solutions

Contemplating whether the UK should adopt an exit tax involves considering opposing views. Proponents of the current system argue that individuals should have the freedom to choose their residency based on tax benefits, and tax competition is a valuable mechanism for holding governments accountable. On the other hand, critics argue that if someone has spent years building a successful business in the UK, it is fair for the country to tax the gains made upon selling that business. Additionally, the tax system incentivizing individuals to leave may be counterproductive.

Careful Consideration of Change

Changing the law regarding tax exiles and implementing an exit tax requires careful consideration. An exit tax would need to be designed to target those specifically leaving for tax havens, rather than individuals relocating to fully taxed countries. To maintain fairness, a reevaluation of capital gain rules upon entry to the UK is also necessary, as the current system can be discouraging for entrepreneurs who have made gains outside the country. Any changes should be implemented cautiously and with great care to avoid unintended consequences.


The case of Alan Sugar highlights the complexities and challenges surrounding tax exiles and the UK tax system. While Lord Sugar’s attempt to become a tax exile failed due to the House of Lords’ tax residence provisions, the broader issue of tax exiles and the ease with which individuals can avoid UK taxes remains. The implementation of an exit tax, coupled with a review of capital gain rules upon entry, could help strike a balance between preserving individual freedom and ensuring fairness within the tax system. However, any changes must be approached with caution to prevent unintended consequences and maintain the UK’s attractiveness for entrepreneurs.