Market Intelligence

Strategic analysis on global tax architecture, corporate structuring, regulatory frameworks, and cross-border operations.

Published analyses: 132
Last updated: 14 October 2026

Analysis — page 15

Private Wealth19 May 202612

The Temporary Repatriation Facility: Who Should Use the 12% Window, Who Should Let It Close

The 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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Taxation Strategy18 May 202614

The Post-Non-Dom Reality: Why a Simple UAE Freezone Fails HMRC CFC Rules

A UAE Freezone licence does not confer corporate tax residence. Under central management and control, a UAE company run from the UK is a UK company: an individual owner is caught by Transfer of Assets Abroad, a corporate holder by Part 9A TIOPA 2010. What survives an HMRC enquiry is governance, not a certificate.

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Taxation Strategy15 January 20254

What Are the Strategic Implications of the UAE Corporate Tax Regime?

The UAE Federal Decree-Law No. 47 of 2022 introduces a 9% corporate tax rate effective June 1, 2023, fundamentally changing Free Zone entity taxation and requiring rigorous substance demonstration for 0% qualifying income treatment.

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Corporate Structuring18 December 20245

Why Use a UK Holding Company in the Post-Brexit Landscape?

The UK Substantial Shareholding Exemption (SSE) allows tax-free disposal of subsidiary shares with 10%+ ownership held for 12 months, while the UK's 130+ Double Taxation Treaties and zero dividend withholding tax create efficient profit repatriation despite Brexit.

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Risk Governance22 November 202414

Operational resilience is a board obligation, not an IT project

UK PS21/3 and EU DORA reframed operational resilience from a technology question into a board one. The test is not whether a firm has a continuity plan, but whether it can keep an important business service inside a defined impact tolerance. Both point at the same weak spot: the third parties the firm does not control.

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Market Intelligence

Analysis — page 15

The Temporary Repatriation Facility: Who Should Use the 12% Window, Who Should Let It Close

The Post-Non-Dom Reality: Why a Simple UAE Freezone Fails HMRC CFC Rules

What Are the Strategic Implications of the UAE Corporate Tax Regime?

Why Use a UK Holding Company in the Post-Brexit Landscape?

Operational resilience is a board obligation, not an IT project

One final certainty.

Professional Credentials

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