Tax advice for internationally mobile clients

The UK remains an attractive destination for entrepreneurs, investors, executives and internationally mobile families.

But UK tax rules are increasingly complex, particularly for individuals with overseas income, investments, trusts, businesses or property.

The earlier planning starts, the more opportunities there are to structure your affairs efficiently before becoming UK tax resident.

We support clients with:

• Pre-arrival tax planning
• UK residence analysis under the Statutory Residence Test (SRT)
• Structuring overseas investments and assets where relevant for UK tax efficiency
• Foreign Income and Gains (FIG) regime advice
• Split-year treatment planning
• Double tax treaty considerations
• Offshore trust and company reviews
• UK inheritance tax exposure analysis
• UK tax reporting obligations

Our focus is not simply compliance. It is helping you move with clarity and confidence.

From 6 April 2025, the long-standing remittance basis regime for non-UK domiciled individuals was abolished and replaced with the new FIG regime.

The new regime works very differently.

Broadly, the FIG regime:

• Applies to individuals arriving in the UK after at least 10 consecutive non-UK tax years
• Provides a temporary exemption for qualifying foreign income and gains
• Applies for the first 4 UK tax years of residence only
• Must be actively claimed
• Does not apply automatically

Once the qualifying period ends, individuals are generally taxed on their worldwide income and gains in the UK.

For many internationally mobile individuals, this creates a much shorter planning window than under the previous rules.

That means timing your move correctly, structuring assets before arrival, planning income and capital events carefully, and reviewing long-term UK tax exposure much earlier can all have a significant impact on your overall tax position.

The rules are highly technical and interact with wider UK tax legislation, particularly inheritance tax and trust rules.

One of the biggest changes in the UK tax system is the move towards residence-based inheritance tax exposure. The concept of the “Long-Term Resident” is now central.

Broadly, an individual becomes a Long-Term Resident after being UK tax resident for at least 10 out of the previous 20 tax years.

Once this threshold is reached, the UK inheritance tax position can change significantly.

This could mean:

• Worldwide assets falling within UK inheritance tax
• Offshore structures becoming less effective
• Existing trust arrangements requiring review
• UK inheritance tax exposure continuing after leaving the UK (“tail” provisions)

“Tail” provisions: depending on how long you were UK resident, UK inheritance tax exposure may continue for up to 10 years after departure from the UK.

For internationally mobile families with significant wealth, trusts, property or overseas investments, these changes can materially impact succession and estate planning.

Leaving the UK does not necessarily mean leaving the UK tax net immediately.

Your UK tax position after departure depends on several factors, including:

• Your residence status under the Statutory Residence Test
• Split-year treatment availability
• Ongoing UK ties
• Temporary non-residence rules
• Long-term residence exposure
• UK source income and assets
• Future return plans

Many individuals mistakenly assume UK tax residence is determined simply by spending fewer than 183 days (or 90 days) in the UK.

In reality, the UK Statutory Residence Test is significantly more complex and also considers family connections, accommodation availability, work patterns, prior UK residence and time spent in the UK across multiple years.

Poorly planned departures can create unexpected UK tax liabilities, particularly around Capital Gains Tax, Inheritance Tax and anti-avoidance legislation.

Early advice allows time to structure matters properly before leaving.

Practical advice tailored to your circumstances.

We work with internationally mobile individuals, entrepreneurs, executives and families who require joined-up UK tax advice across personal, business and international matters.

Our services include:

• UK residence planning
• Statutory Residence Test reviews
• Split-year treatment advice
• Arrival and departure planning
• Temporary non-residence planning
• Double tax treaty analysis
• Foreign Income & Gains (FIG) regime
• FIG eligibility reviews
• Claim support
• Pre-arrival planning
• Foreign income and gains structuring
• Inheritance tax and wealth structuring
• Long-term residence reviews
• UK inheritance tax planning
• Trust structuring and restructuring
• Family wealth preservation strategies