Overview

Our international tax lawyers advise individuals resident in the UK but domiciled elsewhere and individuals not resident in the UK on all aspects of UK taxation.

In light of recent changes and further proposed changes to tax law in the UK, UK resident non-domiciliaries face complex challenges. Our specialist international tax lawyers help clients protect their assets while dealing with these changes. Our team advises on the implications of being taxed on the remittance basis and on planning clients can undertake prior to becoming deemed domiciled for inheritance tax purposes.  

Our international tax lawyers advise non-residents who are planning to move to the UK on the UK residency rules and how to organise their affairs in a tax efficient manner prior to moving.  

We also advise non-residents on structures for the protection of their worldwide assets. In particular, we can advise on the interaction between forced heirship rules and the creation of succession planning vehicles such as offshore trusts. We work with high net worth and ultra high net worth clients around the world, including clients in Europe, the US, the Middle East, Asia, Latin America and Australia.

Our international tax lawyers provide extensive legal advice to those who own, or who are looking to purchase, real estate in the UK. We ensure our clients understand the implications of personal ownership, as well as ownership through various different structures.  

Areas of focus

Our expertise in international tax law includes the following:

  • UK's statutory residence test. 
  • Pre-move tax structuring. 
  • UK real estate and ownership structures.
  • Remittance basis of taxation.
  • Creation of excluded property structures.
  • Bringing tax-free funds into the UK under the business investment relief rules.
  • HMRC tax investigations and voluntary disclosures, including disclosures and settlements under amnesty regimes.
 
Experience

Advising non-resident clients on the time they can spend in the UK without becoming UK tax resident, taking into account their specific personal circumstances and ties to the UK.

Advising non-resident clients on the UK tax implications of planned moves to the UK and on possible pre-residence planning, including setting up remittance trusts to provide clean capital to fund UK expenses.

Advising UK resident non-domiciliaries on bringing tax-free funds into the UK under the business investment relief rules.

Advising UK resident non-domiciliaries on their options and obligations under the UK-Swiss Tax Agreement.

Assisting clients with HMRC tax investigations and voluntary disclosures, including disclosures and settlements under amnesty regimes.

Advising individuals who own UK residential real estate through companies on the constantly changing tax implications of such ownership, including the application of the Annual Tax on Enveloped Dwellings and changes to the inheritance tax regime.

Advising on tax efficient ways to purchase UK residential real estate following the introduction of the Annual Tax on Enveloped Dwellings, the changes to the law regarding the deductibility of debts for inheritance tax purposes and the proposed further changes to the inheritance tax treatment of residential real estate held through companies.

Meet the team
Suzanna Harvey

Suzanna Harvey Partner

  • Private Client Services
  • International Tax
  • International Trusts
John Barnett

John Barnett Partner

  • Head of Private Client Services
  • Head of Partnerships
  • Tax
Beatrice Puoti

Beatrice Puoti Partner

  • Head of Private Wealth
  • Private Client Services
  • International Tax and Trust
Jim Aveline

Jim Aveline Partner

  • Private Client Services
  • Family Offices and Family Businesses
  • Food and Farming