Expert tax advice for non-UK domiciled and non-resident individuals. We navigate complex international tax issues including offshore structures, domicile status, and the remittance basis for optimal tax planning.
Non-Resident Taxation
International tax planning for non-UK residents and non-domiciled individuals requires specialized expertise to navigate the complex UK tax system. We provide comprehensive advice on overseas income and capital, offshore structures, and cross-border tax implications for individuals with international connections.
Domicile and Residence Status
Critical determinations include:
- UK domicile status assessment
- Residence testing for individuals
- Corporate tax residence
- Trust residence determination
- Deemed domicile rules
- Statutory residence test application
UK Tax Planning for Non-Domiciled Individuals
- Remittance Basis: Optimizing the remittance basis regime for foreign income and gains
- Income Tax Planning: Structuring overseas income to minimize UK tax exposure
- Capital Gains Tax: Managing foreign asset disposals and rebasing elections
- Annual Tax Charges: Planning for the remittance basis charge after long-term residence
- Clean Capital Strategies: Segregating funds for tax-efficient UK remittances
Offshore Trust Structures
Comprehensive trust planning:
- Establishing new offshore trusts
- Trust beneficiary taxation
- Capital distributions planning
- Trustee residence changes
- Protected trust elections
- Trust restructuring and migrations
Corporate Structures
International company planning:
- Offshore company formations
- UK property holding structures
- ATED (Annual Tax on Enveloped Dwellings)
- Capital gains tax on UK property
- Corporation tax planning
- Liquidation and restructuring
Pre-Arrival Planning
For individuals moving to the UK:
- Tax residence planning
- Asset restructuring advice
- Employment tax considerations
- Pension transfer options
- Investment portfolio review
- Family wealth structures
Departure Planning
For those leaving the UK:
- Exit tax implications
- Temporary non-residence rules
- Split-year treatment
- Asset disposal timing
- Pension considerations
- Future UK connections
Inheritance Tax Planning
- Domicile impact on IHT
- Excluded property trusts
- UK property IHT charges
- Business property relief
- Pre-owned asset planning
- Cross-border estates
Double Taxation Relief
Managing international tax exposure:
- Treaty claim procedures
- Foreign tax credit relief
- Mutual agreement procedures
- Hybrid mismatch rules
- Tie-breaker provisions
- Certificate of residence
UK Family Home
Special considerations for:
- Principal private residence relief
- Non-resident CGT charges
- SDLT surcharges
- Trust ownership structures
- Occupation by family members
- Future planning options