The verdict
Headline personal rates sit close together. The UK reaches 45% outside Scotland and 48% in Scotland, with National Insurance on employment. Australia reaches 45% plus a 2% Medicare levy. Neither is a light place to take a salary.
The estate contrast is sharper. From 6 April 2025 the UK uses a long-term residence test for inheritance tax, so people who have been UK-resident for long enough can have worldwide assets in the 40% IHT net. Australia has no federal inheritance or estate tax, though superannuation death benefits and later CGT on inherited assets can still arise.
Choose Australia if succession and GST matter more than London market access. Choose the UK when English-law finance, a 19% small-profits company rate or a four-year foreign-income-and-gains claim after ten years outside the UK is the real planning point. Residence, treaty and UK-source work still need modelling.
How to read this comparison
The United Kingdom and Australia both tax residents on worldwide income and both put a 45% headline on high personal earnings. The useful comparison is not โwhich country is low taxโ. It is which extra layer you are willing to live with.
On employment, National Insurance in the UK and the 2% Medicare levy in Australia both sit on top of income tax. A founder taking a large salary will feel expensive in either place. Company profits split more cleanly. The UKโs 19% small-profits rate and 25% main rate undercut Australiaโs 25% base-rate entity and 30% general company rates. Shareholder outcomes then diverge again: UK dividends from April 2026 are 10.75%, 35.75% or 39.35% above a GBP 500 allowance, while Australia uses franking credits so company tax can be credited to the resident shareholder.
Capital gains are closer than the labels suggest. From 6 April 2026 UK individuals generally pay 18% or 24% after a GBP 3,000 annual exempt amount. Australia folds gains into income tax, often with a 50% discount after 12 months, so a top-rate individual can still face a high effective charge. Indirect tax is simpler: Australian GST is 10% and UK VAT is 20%.
The estate point is the one that should stop a long-stay decision being made on income tax alone. The UK charges 40% inheritance tax above frozen nil-rate bands, and long-term UK residents can bring worldwide assets into that charge. Australia abolished death duties. That does not make an Australian estate administratively free โ superannuation death benefits and later CGT still appear โ but it is not a 40% worldwide inheritance tax. A qualifying new UK resident may claim the four-year foreign-income-and-gains regime after ten years outside the UK. That relief does not rewrite IHT for someone who later becomes a long-term UK resident.