What Is Private Client Tax? Expert Private Client Tax Services for Ultra High Net Worth Individuals

At Connaught Law, our specialist private client tax team provides comprehensive private client tax services for ultra high net worth individuals, international families, and globally mobile high net worth clients navigating complex UK and international tax obligations. We understand what private client tax encompasses – sophisticated tax planning for substantial wealth requiring bespoke strategies, offshore structuring, and multi-jurisdictional coordination to achieve optimal tax efficiency while maintaining full regulatory compliance.

Private client tax planning involves strategic management of complex tax exposure for individuals with substantial assets, international investments, and sophisticated financial arrangements requiring expert guidance. Our ultra high net worth tax planning services address the unique challenges facing globally mobile individuals including the revolutionary 2025 non-domicile changes, offshore wealth structuring, international tax residency optimization, and comprehensive wealth protection strategies designed to preserve substantial family wealth across generations.

Whether you require urgent advice on the 2025 non-dom regime abolition, sophisticated offshore tax planning, international relocation strategies, or comprehensive inheritance tax mitigation, we provide discreet, expert private client tax advisory services tailored to your specific circumstances. Our hnw tax planning approach combines technical expertise with strategic commercial insight to deliver optimal outcomes for complex international tax situations requiring sophisticated, compliant solutions.

Critical Tax Changes April 2025: The UK non-domicile regime has been completely abolished and replaced with a residence-based system. Ultra high net worth tax mitigation now requires immediate restructuring of offshore arrangements. The new Foreign Income and Gains (FIG) regime provides only 4 years of relief for new arrivals, while the Temporary Repatriation Facility offers limited time to remit pre-April 2025 gains at 12-15% rates. Contact our private client tax specialists immediately for strategic guidance.

• Our Comprehensive Private Client Tax Services
• Non-Dom Tax Changes 2025 – Critical Implications
• Offshore Tax Planning and Wealth Structuring
• Tax Residency and International Planning
• Wealth Protection and Inheritance Tax Planning
• Our Transparent Fee Structure
• Why Choose Connaught Law for Private Client Tax
• Frequently Asked Questions

Our Comprehensive Private Client Tax Services

At Connaught Law, our private client tax service provides sophisticated tax advisory solutions for ultra high net worth individuals requiring complex multi-jurisdictional structuring and tax planning approaches. Our comprehensive private client services tax portfolio addresses every aspect of high net worth taxation including offshore wealth structuring, international tax residency optimization, and strategic compliance coordination designed to preserve and enhance substantial wealth through legitimate, compliant planning strategies.

What Is Private Client Tax Planning and Why Do You Need It?

Private client tax encompasses sophisticated tax planning services specifically designed for high net worth and ultra high net worth individuals with complex financial arrangements, international assets, and substantial wealth requiring expert guidance. Unlike standard tax advice, private client tax planning addresses multi-jurisdictional tax exposure, offshore wealth structuring, cross-border compliance obligations, and sophisticated estate planning strategies that require deep expertise in both UK and international tax law.

Ultra high net worth tax mitigation requires comprehensive understanding of complex tax interactions, international treaty networks, regulatory compliance requirements, and sophisticated structuring solutions that preserve wealth while maintaining full legal compliance. Our private client tax advisory approach recognises that effective wealth preservation requires strategic coordination between tax planning, legal structuring, and practical implementation aligned with your specific circumstances and long-term objectives.

Revolutionary 2025 Tax Changes – Expert Private Client Tax Guidance

The complete abolition of the UK non-domicile regime from April 2025 represents the most significant change to private client tax in over two centuries, requiring immediate strategic response from ultra high net worth individuals and their families. Our hnw tax planning expertise includes urgent guidance on navigating these fundamental changes including the new Foreign Income and Gains (FIG) regime, Temporary Repatriation Facility opportunities, and residence-based inheritance tax implications affecting internationally mobile wealth.

Our 2025 tax change expertise encompasses comprehensive analysis of how these reforms affect existing private client tax structures, immediate planning opportunities, and long-term wealth preservation strategies. We coordinate with international tax advisors, offshore trustees, and wealth managers to ensure comprehensive understanding of cross-border implications while developing strategic responses protecting your interests throughout this period of unprecedented change following current UK tax rate changes.

Multi-Jurisdictional Structuring and Tax Planning

We provide sophisticated multi-jurisdictional structuring and tax planning services addressing the complex requirements of internationally diversified wealth including offshore trusts, special purpose vehicles, international holding structures, and cross-border investment arrangements. Our offshore structuring expertise recognises that effective international tax planning requires deep understanding of multiple jurisdictions, treaty networks, and regulatory compliance requirements affecting globally mobile individuals.

Our approach combines UK tax expertise with international coordination ensuring optimal structuring approaches that achieve tax efficiency while maintaining full compliance with UK and international obligations. We work closely with our tax advisory specialists to develop integrated strategies addressing both immediate tax planning objectives and long-term wealth preservation goals through sophisticated, compliant structures.

Tax Planning Area	2025 Changes	Planning Opportunities	Action Required
Non-Dom Status	Completely abolished April 2025	FIG regime (4 years), Temporary Repatriation Facility (12-15%)	Immediate restructuring required
Offshore Trusts	Tax protections removed for most structures	Grandfathering rules, alternative structures	Urgent review and restructuring
Inheritance Tax	Residence-based system (10+ years)	Relocation planning, structure timing	Long-term residency assessment
Capital Gains	Rebasing to April 2017 values available	Asset valuation, disposal timing	Immediate valuation and records

Non-Dom Tax Changes 2025 – Critical Implications

The complete abolition of the UK non-domicile regime from 6 April 2025 creates urgent planning requirements for ultra high net worth individuals and their families requiring immediate private client tax service intervention. The new residence-based system fundamentally alters how UK tax applies to global income and gains, requiring immediate strategic response to protect substantial wealth and maintain tax efficiency through legitimate planning structures.

Foreign Income and Gains (FIG) Regime

The new FIG regime provides four years of relief from UK tax on foreign income and gains for individuals who become UK resident after 10 consecutive years of non-residence. This limited relief represents the only remaining tax advantage for globally mobile individuals, but requires careful private client tax planning to maximise effectiveness and coordinate with other ultra high net worth tax planning strategies.

Our FIG regime expertise includes comprehensive analysis of eligibility requirements, strategic timing of UK arrival, and coordination with employment arrangements including Overseas Workday Relief planning. We assist clients in understanding the complex interaction between the FIG regime and existing structures while developing strategies that preserve tax efficiency during the four-year relief period and beyond.

Temporary Repatriation Facility – Limited Time Opportunity

The Temporary Repatriation Facility (TRF) provides a unique three-year opportunity to remit pre-April 2025 foreign income and gains at substantially reduced rates: 12% for 2025/26 and 2026/27, then 15% for 2027/28. This facility applies to unremitted gains held personally or within offshore trust structures, providing significant savings compared to standard UK tax rates reaching 45%.

Our TRF planning includes comprehensive analysis of qualifying amounts, strategic timing of repatriation, and coordination with existing Business Investment Relief arrangements. We work closely with our tax and corporate specialists to evaluate whether TRF elections provide optimal outcomes compared to alternative strategies including ongoing offshore planning or alternative jurisdictional planning approaches.

Immediate Action Required: Review all pre-April 2025 offshore income and gains for TRF eligibility
Strategic Timing: Coordinate TRF elections with other tax planning strategies and cash flow requirements
Trust Structures: Evaluate TRF availability for offshore trust distributions and capital payments
Record Keeping: Comprehensive documentation required for HMRC compliance and audit protection
Professional Guidance: Expert advice essential for optimising TRF elections and avoiding pitfalls

Offshore Tax Planning and Wealth Structuring

Our offshore tax planning private client services address the sophisticated requirements of internationally diversified wealth through compliant structuring solutions that navigate the complex interaction between UK tax law and international regulations. We provide comprehensive guidance on offshore trusts, international holding structures, and cross-border investment arrangements designed to achieve optimal tax efficiency while maintaining full regulatory compliance for ultra high net worth clients.

International Wealth Management and Asset Protection

International wealth management requires sophisticated understanding of multiple tax jurisdictions, treaty networks, and regulatory compliance requirements affecting globally mobile individuals. Our approach combines UK tax expertise with international coordination ensuring optimal structuring approaches that achieve tax efficiency while maintaining full compliance with UK and international obligations including Common Reporting Standard (CRS) and Foreign Account Tax Compliance Act (FATCA) requirements.

We coordinate with international tax advisors, offshore trustees, and wealth managers to develop integrated strategies addressing both immediate tax planning objectives and long-term wealth preservation goals. Our international wealth management services include offshore trust planning, international holding structures, and cross-border investment arrangements tailored to your specific circumstances and objectives.

Offshore Bond and Insurance Wrapper Strategies

Offshore bonds and insurance wrappers have gained significant importance following the 2025 non-dom changes, offering legitimate tax deferral, simplified reporting, and partial tax-free withdrawal opportunities within established regulatory frameworks. These structures provide valuable planning opportunities for high net worth individuals seeking tax-efficient wealth accumulation and preservation through compliant investment vehicles.

Our offshore bond expertise includes comprehensive analysis of insurance wrapper structures, investment management arrangements, and withdrawal strategies designed to optimise tax efficiency while maintaining regulatory compliance. We work closely with specialist offshore providers to develop tailored solutions addressing your specific investment objectives and tax planning requirements through sophisticated, compliant structures.

Tax Residency and International Planning

Strategic tax residency planning provides essential tools for managing global tax exposure while maintaining lifestyle and business objectives for ultra high net worth individuals. Our residency planning private client services address the complex requirements of the UK Statutory Residence Test, international tax treaties, and cross-border compliance obligations affecting globally mobile individuals and their families requiring sophisticated private client tax planning.

Statutory Residence Test and UK Tax Exposure

The UK Statutory Residence Test creates complex requirements for determining UK tax residence based on day counting, accommodation ties, and other connection factors. Our expertise includes comprehensive analysis of residence patterns, strategic planning of UK presence, and coordination with international tax obligations to achieve optimal tax efficiency while maintaining required business and personal activities.

We provide detailed guidance on residence planning strategies including split-year treatment, temporary non-residence rules, and international relocation planning following HMRC guidance on foreign income taxation. Our approach recognises that effective residency planning requires coordination with employment arrangements, family circumstances, and business requirements while maintaining detailed records supporting residence positions through potential HMRC enquiries.

International Relocation and Cross-Border Planning

International relocation creates complex tax planning opportunities and obligations requiring expert private client tax guidance to navigate successfully. Our private client relocation planning services address pre-departure tax planning, arrival strategies, and ongoing compliance requirements affecting individuals moving to or from the UK while maintaining substantial international interests and activities.

We coordinate with international tax advisors, immigration specialists, and wealth managers to develop comprehensive relocation strategies addressing tax, legal, and practical considerations. Our relocation planning includes analysis of tax treaty benefits, timing of asset transfers, and coordination with existing structures to achieve optimal outcomes throughout the relocation process.

Wealth Protection and Inheritance Tax Planning

Strategic wealth protection and inheritance tax planning provides essential ultra high net worth tax mitigation tools for preserving substantial wealth across generations while maintaining family financial security and business continuity. Our inheritance tax planning private client services address the complex requirements of UK inheritance tax law, international estate planning, and cross-border succession issues affecting internationally mobile families requiring sophisticated wealth preservation strategies.

Inheritance Tax Changes and Residence-Based System

The introduction of a residence-based inheritance tax system from April 2025 fundamentally alters how UK inheritance tax applies to internationally mobile individuals. Under the new system, individuals who have been UK resident for 10 or more of the previous 20 years become subject to UK inheritance tax on worldwide assets, with continued exposure for up to 10 years after leaving the UK.

Our inheritance tax planning expertise includes comprehensive analysis of the new residence-based system, strategic timing of international relocations, and development of compliant estate planning structures that optimise inheritance tax efficiency while maintaining family wealth preservation objectives through sophisticated, legitimate planning strategies.

Estate Planning and Family Wealth Preservation

Estate planning for internationally mobile families requires sophisticated understanding of UK inheritance tax law, international estate planning principles, and cross-border succession issues. Our estate planning private client services address comprehensive wealth transfer strategies including will planning, trust structures, and succession arrangements designed to preserve family wealth while achieving optimal tax efficiency.

We coordinate with international estate planning specialists, family office professionals, and wealth managers to develop integrated estate planning strategies addressing both immediate succession planning objectives and long-term family wealth preservation goals. Our estate planning includes analysis of international tax treaties, succession law issues, and coordination with existing family structures to achieve optimal outcomes for multi-generational wealth transfer.

Our Transparent Fee Structure

Connaught Law provides transparent, competitive pricing for private client tax services aligned with the complexity and value of sophisticated tax planning for ultra high net worth individuals. Our fee structure recognises that effective private client tax planning requires substantial expertise, ongoing monitoring, and strategic coordination with other advisors to achieve optimal outcomes for complex international tax situations.

Comprehensive Private Client Tax Planning Fees

Our private client tax planning fees are structured to provide certainty and value for sophisticated tax planning services including offshore structuring, residency planning, and wealth protection strategies. We provide detailed fee estimates for specific planning projects while offering ongoing advisory relationships for clients requiring continuous tax planning support throughout changing circumstances and evolving tax law requirements.

Initial Consultation: Comprehensive tax planning assessment with detailed analysis of your specific circumstances
Project-Based Fees: Transparent pricing for specific tax planning projects with clear scope and deliverables
Ongoing Advisory: Annual advisory relationships for continuous tax planning support and monitoring
Specialist Expertise: Competitive rates for sophisticated private client tax planning aligned with guideline hourly rates
International Coordination: Integrated fee arrangements for cross-border tax planning requiring international coordination

Why Choose Connaught Law for Private Client Tax

At Connaught Law, our private client tax team combines deep technical expertise with strategic commercial understanding to deliver exceptional outcomes for ultra high net worth individuals facing complex international tax challenges. Our track record demonstrates consistent success in sophisticated tax planning projects, HMRC negotiations, and complex international structuring arrangements while providing discreet, professional service aligned with the highest standards of client care and confidentiality.

We understand that private client tax planning affects not only immediate tax efficiency but also long-term wealth preservation, family security, and business continuity objectives. Our client-focused approach provides regular communication, clear explanations of complex tax implications, and strategic guidance helping you make informed decisions about your wealth while pursuing optimal tax outcomes through legitimate, compliant planning strategies.

Proven Expertise in Complex Private Client Tax Planning

Our private client tax specialists have successfully handled sophisticated tax planning projects for ultra high net worth individuals including international relocations, offshore structuring arrangements, and complex succession planning strategies. We leverage extensive experience with HMRC, international tax authorities, and specialist advisors to deliver optimal outcomes while maintaining the highest standards of professional service and client confidentiality.

Client testimonials consistently highlight our ability to handle sensitive tax planning circumstances with discretion and professionalism while achieving outstanding results through sophisticated, compliant strategies. Our approach combines thorough technical analysis with strategic commercial insight, ensuring optimal tax outcomes while maintaining family wealth preservation objectives and business continuity requirements through professional, expert guidance.

Frequently Asked Questions

How do the 2025 non-dom tax changes affect my offshore wealth?

The non-domicile regime has been completely abolished from April 2025. UK residents are now taxed on worldwide income and gains regardless of domicile status. New arrivals may qualify for the 4-year Foreign Income and Gains (FIG) regime, while existing non-doms can use the Temporary Repatriation Facility to remit pre-April 2025 gains at 12-15% rates. Our private client tax solicitors London team provides urgent strategic guidance on these fundamental changes.

What is the Foreign Income and Gains (FIG) regime and who qualifies?

The FIG regime provides 4 years of relief from UK tax on foreign income and gains for individuals who become UK resident after 10 consecutive years of non-residence. This applies to both new arrivals and returning UK nationals. The regime allows foreign income and gains to be brought to the UK without additional tax during the 4-year period, subject to making appropriate elections.

Should I use the Temporary Repatriation Facility for offshore gains?

The Temporary Repatriation Facility offers reduced tax rates of 12% (2025/26-2026/27) and 15% (2027/28) on pre-April 2025 foreign income and gains. This compares favourably to standard UK tax rates up to 45%. However, elections require careful analysis of qualifying amounts, timing considerations, and coordination with other tax planning strategies. Our high net worth tax planning London specialists provide detailed analysis of TRF benefits for your specific circumstances.

How do the new inheritance tax rules affect offshore trusts?

The residence-based inheritance tax system makes individuals liable for UK inheritance tax on worldwide assets after 10 years of UK residence. Offshore trusts lose their excluded property trust status unless grandfathered before October 2024. Many existing offshore trust structures require urgent review and potential restructuring to maintain tax efficiency and wealth protection objectives.

What offshore structures remain effective after the 2025 changes?

Offshore bonds and insurance wrappers have gained significant importance, offering legitimate tax deferral, simplified reporting, and partial tax-free withdrawals. Some offshore trusts retain benefits for non-UK resident settlors or within specific grandfathering arrangements. Our offshore tax advice London includes comprehensive analysis of alternative structures suitable for your specific circumstances and objectives.

Can I still benefit from capital gains tax rebasing?

Current and past remittance basis users can elect to rebase personally held foreign assets to their April 2017 values for capital gains tax purposes. This rebasing opportunity applies to assets held on 5 April 2017 and can significantly reduce capital gains tax liability on future disposals. Immediate professional valuations and record-keeping are essential to secure this benefit.

How do I maintain tax efficiency for international investments?

International investment tax efficiency requires strategic structuring through compliant offshore arrangements, optimal use of tax treaties, and careful timing of investment gains and income. Our private client tax advice London includes comprehensive analysis of international holding structures, offshore bonds, and investment timing strategies designed to achieve optimal tax outcomes while maintaining full regulatory compliance.

Should I consider relocating from the UK following the 2025 changes?

International relocation may provide significant tax benefits for individuals with substantial offshore wealth, but requires careful analysis of residence rules, exit taxes, and long-term implications. The inheritance tax residence-based system creates continued exposure for up to 10 years after leaving the UK. Our specialists provide comprehensive relocation planning including pre-departure tax strategies and ongoing compliance requirements.

Expert Private Client Tax Support

✓ 2025 Non-Dom Changes Expertise

Urgent strategic guidance on FIG regime qualification, Temporary Repatriation Facility opportunities, and residence-based inheritance tax implications

✓ Sophisticated Offshore Planning

International wealth structuring through compliant offshore arrangements, tax treaty optimization, and cross-border investment strategies

✓ Comprehensive Wealth Protection

Strategic tax planning, inheritance tax mitigation, and family wealth preservation through sophisticated, compliant structuring solutions

Private client tax solicitors London expertise requires sophisticated understanding of complex UK and international tax law, offshore planning strategies, and wealth protection structures to navigate the fundamental changes affecting high net worth individuals and internationally mobile families following the 2025 non-domicile regime abolition.

With revolutionary tax law changes from April 2025 eliminating the non-domicile regime and introducing residence-based taxation, expert private client tax advice proves essential for protecting substantial wealth, optimising the limited relief opportunities available, and developing long-term strategies maintaining tax efficiency through compliant planning approaches.

Contact our private client tax solicitors London team at Connaught Law for immediate expert guidance. Our private client tax specialists provide comprehensive support for high net worth individuals requiring sophisticated tax planning, offshore structuring, and wealth protection strategies, ensuring optimal outcomes for your complex international tax requirements.