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Non-dom exit planning, Family Investment Companies, DIFC/ADGM wills, succession, and IHT architecture for HNWIs and their advisers.
A 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 Full 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 Full 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 Full 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 Full 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 Full 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 Full 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 Full AnalysisFederal Decree-Law No. 41 of 2022 on Civil Personal Status and Cabinet Decision No. 122 of 2023 (its Implementing Regulations) gave non-Muslim UAE residents a federal civil framework for wills and inheritance. Two principal registration routes operate in 2026: the DIFC Wills Service (common-law-style English-language wills covering UAE assets and, since the 2017 amendment, worldwide assets) and the Abu Dhabi Civil Family Court under Abu Dhabi Law No. 14 of 2021 plus the federal civil regime. The choice of route is not interchangeable. For UK-connected HNWIs operating under the post-non-dom UK framework, the will is the instrument that sequences UAE-side succession with UK Long-Term Resident IHT exposure under section 6A IHTA 1984 and with the 2025-vintage settlements regime.
Read Full AnalysisA Golden Visa is the right to live in the UAE. It is not the right to be a UAE tax resident. Federal Decree-Law No. 29 of 2021 and Cabinet Resolution No. 65 of 2022 govern an immigration permit; UAE tax residence is a separate question under Cabinet Decision No. 85 of 2022 and Ministerial Decision No. 27 of 2023. After the abolition of the UK remittance basis on 6 April 2025, that distinction matters more than at any time since the Golden Visa was launched. The property route at AED 2 million remains the practical 2026 path; the employment route has been administratively paused since October 2025; the lifetime nomination route circulating on social media since July 2025 was officially denied by the UAE Government and remains denied through January and February 2026 ICP advisories.
Read Full AnalysisA Family Investment Company is not a trust replacement. It is a different architecture for a different problem. After Finance Act 2025 dismantled protected settlements and Finance Act 2026 capped business and agricultural property relief, the question is no longer whether to use a FIC instead of a trust; it is which functions each instrument serves once both are taxed at full rates. The wrong choice locks in a 25% Corporation Tax base on retained returns, 17% SDLT on enveloped residential property, and a settlements-legislation exposure that quietly attributes income back to the founder.
Read Full AnalysisUAE individual tax residency is governed by Cabinet Decision No. 85 of 2022 and Ministerial Decision No. 27 of 2023, which set out three distinct domestic tests: a centre-of-interests test, a 183-day physical-presence test, and a 90-day route conditional on residence permit, employment or business, and a permanent place of residence. The 90-day route is the most useful for internationally mobile HNWIs and the most commonly misunderstood. Domestic residency does not automatically deliver a Tax Residency Certificate for treaty purposes; the FTA requires 183 days of physical presence for treaty TRCs even where domestic residency is established at 90 days.
Read Full 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 Full 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 Full AnalysisFrom 6 April 2025, UK inheritance tax no longer depends on domicile. An individual is a long-term UK resident, and taxable on worldwide estate, once resident in 10 of the preceding 20 tax years. Crossing the threshold is the easier half; coming out of it is the harder half. A minimum three-year tail follows every departure, and the tail extends by one year for each additional year of residence beyond 13, up to a ten-year ceiling.
Read Full 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.
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