The people most at risk would be those with significant unrealised gains in shares, business interests or investment portfolios who are planning to leave the UK in the next few years.
This includes founders and shareholders of private companies, holders of concentrated positions in listed shares or funds, and individuals who have built up large investment portfolios while UK resident. Commentary on the 2025 proposal emphasised that it was aimed primarily at wealthier individuals and entrepreneurs rather than the average taxpayer.


