UK tax planning for international clients
The UK is a popular place to do business, own property, live and raise a family. It continues to attract people from around the world.
If you are looking to relocate to the UK or if you are already resident here, the ever increasing complexity of UK tax laws can be overwhelming. We have a team of specialist solicitors who can guide you through these rules in a practical and accessible way.
In particular, we can assist with:
- Tax planning in advance of an arrival in, or departure from, the UK
- analysing clients’ domicile and residency positions
- creating appropriate and tax efficient structures for owning UK residential and commercial property
- preparing Wills and Lasting Powers of Attorney, taking into account any foreign assets and/or beneficiaries
- charitable giving
- establishing and administering onshore and offshore trusts
- understanding transparency obligations and ensuring compliance with different reporting regimes.
James McNeile, Partner
James specialises in trusts, onshore and offshore planning for UK and foreign domiciled individuals, protecting farms, art and heritage assets.Contact James
Laura Kearns, Solicitor
Laura advises on a broad range of private client and tax matters for domestic and international clients including wills, trusts, and tax advice.Contact Laura
International lawyers with global connections
- Expert team to advise international clients on tax and estate planning issues.
- member of Interleges an international network of firms to help clients.
- experts in advising on the taxation of international high net worth individuals, buying or selling high-value residential property and international family law to provide a joined-up service.
Pre-arrival/departure tax planning
If you are considering relocating to the UK, it is important to take specialist tax advice in advance of your arrival to ensure that you structure your wealth in an efficient manner, making use, where appropriate, of the remittance basis of taxation, clean capital accounts and offshore trust structures to protect your overseas assets from the UK tax net.
We have particular expertise in advising clients on their residence position, taking into account the common law rules pre 5 April 2013 , the statutory residence test which has been in force since and split-year tax treatment.
We also advise individuals who are considering leaving the UK on the tax implications of their departure, ensuring they minimise their exposure to UK tax to the extent this is desirable.
Non-UK domiciled individuals
There have also been significant changes to the taxation of non-UK domiciled individuals and offshore trusts over the past few years and we are well placed to help you navigate these complexities.
We frequently advise our clients on their domicile position (whether they are arriving in the UK or seeking to obtain a domicile of choice elsewhere) and can help long-standing UK residents plan effectively before becoming deemed domiciled in the UK.
Our team can work with you to establish structures (including flexible trusts, companies and partnerships) to manage your wealth in a tax efficient manner and preserve it for future generations. This is particularly important if you want to pass wealth down to the next generation in a measured way. We can help to ensure there is suitable governance in place to regulate how your wealth will be transferred and to protect against family disputes.
We also assist individuals and families in unwinding structures which no longer offer the tax protection they once afforded.
UK property ownership
In recent years there have been major developments in the tax laws governing property ownership in the UK . If you are considering investing in UK residential or commercial property, we can advise you on the most appropriate holding structure, bearing in mind your plans for the property and the application of income tax, capital gains tax (including non-resident and ATED-related CGT), inheritance tax, stamp duty land tax and ATED.
Wills and Lasting Powers of Attorney
Our team works with both non-UK resident/domiciled and UK resident/domiciled individuals to put Wills and other testamentary documents in place to deal with their worldwide assets. In drafting Wills, we carefully consider any foreign assets, forced heirship regimes and advise on practical issues which can be faced when trying to prove a Will in a foreign jurisdiction.
As a founding member of the Interleges network, we work with a strong network of lawyers around the world to ensure that any foreign Wills sit effectively alongside the UK Will.
We also advise on Lasting Powers of Attorney (LPA) and other capacity issues, often where there is an international element (for example, where the LPA is for a non-UK resident individual or for a UK individual with foreign assets).
Advising settlors, trustees, protectors and beneficiaries of UK-resident and non-UK resident trusts
We offer advice to clients on the establishment of trusts, whether onshore or offshore and advise trustees and protectors (both lay and professional individuals as well as professional trust companies) on their duties and obligations. We can also assist them in the day-to-day administration of their trusts.
We can also establish bespoke private trust companies to act as trustee and advise on an appropriate ownership and governance structure.
With the advent of FATCA, CRS and other reporting regimes, there is greater global focus on financial transparency. We assist individuals, families and trustees to ensure they meet their ever increasing compliance and reporting obligations.
We also help clients regularise their UK tax position where necessary, taking into account the progressively more draconian penalty regimes being implemented by HMRC.