Non-dom exit planning, Family Investment Companies, DIFC/ADGM wills, succession, and IHT architecture for HNWIs and their advisers.
A family office becomes an institution not when it grows but when its governance does, when a constitution, a council and a board replace the principal deciding everything. In the corridor that governance decides where the office is taxed and whether the structures beneath it hold.
Read the analysisA UAE or DIFC foundation can hold a family's worldwide assets with a clean UAE result under Article 17. That result stops at the border. Funding the foundation with US or Japanese company shares is taxed where the assets and the owner live, and that is where the real cost sits.
Read the analysisPassing wealth to the next generation is decided by two facts before any structure: where the family is tax resident and when the transfer is made. A trust, company or foundation is the last decision, not the first, and shelters nothing that residence and the seven-year clock have not already settled.
Read the analysisThe five million pound cap on a legacy excluded property trust sounds like a rescue and for almost every family changes nothing. Because the ten-year charge is capped at six per cent, it only helps a trust worth more than eighty-three million. Below that, the trust simply pays.
Read the analysisPrivate placement life insurance is a wrapper, not a shelter. For a UK-resident policyholder efficiency depends on staying outside the personal portfolio bond rules. A policy whose owner personally selects the assets triggers a deemed 15% annual gain whether or not it rose. It is only as good as its compliance.
Read the analysisAsset protection and dynasty trusts are sold as shields, but for a UK-connected family the shield is narrow. A trust settled against a foreseeable claim can be unwound under section 423, a nuptial settlement varied on divorce, and UK tax reaches the settlor anyway. Protection is prospective, not escape.
Read the analysisA private trust company is a company a family owns to act as trustee of its own trusts, instead of an outside professional. It also creates the exposure a UK-connected family should fear: a trust is resident where its trustee is managed, so controlling the trustee from the UK builds a UK-resident trust.
Read the analysisA UK family investment company, a UK trust and a DIFC or ADGM foundation answer three different questions about control, succession and tax. After the 2025 reforms the honest choice turns on one variable: where the founder is resident. This is the decision layer, and the cost of moving once the wrong one is built.
Read the analysisRetirement Relief can pass an Irish business to your children with no Capital Gains Tax, but since 1 January 2025 a €10 million cap applies to owners aged 55 to 69, and €3 million from 70. Tax above the cap can be deferred if the child holds for twelve years, with two clawback clocks to track.
Read the analysisOn death, a Dubai property owned by a long-term UK resident is caught twice: by UK inheritance tax at 40%, and by UAE succession law, which decides who inherits it regardless of an English will. The two regimes are independent, they answer different questions, and each needs its own plan.
Read the analysisA UAE family foundation can be fiscally transparent under Article 17, with no 9% corporate tax at the foundation level, but only if it earns and keeps the treatment. The current rules, set by the FTA's CTGFF1 guide, decide how multi-tier holding companies qualify and why an ordinary LLC does not.
Read the analysisPaying the Temporary Repatriation Facility charge cleanses pre-6 April 2025 foreign income and gains, but the relief is delivered or lost in the mixed fund rules. Designation turns a clean account into a mixed fund, and the TRF capital account carries a deposit rule with a 30-day cure and a two-day cliff.
Read the analysisA UAE tax residency certificate is the document people chase when they move to Dubai, and it is widely misunderstood. It proves a UAE status and is used to claim double-tax-treaty relief, but it does not by itself make a UK leaver non-resident, and the treaty version requires 183 days, not the 90-day route.
Read the analysisA family office in the DIFC or ADGM runs the family's wealth; it does not hold it. It is a taxable service company at 9%, its fee income does not reach the free zone 0% rate, and because it is where the decisions are made it is the entity most exposed to UK tax residence if the principal runs it from London.
Read the analysisA DIFC or ADGM foundation is an orphan legal person, neither a company nor a trust, and the structure families reach for once the offshore trust became settlor-transparent in 2025. For a UK-resident founder it does not escape the settlements code or inheritance tax by itself.
Read the analysisSince 6 April 2025 the offshore settlor-interested trust is transparent for income tax and capital gains tax, and its non-UK assets sit inside UK inheritance tax while the settlor is a long-term UK resident. The question left is whether to keep, collapse, or re-home it.
Read the analysisA UAE Golden Visa gives you the right to live in Dubai. It does not, on its own, make you a UAE tax resident, and it gives you no protection from HMRC. Tax residency is a separate test run by the Federal Tax Authority, and a treaty certificate needs 183 days in the country, not just a visa in your passport.
Read the analysisThe UK non-dom regime ended on 6 April 2025, and Dubai is the natural destination for much of the wealth that left with it. But moving does not switch off UK inheritance tax. Once you have been UK resident for 10 of the last 20 years, your worldwide estate stays in the 40% net for a three-to-ten-year tail after you go.
Read the analysisThe pre-exit year is engineered backwards from the SRT exit date under Schedule 45 Finance Act 2013. TRF designation, 5 April 2017 rebasing, the section 6A IHTA 1984 tail, UAE 90-day residence, the Golden Visa property route, CMC reconstitution, QFZP substance, and DIFC will registration converge on one date.
Read the analysisA UK will is a weak way to pass a Dubai flat. UAE law now governs a foreigner's will over UAE property, and a non-Muslim who dies without a UAE will meets a statutory split. How the DIFC, ADGM and Abu Dhabi routes differ, and what none does for UK inheritance tax.
Read the analysisA UAE Golden Visa gives UK citizens the right to live in the UAE, not the right to be a UAE tax resident. The AED 2 million property route is the practical 2026 path, with off-plan and mortgaged properties now qualifying, but the visa gives no protection from HMRC. What it delivers, and the tax catch it does not.
Read the analysisChoosing between a UK trust and a family investment company to pass wealth to your children is no longer a tax-arbitrage question. Finance Act 2025 stripped the trust of its non-dom shield, and a FIC never had one, so both are now taxed at full UK rates. The choice is now architectural, not a matter of tax.
Read the analysisUAE individual tax residency runs on three tests under Cabinet Decision No. 85 of 2022: centre of interests, a 183-day presence test, and a conditional 90-day route. Domestic residency alone does not deliver a treaty Tax Residency Certificate; the FTA requires 183 days for a treaty TRC even if you qualify at 90.
Read the analysisThe Finance Act 2025 extended the 2017 rebasing election from a narrow deemed-domicile cohort to the broader population of former remittance-basis users. It is the second transitional provision alongside the TRF, and the less understood of the two. Rebasing elects a 5 April 2017 market value as the base cost on disposal of eligible foreign assets. The election is per-asset, is made on disposal, and is irrevocable. It saves significant CGT in some cases and destroys value in others.
Read the analysisThe Finance Act 2025 repealed sections 628A to 628C and 630A of ITTOIA 2005, dismantling the protected-settlement regime for non-domiciled and deemed-domiciled settlors. The section-86 TCGA blocking provision fell with them. What survived is more consequential than what was removed: a stockpiled pool of protected foreign-source income, a revived section 731 charge on transferor-settlors, and an arising-basis attribution stack that catches UK-resident settlors at marginal rates. Trustees now face four architectural decisions, and every existing offshore settlor-interested trust carries one of them.
Read the analysisFrom 6 April 2025, UK inheritance tax no longer depends on domicile. You are a long-term UK resident, taxable on your worldwide estate, once resident in 10 of the previous 20 tax years. Leaving does not end it: a tail of three to ten tax years follows departure, and the exit runway is the real planning problem.
Read the analysisThe Temporary Repatriation Facility lets former remittance-basis users pay 12% in 2025/26 and 2026/27, or 15% in 2027/28, on designated pre-6 April 2025 foreign income and gains. It is not a deadline to remit; it is a designation election that cleanses the amount for future remittance without further UK tax. The decision is architectural, not reflexive. The facility closes on 5 April 2028 and will not be extended.
Read the analysisWe do not exit when complexity enters. We stand by our clients through every regulatory shift, audit, and challenge. Unwavering support is the foundation of our firm.
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