UK Hedge-Fund Founder Exits Non-Dom Regime via BVI + ADGM SPV

London hedge-fund founder, GBP 410M AUM, GBP 38M personal wealth. April 2025 non-dom abolition under Finance Act 2024 + FIG four-year transition. Modelled ongoing UK tax exposure: ~GBP 14M annually (vs GBP 200k-400k pre). Introduced by Lincoln's Inn tax silk. Three-layer structure: BVI BC (personal portfolio + ManCo founder equity), ADGM SPV (CIO services to London ManCo with QFZP analysis), UAE personal residency (Golden Visa investor). Kensington property deliberately not unwound. 11-week execution: SRT day-count planning under Schedule 45 FA 2013 (<16 UK days), BVI BC + ADGM SPV incorporations, Golden Visa investor route, UK exit administration, ADGM first management invoice with TP memorandum under Article 34 FDL 47/2022. UAE TRC issued at 183 days.

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