UK and International Tax
We advise both UK and international clients on personal tax issues.
Typically, UK clients seek tax advice from us in connection with either succession planning or when contemplating a disposal of a business. In those scenarios the principal focus will be on inheritance tax and capital gains tax but we will also advise on related tax issues such as income tax, stamp duty and stamp duty land tax.
For international clients it is generally necessary to cover a broader range of issues and we will advise on the concept of domicile, tax residence (for individuals, trustees and companies), inheritance tax, capital gains tax and income tax, including the particular tax treatment of resident but non-domiciled individuals and the ever-increasing raft of anti-avoidance rules that potentially apply to international clients and entities associated with them.
As part of this practice we regularly work with our property and corporate teams in providing bespoke advice to international clients on the best means of acquiring, owning and disposing of assets in the UK.
Although we have a fair degree of experience with certain jurisdictions we only advise international clients on UK taxation and in relation to double tax treaties. We are always mindful of the tax and succession rules in other relevant jurisdictions and, so, will always be keen to work as part of a team with advisers in those jurisdictions.
Our experience in this area includes:
- Advising a billionaire foreign client on UK tax planning. This consisted of advice on tax residence, the remittance basis of taxation applicable to foreign domiciled individuals, the impact of the double tax treaty between the UK and the individual’s “home” country, the use of trusts in relation to UK assets and assets located outside the UK and all relevant anti-avoidance legislation. As part of the overall brief advice was given on structuring to hold extremely valuable real estate purchased in England
- Advising a US citizen on succession and tax planning in relation to in relation to UK and US assets, working with US lawyers to implement an arrangement to mitigate US Estate Tax involving a US limited liability partnership between the client and family members and subsequently overhauling the structure
- Advising shareholders in a private company on capital gains tax planning in relation to their sale of the company which resulted in a re-organisation which enabled two shareholders, who would not have otherwise qualified for entrepreneur’s relief, to obtain that relief on their share disposals
- Advising a foreign domiciled client who was about to become UK tax resident on the tax and commercial implications of purchasing an offshore company which owned an intended residence in London as opposed to the underlying property itself