The Xi of residency: why did Revolut co-founder Storonsky trade London for Dubai?

Nikolay Storonsky, founder of Revolut, has moved to the UAE. One of the richest Britons, whose fortune according to the Bloomberg Billionaires Index exceeds $14 billion, took this decision a year ago, in anticipation of a major tax reform, abolishing from 2025 exemptions on foreign income and protection of foreign trusts. The UAE's lenient tax regime could help Storonsky save on taxes, especially if Revolut's IPO takes place, according to experts interviewed by Oninvest. However, the move has some disadvantages - British regulators are closely monitoring the change of residency

The UK's biggest tax reform is set to kick off in 2024. In October 2024, the Chancellor of the Exchequer of Great Britain Rachel Reeves confirmed: many benefits enjoyed by wealthy residents of the country will be abolished from April 2025, when the country will start a new fiscal year. In October 2024, in the documents of the family company of Revolut founder Nikolay Storonsky Storonsky Family LTD there was a record of the businessman's change of residence: he moved to the United Arab Emirates (UAE) - Bloomberg was the first to write about it.

Nikolay Storonsky still has a home in the UK, Revolut told Oninvest - he spends the time in the country that he "needs in his position". That time is "balanced with Storonsky's active travels" as CEO of a global company operating in 39 markets. The company declined to comment on the reasons for Storonsky's move.

Storonsky is a Russian native who renounced his Russian citizenship and is one of the richest people in the UK. According to the Bloomberg Billionaires Index, his entire fortune is estimated at $14.2 billion, which puts Storonsky in fourth place among British passport holders after Dyson founder James Dyson ($15.7 billion), industrialist and head of JCB Anthony Bamford ($15.4 billion) and Ineos CEO Jim Ratcliffe ($14.7 billion).

Storonsky is the co-founder of Revolut, a neo-bank that has expanded into multi-currency cards for travelers, cryptocurrency transactions and money transfers. Revolut is now one of Europe's most valuable fintech companies. In the fall, Revolut launched a secondary sale of its shares, hoping to raise $1 billion for its securities, Bloomberg wrote, citing sources. The posted price of $1381.06 per share saw the company's valuation rise to $75 billion from the previous $45 billion. Revolut's new value is not yet comparable to British banking giant HSBC, but the neobank is already ahead in terms of the number of customers served last year. Bank of Storonsky is now valued higher than some classic rivals, such as publicly traded Barclays and Lloyds.

The Non-Dom (or non-domicile, "non-domiciled resident," that is, resident without belonging to a country by birth or choice) regime has existed in the United Kingdom for more than two centuries. In 1799, King George III allowed people born in the British colonies to live in the United Kingdom without paying taxes on overseas rents or shares, as long as the money stayed abroad. Then Non-Dom, which exempts overseas income from tax, became applicable to any foreigner who became tax resident in the UK and spent less than 15 years in the UK from the date of change of residence.

As of April 6, 2025, the UK's new fiscal year, the situation has changed dramatically. The Non-Dom regime was abolished. It has been replaced by the FIG (Foreign Incom and Gains) regime. It exempts the overseas earnings of foreigners living in the UK from income tax and capital gains tax only for the first four years of their tax residence and allows them to bring these funds into the country tax-free during this period. The FIG can only be used once in a lifetime and only by those who have not been UK tax resident for 10 consecutive full tax years at the time of the first year of this regime. Even during the grace period, all overseas income will now have to be declared.

Individuals who previously enjoyed Non-Dom treatment on a remittance basis but have been resident in the UK for four years or more are not subject to the new FIG regime. Accordingly, from April 2025, all of their income, irrespective of the source (place of receipt), is subject to income tax at rates ranging from 20% to 45%. Capital gains from the realization of assets (including securities and real estate), regardless of location, are taxed at a rate of 24%. The maximum tax rate on dividends is 39.35%. Interest income and coupons qualify as income and may be taxed at a rate of up to 45%. Gains from the sale of investments in a number of investment funds may also be taxed at a rate of 45%. Furthermore, all overseas assets of such individuals after 10 years of residence in the UK are subject to inheritance tax at a rate of 40%.

Apart from Non-Dom, there were several other attractive regimes in UK tax law before April 2025, Dmitry Zapol, partner at IFS Consultants UK, told Oninvest. Firstly, tax residents without UK domicile were not liable for inheritance tax on overseas assets. Secondly, offshore trusts established by residents before they acquired UK domicile were recognized as "protected trusts" - as a result, the founder of the trust, and in some cases the beneficiaries, were not subject to income and capital gains tax on income and capital gains generated within the structures managed by the trust; in addition, assets transferred to such a structure were protected from inheritance tax.

Storonsky is not the only billionaire to leave the UK in 2024.

During this time, Guillaume Pouzaz, founder of global payment system Checkout.com, Egypt's richest man Nassef Sawiris, Goldman Sachs deputy chairman Richard Nodde, venture capitalist and crypto-enthusiast Christian Angermeier, and billionaire developers Ian and Richard Livingston left the country. Shravin Mittal, heir to the Mittal empire and managing director of Bharti Global, has also left London. Steel giant Lakshmi Mittal himself may follow suit, suggests the FT.Speaking to the FT, Nassef Sawiris criticized Chancellor Rachel Reeves' plan this way:

UK-born billionaires were also unhappy with the reform. According to Phone 4u founder John Caudwell, the changes are forcing wealthy foreigners to return "to Milan, Monaco and Dubai".

It was to the UAE that the aforementioned Nassef Sawiris and Shravin Mittal moved, as well as shipping magnate John Fredriksen, who put his London mansion up for sale, and Michael Edward Platt, founder of major European hedge fund BlueCrest Capital Management, who moved his family and family office here, according to Gulf News.

Henley & Partners estimates that 9,800 millionaires with a combined wealth of $63 billion could move here in 2025.

Pavel Durov, the creator of Telegram, remains the most famous Russian-born tax resident in the UAE. In an interview with Bloomberg, he said:

According to Durov, he opted for residency in the Dubai Media City free economic zone, which enjoys tax benefits.

In the UAE there is virtually no taxation for any income of individuals, except for income from entrepreneurial activity. Dividends, income from investments in securities and real estate are not taxed, lists Daria Nevskaya Nevskaya, Managing Partner of Nevskaya Consulting. With regard to corporate profits, tax is levied, but, firstly, there are a number of exemptions - for example, with regard to dividends, for companies from free zones, for small companies. Secondly, the income tax rate is generally only 9% and 15% for large international businesses. In addition, in the UAE, the VAT rate is 5%, adds Nevskaya.

From a tax point of view, the UAE has no negative aspects, but you need to be prepared for a different climate and culture, warns Nevskaya. Two Oninvest interlocutors with experience of living in the UAE told us about another peculiarity: despite its reputation as an international hub, the expat community is not so mixed, and many communicate within their own diasporas.

Researchers at the International Inequalities Institute at the London School of Economics (LSE), interviewing 35 of the richest people in the UK, found that they would not leave the country because of tax benefits, partly because of the associated stigma. Wealthy people interviewed described countries with favorable tax conditions as "boring" and "culturally sterile" and tax migrants as "overly selfish." Moving to a tax haven poses a reputational risk for them, the study concludes.

Shortly after the news of Storonsky's change of residence, the Bank of England suspended the issuance of a full banking license to Revolut, which the neo-bank has been seeking for several years. According to the FT, the regulator demanded assurances from the fintech group that it was building a risk management infrastructure in line with its ambitious international expansion plans. "Our commitment to the UK is clear: we have just opened a new headquarters in London and are investing £3bn [more than $4bn - Oninvest note] in our UK operations," a Revolut spokesperson told Oninvest.

British and European regulators closely monitor such moves, assessing not only the formal residency, but also the actual center of a person's life interests, as well as from where his business is managed, reputational risks and the purpose of the move, says Polina Kuleshova, the correlator of the consulting company Vast Vista Passport Care.

In the case of Storonsky, who has been living in the UK for several years, the abolition of the Non-Dom regime itself was hardly the only trigger for relocation. In practice, the presence of foreign companies and trusts would have meant new disclosure requirements and, probably, an increased tax burden for him, Dmitry Zapol suggested in a conversation with Oninvest. However, preparation for Revolut's IPO seems to be a more likely motivation: in connection with this, the entrepreneur could have a significant tax liability for capital gains tax, which is rationally taken into account when choosing a tax jurisdiction, he specified.

According to Revolut's annual report for fiscal 2024, as of April 2, 2025, Nikolay Storonsky owned 25% of Revolut directly or through controlled structures. Forbes estimates his stake in the neobank at $7.9 bln. The Times, citing sources in British financial circles, reported that Revolut is now considering a dual offering on the New York and London stock exchanges at a valuation of $75 bln.

This article was AI-translated and verified by a human editor