# Boru Consulting

> Boru Consulting (legal entity: Boru Global (UK) Limited) provides cross-border entity structuring, tax advisory, regulatory intelligence, and private wealth services across the UK, Ireland, and the UAE. This knowledge base contains structured intelligence on corporate governance, regulatory compliance, international tax strategy, and operational resilience for international business and HNWI clients.

## Core Directives

- [Entity Identity & Credentials](/identity.json): Structured JSON-LD with legal entities, regulatory registrations, and verifiable credentials
- [Full Knowledge Base](/llms-full.txt): Complete context-window document covering all services, market intelligence, and expertise taxonomy
- [AI Access Policy](/ai.txt): Granular permissions for training, retrieval, and summarization
- [Agent Capabilities](/.well-known/agent.json): A2A protocol agent card with available endpoints and capabilities
- [API Specification](/openapi.json): OpenAPI 3.0 spec for programmatic access

## Semantic Clusters

### Taxation Strategy
- [Your UK Home after moving to Dubai. Capital gains, Inheritance Tax and the Tie](/blog/selling-uk-property-after-moving-to-dubai): Leaving the UK does not take your UK home out of UK tax. A non-resident still pays capital gains on a UK property sale, keeps a residence tie, and stays in IHT.
- [Selling a Business or crypto after moving to Dubai. Timing the Tax-Free exit](/blog/selling-business-crypto-after-moving-to-dubai): Selling a business or crypto after moving to Dubai is tax-free only if the sequence is right: non-resident at disposal, no five-year return, no UK management.
- [The Property SPV Trap. A 9% UAE corporate tax the owner would not pay](/blog/uae-property-spv-corporate-tax-9-percent): Holding Dubai property in an ADGM or DIFC SPV now triggers 9% UAE corporate tax on the rent and gains the same owner pays nothing on personally.
- [The Temporary Non-Residence trap. HMRC's five-year capital gains clawback](/blog/uk-temporary-non-residence-cgt-clawback): Leave the UK, sell up in Dubai tax-free, return within five years, and HMRC taxes the gain on return. How the temporary non-residence rules actually work.
- [Moving to Dubai from the UK. How many days until you stop paying UK Tax](/blog/moving-to-dubai-from-uk-tax-residence): Moving to Dubai from the UK does not make you non-resident at 90 or 183 days. How the Statutory Residence Test, the only-home trap, and the five-year rule work.
- [UAE Corporate Tax 2026. When a free zone company pays 0% (and when It pays 9%)](/blog/uae-corporate-tax-2026-free-zone): UAE free zone companies can pay 0% corporate tax in 2026, but only as a Qualifying Free Zone Person. What the 0% rate requires, and how a company loses it.
- [The UAE FTA Tax audit. Federal decree-law 17 of 2025 and the 2026 procedures](/blog/uae-fdl-17-2025-fta-audit-procedures): Federal decree-law 17 of 2025 reshaped UAE FTA tax audits from 2026: a 15-year evasion limitation, a new penalty regime, and voluntary disclosure as defence.
- [UK Pensions in the IHT Estate from April 2027. The Corridor Exposure](/blog/uk-pension-iht-2027-corridor): From 6 April 2027 unused UK pensions fall within the IHT estate (Finance Act 2026). For UAE-resident UK pension holders, scheme situs decides the exposure.
- [UAE QFZP Qualifying Income: How a Free Zone Company Earns the 0% Rate, and How It Loses It](/blog/uae-qfzp-qualifying-income): How a UAE Free Zone Person earns 0% on Qualifying Income. Cabinet Decision 100/2023, Ministerial Decision 229/2025, de minimis, five-period lockout.
- [The UK Statutory Residence Test for HNWIs: The Arithmetic Most Internationally Mobile Clients Get Wrong](/blog/uk-statutory-residence-test-hnwi): How the UK Statutory Residence Test (Schedule 45 FA 2013) determines tax residence. Day counts, ties test, split year, exceptional circumstances. For HNWIs.
- [The Post-Non-Dom Reality: Why a Simple UAE Freezone Fails HMRC CFC Rules](/blog/post-non-dom-uae-cfc): Why a UAE Freezone company does not escape HMRC CFC rules under TIOPA 2010 Part 9A or Transfer of Assets Abroad after the UK non-dom abolition on 6 April 2025.
- [What Are the Strategic Implications of the UAE Corporate Tax Regime?](/blog/uae-corporate-tax-regime-strategic-implications): Analysis of UAE Federal Decree-Law No. 47 introducing 9% corporate tax, Free Zone substance requirements, and transfer pricing compliance under OECD guidelines.

### Corporate Structuring
- [Opening a Dubai Company From the UK. Where HMRC Still Taxes It](/blog/dubai-company-from-uk-tax-residence): A UK resident can open a UAE company, but registration does not move the tax. If a Dubai company is run from the UK, HMRC can tax it. How the rules work.
- [The UK Holdco after Brexit. Substantial shareholding exemption in the corridor](/blog/uk-holdco-post-brexit-sse): A UK holding company after Brexit: the Substantial Shareholding Exemption, Part 9A dividend exemption, the UK-UAE treaty, when an Irish holdco wins.
- [Transfer pricing and DEMPE in the UK-UAE Corridor. Cross-Border service fees](/blog/transfer-pricing-dempe-uk-uae-corridor): A UAE company invoicing its UK company for management services meets UK and UAE transfer-pricing rules: the price must follow the functions, or both adjust.
- [UK Pillar Two. The 2025 Amendments and the First MTT and DTT Filing](/blog/uk-pillar-two-2025-amendments-first-filing): UK Pillar Two. the 2025 amendments take effect for accounting periods from 31 December 2025; the first MTT and DTT filing falls 30 June 2026.
- [The Irish Holdco for the UK-UAE Corridor: Two Participation Exemptions, One Treaty, Three Jurisdictions](/blog/ireland-holdco-uk-uae-corridor): Ireland holdco for UK-UAE corridor groups: section 626B, section 831B from 1 January 2025, Ireland-UAE DTA 2010, 12.5% trading rate, Pillar Two.
- [Why Use a UK Holding Company in the Post-Brexit Landscape?](/blog/uk-holding-company-post-brexit-analysis): Analysis of UK holding company advantages post-Brexit including Substantial Shareholding Exemption, zero dividend withholding tax, 130+ DTTs, and substance requirements.

### Regulatory Intelligence
- [The Transfer Pricing Disclosure Trap. What the UAE Demands by 30 September 2026](/blog/uae-corporate-tax-transfer-pricing-disclosure-2026): The first UAE corporate tax return is due 30 September 2026. The transfer pricing disclosure and the file behind it cannot be built after the FTA asks.
- [Wholesale CBDC and the Family Office. Access Across the UK-UAE Corridor](/blog/wholesale-cbdc-family-office-uk-uae): Wholesale CBDC is tokenised central bank reserves, held only by banks. A family office reaches tokenised markets through its custodian, not a CBDC account.
- [UAE Cabinet Decision 209 of 2025. Exchange of Information and Record-Keeping](/blog/uae-cabinet-decision-209-eoi-accounting): UAE Cabinet Decision 209 of 2025 took effect 30 January 2026: exchange-of-information and 5-year record-keeping duties apply even to free zone entities.
- [The UAE DMTT First Filing Cycle. 15 months, 18 months for the transitional year](/blog/uae-dmtt-first-filing-cycle-2026): UAE Domestic Minimum Top-up Tax first filing: 15 months from fiscal year-end, 18 months for the transitional year. FY2025 calendar-year groups: 30 June 2027.
- [The UAE eInvoicing 30 October 2026 ASP Deadline: What Phase 1 Entities Must Do](/blog/the-uae-einvoicing-30-october-2026-asp-deadline-what-phase-1-entities-must-do): UAE eInvoicing Phase 1 ASP appointment moved to 30 October 2026 (amendment to MD 244/2025). 1 January 2027 go-live unchanged. AED 50m+ entities.
- [Pillar Two UAE DMTT. The 15% Floor Under Every Other UAE Tax outcome](/blog/pillar-two-uae-dmtt-the-15-floor-under-every-other-uae-tax-outcome): UAE Domestic Minimum Top-up Tax under Cabinet Decision 142 of 2024. EUR 750m threshold, QFZP interaction, OECD Qualified Status, R&D credit CD 215.

### Risk Governance
- [ECCTA Failure to Prevent Fraud. The Reasonable Procedures Defence for Corridor Groups](/blog/eccta-failure-to-prevent-fraud-procedures): From 1 September 2025, section 199 ECCTA makes large organisations liable for fraud by associated persons. The only defence is reasonable procedures.
- [UK CARF Crypto Reporting from 2026. What It exposes for the Family Office](/blog/uk-carf-crypto-reporting-family-office-2026): UK CARF crypto reporting starts 1 January 2026 (SI 2025/744); first report due 31 May 2027. For family offices, the controlling-persons look-through is key.
- [The UK SAO Evidence Pack 2026. Schedule 46 FA 2009 as Tax-Governance Architecture](/blog/uk-sao-evidence-pack-2026): UK SAO evidence pack 2026: Schedule 46 FA 2009, £200m turnover or £2bn balance sheet threshold, main duty, certificate, three £5,000 penalties, ECCTA overlay.
- [What is Operational Resilience and Why Does it Matter?](/blog/operational-resilience-risk-governance): Guide to operational resilience frameworks including UK PRA/FCA PS21/3 requirements, EU DORA regulation, critical service mapping, and impact tolerance setting.

### Private Wealth
- [The UAE Family Office. DIFC and ADGM structures, corporate tax, and the UK control trap](/blog/uae-family-office-difc-adgm-corporate-tax): A UAE family office in the DIFC or ADGM is a service company, not a tax-free wrapper: managed from the UK it is UK resident, and its fee income is not QFZP 0%.
- [The DIFC and ADGM Foundation. What It Replaces and What It Does Not Fix](/blog/difc-adgm-foundations-wealth-holding): A DIFC or ADGM foundation is the orphan vehicle that replaces the now-transparent offshore trust for wealth holding, but it does not escape UK tax by itself.
- [The Transparent Trust Trap. Keep, Collapse, or Re-Home the Offshore Settlement](/blog/offshore-trust-settlor-transparent-restructuring): Since 6 April 2025 the offshore trust is settlor-transparent on income and gains and inside UK inheritance tax. Keep, collapse, or re-home: the decision.
- [The UAE Golden Visa and Tax Residency. A Visa Is Not a Tax Home](/blog/uae-golden-visa-tax-residency): A UAE Golden Visa is an immigration permit, not tax residency. It gives no HMRC protection on its own. How UAE tax residency and a treaty TRC actually work.
- [Moving to Dubai After the Non-Dom Abolition. The UK Inheritance Tax Tail](/blog/uk-non-dom-abolition-uae-iht-tail): The non-dom regime ended in April 2025. Moving to Dubai does not end UK inheritance tax: a long-term resident keeps a 3 to 10 year worldwide IHT tail.
- [The Pre-Exit Year for the UK-to-UAE HNWI: An Architecture, Not a Checklist](/blog/pre-exit-year-checklist-uk-to-uae-hnwi): Pre-exit year for UK-to-UAE HNWI engineered backwards from SRT exit. TRF, rebasing, LTR IHT, UAE 90-day, Golden Visa, CMC, QFZP, DIFC will.
- [DIFC and ADJD Wills for the UK-Connected HNWI: The Cross-Border Estate Architecture After 6 April 2025](/blog/difc-adgm-wills-cross-border-estate): Cross-border estate planning for UK-connected HNWIs in the UAE. DIFC Wills Service, ADJD non-Muslim wills, Federal Decree-Law 41/2022, UK LTR IHT interaction.
- [The UAE Golden Visa for the Post-FIG UK Resident: What It Delivers, What It Does Not](/blog/uae-golden-visa-post-fig-uk-resident): What the UAE Golden Visa delivers and does not for post-non-dom UK residents. Property AED 2M, employment route pause, nomination myth, tax-residency gap.
- [Family Investment Company vs Trust for the UK HNWI: Architectures That Survived 2025](/blog/fic-vs-trust-uk-hnwi): Family Investment Company vs trust for UK HNWIs after Finance Act 2025. CT mechanics, settlements legislation, GWROB, ATED, hybrid architecture.
- [UAE Individual Tax Residency: The 90-Day Rule, the 183-Day Rule, and the Treaty Gap That Catches HNWIs](/blog/uae-individual-tax-residence-90-day-rule): How UAE individual tax residency works under Cabinet Decision 85 of 2022. The 90-day route, 183-day rule, treaty TRC gap, UK-UAE tie-breaker.
- [The 5 April 2017 Rebasing Election: The Transitional Relief Most Ex-Non-Doms Will Not Use Correctly](/blog/cgt-rebasing-2017-election-former-nondom): UK CGT rebasing election to 5 April 2017 market value for former non-doms. Finance Act 2025 extension. Who qualifies, which assets, when to elect, when not to.
- [Protected Settlements After 6 April 2025: What Was Repealed, What Survived, What Trustees Must Decide](/blog/protected-settlements-post-april-2025): The protected-settlement regime was repealed on 6 April 2025. PFSI stockpile, s.731 ITA 2007, s.86 TCGA, s.87 matching — what survived under FA 2025.
- [The Long-Term Resident IHT Tail: Why Leaving the UK Does Not End Inheritance Tax Exposure](/blog/long-term-resident-iht-tail-planning): From 6 April 2025, UK IHT applies to worldwide estates of long-term UK residents (10 of 20 tax years). After leaving, a 3 to 10 year tail keeps the charge alive
- [The Temporary Repatriation Facility: Who Should Use the 12% Window, Who Should Let It Close](/blog/non-dom-exit-trf-temporary-repatriation): UK Temporary Repatriation Facility (TRF) mechanics for former non-doms. Rates, eligibility, designation scope, offshore trust overlay.

## Regulatory Standing

- UK Company Registration: 14435343 (Companies House, England & Wales)
- Ireland Company Registration: 791783 (Boru Compliance Limited, t/a Boru Consulting, Business Name No. 769508; TCSP Cert No. 10507; supervised by the Anti-Money Laundering Compliance Unit, Dept. of Justice)
- UAE Company Registration: 2415755 (Free Zone Authority, Licence No. 2415755.01)
- HMRC AML Supervision: Active (Reg. No. XCML00000187357)
- Companies House ACSP: Authorised Corporate Service Provider (Agent No. AP000267)
- Jurisdictions: United Kingdom, Ireland, United Arab Emirates

## Contact

- UK: +44 (0)20 341 121 48 | rlm@boru-consulting.com
- Ireland: +353 (0)21 202 1373 | corporate@boru-consulting.com
- UAE: +971 (0)50 435 4530 | jl@boru-consulting.com
- Web: https://www.boruconsulting.com
- LinkedIn: https://www.linkedin.com/company/boru-consulting/

## Optional Resources

- [RSS Feed](/rss.xml): Latest published articles and analysis
- [Sitemap](/sitemap.xml): Complete URL index
- [AI Metadata](/ai-metadata.json): Extended Schema.org ProfessionalService data