Strategic analysis on global tax architecture, corporate structuring, regulatory frameworks, and cross-border operations.
A 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 analysisQualifying Free Zone Person status is a five-condition categorisation, not a tax exemption attached to a freezone licence. Article 18 of Federal Decree-Law No. 47 of 2022, Cabinet Decision No. 100 of 2023, and Ministerial Decision No. 229 of 2025 (which replaced Ministerial Decision No. 265 of 2023 retroactively from 1 June 2023) define what counts as Qualifying Income, what counts as an Excluded Activity, and where a single non-qualifying transaction collapses the regime for the current period and the next four. The 9% rate on the entire Taxable Income, not on the marginal slice, is the consequence of getting any one condition wrong.
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 Statutory Residence Test in Schedule 45 of the Finance Act 2013 decides whether a person is UK tax resident, mechanically, not by intent. For HNWIs it bites hardest in three places: the midnight day count, the ties test that tightens with residence, and full-time work abroad that breaks on unrecorded detail.
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.
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