International Private Client

Cross-border private client planning has changed materially with the move from domicile-based rules to a more residence-based regime from 6 April 2025.

Individuals with international connections, offshore structures or changing residence patterns require coordinated advice across income tax, capital gains tax and inheritance tax.

We advise internationally mobile individuals and families on managing their UK tax position in a way that is structured, compliant and aligned with wider personal and commercial objectives.

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A Changing International Tax Landscape

The UK tax framework for internationally connected individuals has evolved significantly, with a shift away from traditional domicile-based rules towards a more residence-focused approach.

These changes have implications for:

  • Individuals moving to or from the UK
  • Former non-domiciled individuals
  • Those with offshore income, gains or structures
  • Families with assets across multiple jurisdictions

Understanding how these rules apply in practice is essential to managing exposure and ensuring compliance.

Who We Act For

We advise a range of clients with international connections, including:

  • Internationally mobile individuals and families
  • Former non-dom clients and returning UK residents
  • Families with offshore trusts or holding structures
  • Business owners and property owners with multi-jurisdictional interests

Our work is often coordinated alongside other professional advisers, both in the UK and internationally.

Residence, Remittance and Legacy Issues

Changes to the UK tax regime have brought renewed focus to residence status and historic remittance positions.

We advise on:

  • Residence and non-residence issues
  • Former Non-Dom considerations and legacy remittance planning
  • Reviewing historic positions in light of current legislation
  • Managing exposure to UK tax on worldwide income and gains

Ensuring that historic structures and decisions are properly understood is often a key part of current planning.

Offshore Structures and Anti-Avoidance Rules

Offshore structures remain a central feature of many international arrangements, but are subject to complex UK tax rules.

We advise on:

  • Offshore trusts and settlor planning
  • Transfer of assets abroad and related anti-avoidance provisions
  • The UK tax treatment of offshore income and gains
  • Ongoing compliance and reporting obligations

Given the level of HMRC scrutiny in this area, careful analysis is essential to ensure that structures remain effective and compliant.

Cross-Border Succession and Wealth Planning

Succession planning in an international context often involves additional complexity, particularly where assets, family members or structures span multiple jurisdictions.

Our work includes:

  • Cross-border succession and family wealth planning
  • Coordinating UK tax advice with overseas legal frameworks
  • Advising on the interaction between inheritance tax and other jurisdictions
  • Structuring arrangements to support long-term family objectives

A coordinated approach is often required to ensure that planning is effective across all relevant jurisdictions.

Our Approach

International private client work requires a clear understanding of both UK tax rules and how they interact with other jurisdictions.

We take a practical and coordinated approach, focusing on:

  • Providing clear guidance on complex and evolving rules
  • Identifying risks and opportunities within existing structures
  • Supporting clients through changes in residence or circumstances
  • Working alongside other advisers to deliver joined-up advice

Our focus is on ensuring that planning remains robust, compliant and aligned with long-term objectives.

Speak to Our Private Client Team

International private client planning involves navigating a complex and evolving tax landscape, particularly in light of recent changes to the UK’s approach to residence and offshore structures. For individuals and families with cross-border connections, understanding how these rules apply is essential to managing tax exposure and ensuring compliance.

Whether you are moving to or from the UK, reviewing existing offshore structures, or planning for the next generation, taking coordinated advice can help ensure that your affairs are structured effectively across jurisdictions.

If you would like to discuss your position or require support with international tax planning, we would be happy to assist.

Contact Us

Frequently Asked Questions

How does UK property affect a non-UK resident client?

UK property brings UK tax with it. Non-UK residents can face UK income tax on rents, non-resident CGT on disposals and UK IHT exposure on some residential property structures. There may also be SDLT, LTT and LBTT surcharges on acquisition and short reporting deadlines on disposal. Owning UK property is often the point where an international client becomes very visible to the UK tax system.

Do offshore trusts still work?

They can, but not on autopilot. Offshore trusts remain useful in some international planning, but UK anti-avoidance rules, reporting obligations and the post-2025 residence-based regime all need proper review. The question is not whether the trust worked when it was set up. The question is whether it still works now, for the people and assets currently involved.

What changed for internationally connected individuals from April 2025?

The UK moved away from the old domicile-based regime and towards a residence-based system. The new rules include the four-year foreign income and gains regime for qualifying individuals coming to the UK after a period of non-UK residence. Former non-dom clients, returners, offshore trust users and internationally mobile families should review their position. Old planning can become wrong without making a noise.

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Let's work together!

Whether you need advice on a specific matter or wish to discuss how we can support your business or personal needs, we're here to help.

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