International Private Client services

Until 5 April 2025, UK resident non-doms were able to benefit from the remittance basis of taxation for non-UK income and capital gains, allowing for a very favourable UK tax regime. 

While this has now been replaced by a new, residence-based regime, the remittance basis continues to apply to non-UK income and capital gains of previous remittance basis years, with the new Temporary Repatriation Facility (TRF) allowing remittances to the UK at a reduced rate of tax. Where the remittance basis has previously been claimed, we assist clients with identifying ‘clean capital’ which can be remitted to the UK tax-free and to use the TRF to make taxable remittances at a reduced rate of tax. Our insight outlines the changes on taxation of non-doms and their offshore structures.

Until 5 April 2025, domicile also determined an individual’s exposure to IHT. This has also been replaced by a regime based on the individual’s long-term residence in the UK. We can assist clients in determining whether they would fall within the new rules of long-term residence and assist them with managing their IHT exposure.

There is a three-year window to avail of the TRF 2025/26 – 2027/28 and the rate for the first two years is 12%, increasing to 15% in year three.

Learn more about the new tax regime for Non-Doms and how to navigate the changes.

Tax treaties and relief from double taxation

Due to our familiarity with the UK law and the UK’s network of tax treaties, we can determine in which jurisdictions different sources of income and capital gains are taxable and claim relief in the UK for foreign taxes suffered. It is extremely important to ensure tax is paid in the correct jurisdiction, as it can often be difficult and costly to recover tax paid in error to a jurisdiction.

We also work with investment managers and HMRC to reclaim excess foreign tax deducted, for example, withholding tax on dividend income in excess of that permitted by the tax treaty.

Buying, owning, and selling UK real estate

We advise on the structuring and timing of the acquisition, ownership, and disposal of UK real estate by non-UK residents or their associated companies and trusts.

We are also able to assist with registration and tax compliance for non-resident landlords, the Annual Tax on Enveloped Dwellings (ATED), and Capital Gains Tax calculations, determining whether rebasing applies which can uplift the base cost thus reducing the tax. This can include advice on payment dates for the tax due, the availability of any relief for the main residence, and the reporting requirements on the sale of UK property, many of which have seen significant changes in recent years.

We prepare income and expenditure accounts for non-resident landlords of UK rental properties for inclusion in UK tax returns, ensuring the correct income is taxed and the correct treatment is applied to expenditure allowable against that income, in particular considering the nature of expenses and the recent restriction of relief for loan interest for individuals.

Tax issues around marriage and divorce can be complex; even more so where residence and cross-border issues are involved. We advise on planning for the marriage of couples from different countries, along with any possible change (planned or resultant) in residence of either party.

We also advise on minimising tax liabilities in the event of a divorce. Very often taking advice at the earliest stage in the divorce proceedings is critical in determining the optimal timing for any transfer or disposal of assets as part of the financial settlement on divorce. Furthermore, it is critical to understand the tax implications of the use of funds held offshore to satisfy the financial settlement, as significant UK tax liabilities can arise if this aspect is not reviewed.

We can also offer support as expert witness in divorce cases, quantifying the tax exposure from the proposed settlements and working alongside our expert forensic accounting team to help clients and their lawyers reach a conclusion.

Find out more: forensic accounting services.

Relocating executives

In addition to residence issues, we advise executives relocating to or from the UK on tax-efficient timing of remuneration. We also examine whether those arriving in the UK are able to take advantage of the available UK tax reliefs specific to their circumstances.

Foreign entertainers and sportspeople

Foreign entertainers and sportspeople present in the UK in the longer term will require assistance on residence issues, while those in the UK on short-term engagements will be more concerned with UK withholding tax and reclaiming any excess tax paid from HMRC.

In addition to dealing with UK tax compliance matters, we are also able to advise on residence, contractual arrangements, and UK tax exposure on matters such as image rights and sponsorship.

IHT and succession planning

The protection of wealth for future generations can be complex in cross-border situations. We have extensive experience of estate and succession planning to minimise IHT.

We work with the client's other advisors in all countries to ensure that the optimal position is obtained and that good practice in one jurisdiction does not result in an unnecessarily complex and high tax consequence in another jurisdiction.

Structuring your investments

Individuals with international wealth often make use of structures, such as holding companies or partnerships, to own their underlying investments, business interests, and family wealth. There are often good non-tax reasons for these structures, such as pooling wealth across the generations or streamlining costs. However, the UK tax treatment of such structures will not always follow the tax treatment afforded in other jurisdictions.

Until 5 April 2028, non-doms can continue to take advantage of Business Investment Relief to remit pre-6 April 2025 foreign income and gains to the UK free of tax to invest in UK businesses. We can advise on the strict conditions they must adhere to to qualify for this relief.

Offshore Trusts

Despite the significant changes in the taxation of offshore Trusts which took effect from 6 April 2025, they can still be a useful tool in tax planning. Trusts can also be used for non-tax reasons, such as succession planning and asset protection, particularly to avoid local 'forced heirship' rules.

Some clients will already be settlors or beneficiaries of existing Trusts. We can advise on the UK tax implications of these Trusts, including distributions to UK resident beneficiaries and whether any action should be taken in relation to those existing Trusts before the client becomes UK resident.

We can also assist in the unwinding of historic offshore Trust structures that may no longer be fit for purpose and repatriate these to the UK, ensuring that tax liabilities are managed as far as possible.

In recent years philanthropy has seen a rise in popularity and the worldwide pandemic influenced many people who wanted to give back to society and benefit those less fortunate than themselves.

Our advice can range from organising individual donations to charities to attract the optimum UK tax reliefs while avoiding taxable remittances by non-doms to more long-term, structured philanthropic planning. For more substantial donations we are able to assist in the creation of a family charity or a designated bespoke charitable fund managed by a larger organisation on the family’s behalf.

Tax compliance is often seen as a necessary evil and not given a great deal of time or attention. However, in these days of greater global transparency and information sharing arrangements between countries, such as the Common Reporting Standard, it is important that the reporting is accurate and the correct tax is paid.

We are able to guide you through the complexities of the UK tax system, assisting you in registering with HMRC where necessary and preparing and filing:

• annual tax returns for individuals and Trusts
• returns on disposal of UK residential property
• non-resident landlord returns
• ATED returns
• IHT returns.

We work with existing advisors or colleagues in the Crowe Global network to ensure the correct application of local tax law. We also consider the effect of tax treaties to determine how and where income and gains should be taxed and to claim the correct reliefs for foreign taxes suffered.

We do understand that things can go wrong and where this happens, we work with our specialist Tax Resolutions team to resolve historical UK tax problems which may arise. They will ensure any enquiry from HMRC is valid, take advantage of available reporting facilities to disclose the correct tax position and minimise the financial penalties levied.

Where an enquiry has not yet been raised, we are able to review the client’s tax compliance position, consider the requirements of the Common Reporting Standard, and ensure that no inadvertent historic UK tax liabilities have been triggered and no UK reporting deadlines missed. This can be particularly relevant for offshore Trustees especially in view of the legislative changes in recent years.

Where mistakes have been made, we will determine the correct position and explain the most appropriate way to disclose this to HMRC in order to minimise interest and penalty charges. Once the history is fully understood and all relevant disclosures made, we are then able to work with the client to ensure the ongoing compliance requirements are followed.