South Africa’s richest woman, Magda Wierzycka faces a dilemma as she may have to leave London which she has called home since 2019 over changes in the UK’s Non-Dom tax laws.
Wierzycka was born in Poland but had to flee the country with her family at the age of 12 after the Polish government declared martial law.
Magda Wierzycka arrived in South Africa with her family via an Austrian refugee processing center in 1983 having lived a year in the Polish refugee camp at Traiskirchen.
Her family settled in Sunnyside, Pretoria and she went on to attend the University of Cape Town where she graduated with a Bachelor of Business Science and a Postgraduate Diploma in Actuarial Science in 1993 as it was the only course she could get a bursary for.
Journey to Billionaire Status
Wierzycka’s journey to becoming one of the country’s most successful entrepreneurs, founding and running the major investment firm Sygnia while becoming one of its most recognizable anti-corruption campaigners started in 1993 when she became a product development and Investment actuary at the Southern Life Association for Mutual Life and Accident Insurance (now part of MMI Holdings Limited).
Here, she was able to pay back her bursary, she then spent two years building an asset consulting division as an investment consultant for the retirement fund clients of Alexander Forbes. In 1997, She joined Coronation Fund managers, a third-party fund management company based in Cape Town, in 1997 as a director and Head of Institutional Business. At Coronation, she played a pivotal role in making the company one of the largest asset management firms in South Africa.
Wierzycka became the CEO of the African Harvest Group in 2003 and in 2006, she negotiated the sale of Metallon Corporation’s African Harvest Fund Managers, a R18 billion asset management company, to Cadiz Asset Management. She then led the management acquisition of the remainder of the group, which culminated in the establishment of Sygnia Asset Management, a Fintech company.
Wierzycka became Sygnia’s CEO in 2006. In a decade, she grew the company’s assets from R2 billion to R162 billion which resulted in Sygnia becoming the second largest multi-management company in the country and Wierzycka became a made billionaire.
Anti-Corruption Activism
Wierzycka is not only a business tycoon/Billionaire. She has also proven herself as a force against widespread corrupt practices in South Africa having played a part in the ‘Gupta Leaks‘.
In 2017, Wierzycka was linked to the whistleblower who leaked a vast cache of emails from inside the business empire of the Guptas: three brothers who moved to South Africa from India in the 1990s, cozied up to former President Jacob Zuma and his family, and gradually “captured” the levers of the South African state, siphoning mountains of public cash to their companies in the process.
This was after a whistleblower handed her a a drive containing over 500,000 emails that revealed the true scale of rank corruption and iniquity that lay at the heart of the South African government.
The leaks revealed the Guptas were engaged in snagging lucrative tenders from departments across government and doling out ministerial appointments. The leaks implicated global heavyweights KPMG and McKinsey in the Guptas’ affairs, and helped to force out of business the British PR firm Bell Pottinger — which exploited racial tensions to spin scrutiny away from the Guptas.
These leaks were a key factor as Jacob Zuma fell from grace, ousted first as head of his party, then as head of state.
Involuntary Exile
As a result of her purported role in the “Gupta leaks”, Wierzycka was forced to flee into exile due to fears over her safety. she fled to London with her family, using a luxury Park Lane hotel as a bolt hole.
Her family would later return to south Africa, but the constant phone-tapping, threats on Twitter, and interventions from state security led Wierzycka to make London her new home.
Her newfound freedom brought with it benefits spanning all corners of her life. She could now walk down the street without having to choose between fearing for her safety in South Africa’s febrile political climate or having a cumbersome security detail follow her around.
Not content with just sitting in an apartment, the restless billionaire and serial entrepreneur set up a UK-based venture capital firm, Bravoos Investment Advisers looking to back the kind of long-term life science firms on which the UK investment community and risk-averse pension funds were unwilling to take risks.
Things were going very smoothly until the UK Labour Government’s changes to to how “non doms” are taxed under the recent Tax and spend budget presented by Rachel Reaves.
Understanding UK’s Non-Dom Status
The non-dom status in the UK allowed residents whose permanent home, or domicile, was outside the UK to be taxed only on their UK income and gains, while foreign income remained untaxed unless brought into the UK.
This regime attracted many wealthy individuals and entrepreneurs to the UK, offering them favorable tax conditions. For wealthy individuals, this presented the opportunity for significant – and entirely legal – savings, if they nominate a lower-tax country as their domicile.
However, the UK government has decided to abolish this status from April 2025, aiming to increase tax revenues and address perceived inequalities in the tax system.
UK leaning Towards the US Tax System
The U.S. does not have a “non-dom” concept in the same way the UK does, but it has a complex tax system that taxes individuals based on their citizenship, residency, and worldwide income.
The U.S. tax system does not formally recognize the concept of “non-dom” status as the UK does. However, there are provisions for foreign individuals and U.S. expatriates that can affect their tax obligations, particularly through the Substantial Presence Test and Tax Treaties.
The U.S. taxes its citizens and green card holders on their worldwide income, regardless of where they live or their domicile status.
Individuals who are not U.S. citizens or green card holders but who spend a limited amount of time in the U.S. may qualify as “non-resident aliens” (NRAs) and would generally only be taxed on income sourced from within the U.S.
The U.S has tax treaties with various countries that can provide relief from double taxation or affect how foreign income is taxed, but this does not provide an exemption similar to the UK’s non-dom status.
U.S. citizens or green card holders who expatriate (renounce their citizenship or green card) may be subject to an exit tax which taxes certain unrealized gains at the time of expatriation.
The UK on the other hand provides specific rules for individuals who are considered non-domiciled. This status allows certain tax benefits for those who are domiciled in another country but reside in the UK.
The U.S. applies an exit tax when a person renounces citizenship or abandons a green card, taxing unrealized gains as if the individual had sold all their assets. The UK does not have an exit tax but imposes a charge on long-term non-doms who leave the UK and may be subject to inheritance tax on their worldwide assets.
However, with the latest ‘non dom’ legislation, the UK seem to be going down the route of the US.
Magda Wierzycka’s Peculiar Situation
For Magda Wierzycka, the changes are set to complicate her once peaceful arrangement in which her south African assets including her shares in Sygnia were taxed by South Africa while her UK assets comprising Bravoos and two properties were taxed in the UK.
The initial understanding of domicile was that if a UK resident had lived in the UK for fewer than 15 of the last 20 tax years their permanent home could be elsewhere. However, under the new ‘dom’ laws, foreign income and assets vs domestic assets were distinguished for just four years before asset holders are deemed permanent UK residents.
The new ‘dom’ law applies inheritance tax on the foreign assets of anyone who has been in the UK for more than 10 years as opposed to the earlier arrangement where inheritance tax would not apply to assets owned by people claiming non-dom status that were held in a foreign trust.
This change, Wierzycka says, has left her and the other non-doms she knows doing one calculation: “How many more years before the axe falls. What’s our deadline for being in the UK?”
As well as well as personal objections that make the changes unpalatable, there are also – the billionaire investor says – practical and diplomatic ramifications that make them unworkable.
“My husband still has to live in South Africa because it has foreign exchange controls,” she says .
The question on every non-dom’s lips in the UK she notes is “How many more years before the axe falls. What’s our deadline for being in the UK?”
So many non-doms are leaving the UK or planning to leave as a result of this new law but for wierzycka, her situation is very much different as she Still has a target on her back home in South Africa
Her current shortlist of possible locations is Greece, Italy and Switzerland, which all operate foreign national schemes redolent of old non-dom regime.
“I really don’t want to leave the UK,” she says. “I was in dreamland, until my tax advisors were all of sudden saying, ‘Okay, we have to have a plan, let’s put forward alternatives.”
Should Wierzycka however choose to leave, the loss for the UK economy would spread much further than than just the (not insignificant) absence of her personal income tax bill.
She employs a lot of domestic staff who would become jobless if she decides to leave the UK.
she has also put on ice fundraising activities for its fourth fund – worth millions of pounds – until she makes a decision. If the government’s non-dom reforms do go through without any compromises to the inheritance tax cut-off or dividend issue, Wierzycka has vowed take that funding round “to a destination that will welcome the support for the most risky investment space”.
Nigeria’s Non-Dom Tax System
Nigeria’s non-domiciled (non-dom) taxation system is designed to tax individuals who are foreign nationals but reside in Nigeria.
Under this taxation system, individuals who are tax residents in Nigeria are subject to taxation on their worldwide income. However, those who are not tax residents (non-doms) are only taxed on income that is derived within Nigeria.
An individual is considered a tax resident if they spend at least 183 days in Nigeria during a 12-month period or if they have a permanent home in the country.
Non-domiciled individuals (who do not meet the criteria for tax residency) are only taxed on income derived from Nigerian sources, such as employment or business income within Nigeria.
Non-doms may benefit from exemptions on foreign income, meaning they are not taxed on income earned outside Nigeria, as long as it is not brought into the country. They are generally not taxed on foreign income unless it is remitted into Nigeria. However, if foreign income is brought into Nigeria, it may be subject to Nigerian taxes.
This system is designed to attract foreign investors and expatriates by offering tax relief on foreign income, while ensuring that individuals with a substantial connection to Nigeria are taxed on their global earnings.
What About Taxation of Assets that Nigerians Have Abroad?
Nigerians residing in Nigeria are subject to taxation on their worldwide income. But Nigeria has Double Taxation Agreements (DTAs) with some countries to prevent the same income from being taxed twice. If a Nigerian taxpayer has paid tax on their foreign income in another country with which Nigeria has a DTA, they may be eligible for tax relief under the agreement.
However, if a Nigerian does not qualify to be called a “tax resident” of Nigeria, their wealth abroad would not be taxed except such wealth is brought into Nigeria.
Due to the fact Nigeria finds it difficult to tax income held in ‘offshore accounts’ and ‘investment portfolios’ abroad, many Nigerians have been able to wiggle their way out of remitting such taxes to the federal government. This deprives the FG of substantial revenue.
