BHP Tax Intelligence - Issue 1

September 23, 2026

I’m pleased to share the first consolidated issue of BHP Tax Intelligence | Property, Private Wealth & Investment which you can download here.

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This publication is deliberately different from our case-law reports.

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Our SDLT, LTT and LBTT Case Reports, FTT Private Client Tax Watch and Beyond Tax: Property Law Developments primarily examine decided cases and legal developments.

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BHP Tax Intelligence looks beyond the cases.

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It considers the wider tax, wealth, property and investment questions that may shape decisions before they ever reach a tribunal or court.

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In this issue, we look at nine areas:

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• Wealth on the move – what the available data can, and cannot, really tell us about wealthy individuals leaving the UK.

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• High-value homes – who should be allowed to defer the proposed High Value Council Tax Surcharge, and how hardship should be identified.

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• Offshore trusts – when does a trust still serve a useful family or governance purpose, and when has the structure simply become expensive inertia?

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• Taxes on wealth – should the UK fix weaknesses in existing taxes before introducing another tax on wealth?

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• Inheritance tax and pensions – why the April 2027 changes require families to reconsider the order in which assets are spent, retained or gifted.

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• Buy-to-let – whether the sector is moving from a relatively passive investment model towards a more operational and professionally managed business.

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• Annuities – why guaranteed retirement income is becoming strategically relevant again for some older and wealthier pension holders.

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• Family offices – why jurisdiction choice starts with residence, control, substance and decision-making rather than a licence or a low headline tax rate.

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• Scotland and high-value property – whether new Council Tax bands should be assessed alongside the highly concentrated residential LBTT base.

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The aim is not to produce another technical update.

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Each article asks a broader question, explains the issue in straightforward language and ends with a BHP Summary setting out our view of what matters.

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The underlying sources are identified and attributed. BHP’s commentary is separately expressed and intended to challenge assumptions, encourage debate and prompt better questions.

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This is general commentary and opinion, not individual tax, legal, investment or other professional advice.

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The full issue is attached.

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I hope you find it interesting.

Simon Howley