International tax is not a single set of rules but an interaction between the domestic tax regimes of different countries, bilateral tax treaties and, in some cases, the specific rules that individual jurisdictions apply to non-residents or to overseas structures. For property, which is inherently fixed in location, the country in which the asset sits will almost always have a claim to tax, but that does not mean the position ends there.

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Our approach is to help clients understand how the UK tax rules apply to their international property interests, where overseas tax obligations may also arise, and how the interaction between different regimes affects the overall position. We work with clients to ensure that their arrangements are structured in a way that is both compliant and commercially sensible, taking into account their wider personal and financial circumstances where relevant.

We advise a range of clients on international tax matters connected to property and private client work, including non-UK residents acquiring, holding or disposing of UK property, UK residents with property interests in other jurisdictions, internationally mobile individuals navigating residence and domicile questions, families with cross-border estate and succession planning needs, and professional advisers supporting clients with international property or personal tax matters.

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Our advice is frequently delivered alongside solicitors, overseas advisers and other professionals, ensuring that the position is properly considered across all relevant jurisdictions.

Non-UK residents owning UK property are subject to a range of UK tax obligations that have expanded considerably in recent years, including non-resident capital gains tax on disposals of UK residential and commercial property, income tax on UK rental income, and in some cases inheritance tax where UK residential property is held through overseas structures.

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We advise non-resident individuals and entities on their UK tax obligations in connection with UK property, including the reporting and payment requirements that apply on disposal, the treatment of rental income and the compliance obligations that arise on an ongoing basis.

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Understanding the UK tax position clearly is essential for non-resident owners, particularly given the filing deadlines that apply to property disposals and the consequences of non-compliance.

UK residents are generally subject to UK tax on their worldwide income and gains, which means that property held overseas gives rise to UK tax obligations in the same way as domestic property, subject to any relief available under a double tax treaty with the country in which the property is situated.

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We advise UK resident individuals on the UK tax treatment of overseas property, including the declaration of rental income, the CGT treatment of disposals, the availability of double tax relief and the interaction between overseas property interests and the wider UK tax position.

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For clients who are not UK domiciled, the position may be more nuanced, and we can advise on how the remittance basis and domicile rules interact with overseas property interests.

For internationally mobile individuals and families, questions of tax residence and domicile are often central to how their property interests are taxed, both in the UK and overseas. The statutory residence test, the rules around domicile and deemed domicile, and the availability of the remittance basis all affect how UK and overseas property income and gains are brought into charge.

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We advise private clients on the interaction between residence, domicile and property taxation, helping individuals understand how their personal status affects their tax position and how changes in residence or domicile, whether planned or arising from changes in circumstances, may affect the treatment of their property interests.

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For families with assets and connections in more than one country, this advice is often an important part of wider estate and succession planning.

Property held through overseas structures, or transactions involving parties in multiple jurisdictions, can give rise to complex interactions between different tax regimes. Double tax treaties can provide relief in some circumstances but do not eliminate all overlap, and the UK's rules around offshore structures and the taxation of UK property held through non-UK entities have become increasingly detailed.

We advise on the tax implications of cross-border property structures, the application of double tax treaties to property income and gains, and the UK rules that apply to property held through offshore vehicles, helping clients understand where complexity arises and how it can be managed.

International tax and property is an area where the rules are technical, the interaction between different regimes can be difficult to navigate and the consequences of getting the position wrong can be significant, particularly where filing deadlines are tight or where structures have not been reviewed for some time.

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If you have property interests with an international dimension, or if you are an internationally mobile individual with questions about how your residence or domicile affects your property tax position, we would be happy to assist.