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Practice 05

Private Client & Residence

The rules that governed internationally mobile wealth for a generation have just been rewritten. Domicile is out, residence is in, and the remittance basis is gone. Families, founders and trustees are reviewing arrangements that were settled for decades. We give clear advice on where you now stand, and what to do about it, owned by one senior specialist.

Speak to a private client specialist

What we do

01

Residence & domicile

Where you are taxed under the new residence based system, and how to plan around the statutory tests with certainty.

02

Foreign income & gains

Making the most of the new four year regime for arrivals, and managing the position for those already here.

03

Trusts & estates

Reviewing settlements whose treatment has changed, and advising trustees on the route forward.

04

Inheritance tax

The move to a residence basis for inheritance tax, and what it means for global estates and long term residents.

05

Arrival & exit planning

Coming to or leaving the country with a clear, defensible plan rather than a costly surprise.

06

Wealth structuring

Family investment structures and succession planning built to last across generations and borders.

Why it matters now

Residence has replaced domicile as the basis of taxation.

From 6 April 2025 the remittance basis was abolished and replaced with a residence based foreign income and gains regime. Inheritance tax moved to a residence basis at the same time. Arrangements that were stable for decades now need a fresh look, and the window to plan well is open only briefly. We review your position and set out the options plainly.

Apr 2025
remittance basis abolished
4 years
exemption for qualifying new arrivals
Residence
now the basis for inheritance tax
10 / 20
years that define a long term resident

Common questions

What replaced the remittance basis?

From 6 April 2025 the remittance basis was abolished and replaced with a residence based foreign income and gains regime. Qualifying new arrivals receive a four year exemption on foreign income and gains. Inheritance tax moved to a residence basis at the same time.

Does the change affect my trust?

It can. The treatment of protected settlements has changed and trustees should review their position rather than assume the old rules still apply. We assess each structure on its own facts.

Who will actually do my work?

A senior specialist with at least fifteen years of experience. The person who wins the work does the work. Private matters are not handed to a junior team.

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