For substantial and international wealth, UK tax is no longer a filing exercise — it's a design problem: residence, structures, succession and disclosure interacting across borders, under rules that have just been rewritten. Connaught Law's private client tax lawyers act for HNW and UHNW individuals, families and their offices, in the UK and offshore.
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How We Can Help
Residence & the New Regime
The old non-dom world is gone: the remittance basis has been replaced by a residence-based regime, with a limited window of relief for new arrivals' foreign income and gains and transitional rules for those the change caught mid-plan. Everything now hangs on residence under the statutory residence test — day-counts, ties, split years — and on sequencing arrival, realisations and remittances correctly. We advise on exactly that sequencing, before the tax year does it for you.
Relocating to or from the UK
UHNW relocation is a single project wearing three disguises — tax, immigration and property. We plan the tax entry position alongside residence and citizenship options and the property acquisition, or the exit: ceasing UK residence cleanly, what remains taxable here, and the timing that separates an expensive departure from an efficient one. One firm, one coordinated move.
Offshore Structures & Trusts
Offshore trusts, companies and foundations built under the old rules need reviewing under the new ones — protections have narrowed, charges have shifted, and structures that once made sense can now cost more than they save. We review, restructure and, where right, unwind: always against the UK anti-avoidance framework and the register and reporting duties that now surround offshore holdings, including UK property held through entities.
Inheritance Tax & Succession
IHT has gone residence-based too, reaching long-term UK residents' worldwide estates — a fundamental change for international families — while lifetime planning still works: gifts and the seven-year clock, spouse and charity exemptions, business reliefs under tightening rules, and wills coordinated across every jurisdiction that touches the family. Succession planned early is measured in percentages saved; planned late, in disputes. Our HNW family team handles the marital side of the same wealth.
HMRC Disclosure & Defence
Global data-sharing means offshore affairs are visible to HMRC by default — and the Worldwide Disclosure Facility and related routes reward those who correct positions before the nudge letter becomes an investigation. We prepare disclosures, defend enquiries into residence, domicile history and offshore structures, and negotiate settlements — under legal privilege throughout, which in this territory is not a technicality.
Family Offices & Advisers
We work as the UK tax-law seat at the family's table: alongside offshore trustees, private banks and accountants across jurisdictions, giving the UK legal analysis that anchors the global plan — and drafting the structures, wills and agreements that implement it. Discretion is assumed; responsiveness across time zones is the service standard.
How We Work
Every engagement starts with the map: residence history and trajectory, structures and what they hold, family and succession intentions — then a written plan sequencing what happens when, because in the new regime timing is the tax planning. Implementation follows in-house: structures, wills, property and immigration executed by the same firm, with HMRC compliance built in rather than retrofitted.
Why Connaught Law
01Fluent in the new regimePost-non-dom planning is different planning. Ours is built on the current rules, not the remembered ones.
02The whole relocationTax, immigration, property and family wealth in one firm — a move planned as one project.
03Senior attention throughoutYour affairs are handled by our experienced team directly — one relationship, absolute discretion.
04Privileged and defensibleAdvice under legal privilege, positions built to withstand HMRC's interest in exactly this wealth bracket.
Fee structures are set out on our fees page — scoped per engagement, agreed before work begins.
Frequently Asked Questions
What replaced the non-dom regime?
A residence-based system: the remittance basis is gone, new arrivals get a time-limited relief window on foreign income and gains, and long-term UK residence now drives exposure — including, over time, to inheritance tax on worldwide assets. Anyone whose planning was built on domicile needs it reviewed against the current rules; the transitional provisions still reward those who act deliberately.
I'm moving to the UK — when should tax planning start?
Before you become UK resident, ideally a tax year out: the relief window, pre-arrival realisations, structure reviews and the residence test's day-counting all work best prospectively. Planning after arrival closes options that were free the year before. The same is true in reverse for leaving — the departure year is the plan.
Are my offshore trusts still effective?
They need checking rather than assuming: recent reforms narrowed protections, changed charges and expanded reporting, and structures that were efficient under the old regime can now be neutral or worse. A structure review against current law — keep, restructure or unwind — is the single most common piece of work we do for international families right now.
HMRC has written about my offshore affairs — how serious is it?
Treat every such letter as serious and answer none of it unadvised: data-sharing means HMRC usually writes because it already holds information, and the response route — disclosure facility, correction or defence — should be chosen strategically. Handled early and properly, most matters settle civilly; ignored, they escalate. The conversation with us is privileged.
International wealth, UK questions?
Tell us your residence picture and what you hold. We'll map your position under the new rules and sequence the moves — in confidence, before the tax year decides for you.
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