International Financial Planning · Tax Strategy
International Tax Planning — for Expats & HNW Individuals
When you live, work, or invest across borders, multiple tax systems interact simultaneously. Managing that interaction — legally, efficiently, and with a clear understanding of where you stand — is the foundation of sound international financial planning. We advise on UK residence, domicile, non-dom rules, CGT, IHT, and double taxation treaties for internationally mobile high-net-worth individuals.
Why international tax planning matters
The interaction of multiple tax systems
An internationally mobile individual can simultaneously be subject to income tax in their country of residence, CGT in the country where an asset is situated, and IHT in the country of their domicile — all on the same underlying wealth.
Without careful planning, this overlap produces unnecessary double taxation. With the right structure — and the right timing — it is often possible to arrange affairs so that income and gains fall within a single, lower-tax jurisdiction, or are sheltered within compliant international structures that defer or eliminate the liability.
Key questions to answer before you move
- When will I become non-UK resident for tax purposes?
- What is my domicile status and how does it affect IHT?
- Do I qualify for the 4-year FIG exemption on arrival in the UK?
- Should I crystallise gains before or after departure?
- Which assets will remain within the scope of UK CGT?
- Does the UK have a DTA with my new country of residence?
- What is my IHT position and does the 10-year tail apply?
Key planning areas
International tax planning — core topics
UK Statutory Residence Test
The Statutory Residence Test (SRT) determines your UK tax residence status for each tax year. It works through a series of automatic overseas tests, automatic UK tests, and — if those are inconclusive — a sufficient ties test based on your connections to the UK. Your result determines whether UK income tax and CGT apply to your worldwide income and gains for that year.
Run the SRT test →Domicile vs Tax Residency
Domicile and tax residence are distinct legal concepts that each carry their own tax consequences. Tax residence is determined annually by the SRT and controls income tax and CGT exposure. Domicile is a more enduring concept determined by origin and intention — it governs IHT on worldwide assets and, historically, the remittance basis of taxation for non-doms. You can be UK-resident but non-UK-domiciled, or UK-domiciled but non-resident — each combination produces different tax outcomes.
Check your domicile position →Non-Dom & the New FIG Regime (Post-April 2025)
The remittance basis for non-doms was abolished from April 2025. In its place, a four-year Foreign Income and Gains (FIG) exemption applies to individuals who have not been UK-resident in the ten tax years before arrival. During the four-year window, foreign income and gains are not subject to UK tax, regardless of remittance. After four years, worldwide income and gains are taxed on the arising basis. The Temporary Repatriation Facility (TRF) — available 2025 to 2027 — allows pre-2025 unremitted foreign income and gains to be brought to the UK at a reduced rate. Planning around the transition is essential for those who had relied on the remittance basis.
Capital Gains Tax for Non-Residents
Non-UK residents are subject to UK CGT on disposals of UK residential property (from April 2015) and UK commercial property (from April 2019). Gains on other UK assets are generally outside the scope of UK CGT while non-resident — but a temporary non-residence anti-avoidance rule applies: if you become non-resident, dispose of assets, and return within five years, the gains may be brought back into charge. Timing disposals relative to a change of residence can be highly advantageous with proper planning.
Inheritance Tax Planning
UK IHT at 40% applies to the worldwide estate of UK-domiciled individuals above the nil-rate band (£325,000) and residence nil-rate band (£175,000 for direct descendants where the family home passes to them). For non-UK domiciled individuals, only UK-situated assets were previously within scope — overseas assets could be sheltered in excluded property trusts. From April 2025, a ten-year tail rule applies: individuals who have been UK-resident for ten or more of the previous twenty years remain within the scope of UK IHT for ten years after ceasing UK residence. This significantly changes planning for long-term expats returning overseas.
Pre-Departure Planning
The period immediately before leaving the UK is one of the most significant planning windows available. Key decisions include: crystallising capital gains while still UK-resident (to benefit from CGT-free wrapper options on arrival) or deferring them to after departure; maximising pension contributions during the final year of UK employment income; reviewing asset ownership structures and whether any transfers should occur before departure; reviewing domicile status and the implications for IHT going forward. Leaving without a plan often creates unnecessary UK tax liabilities in the years that follow.
Double Taxation Treaties
The UK has an extensive network of double taxation agreements (DTAs) with over 130 countries. DTAs generally allocate taxing rights between countries — so that the same income or gain is not taxed in full by both jurisdictions. Most DTAs follow the OECD Model Convention. The relevant treaty depends on your country of residence and the source of your income. Relief under a DTA is claimed through self-assessment or — for employment income — by completing form DT-Individual with HMRC and the overseas tax authority. Treaty relief is not automatic: it must be actively claimed.
IHT mitigation
Inheritance Tax planning strategies for internationally mobile individuals
Gifts and exempt transfers
- Potentially Exempt Transfers (PETs) — gifts to individuals fall outside the estate if the donor survives seven years. Taper relief reduces the charge on death in years three to seven.
- Annual gift exemption — £3,000 per tax year per donor, immediately outside the estate.
- Small gift exemption — £250 to any number of individuals per tax year, provided no other exemption has been used for that recipient.
- Normal expenditure out of income — regular gifts from surplus income (not capital) can be immediately exempt if they do not reduce the donor's standard of living.
Business and agricultural reliefs
- Business Property Relief (BPR) — 100% relief on qualifying business assets (minimum two-year hold), now capped at £2.5 million per estate from 6 April 2026 (transferable between spouses), with 50% relief above that cap. AIM-listed shares qualify for 50% relief only from 6 April 2026. Advice should reflect these current rules.
- Agricultural Property Relief (APR) — 100% relief on qualifying agricultural property in the UK, Channel Islands, and Isle of Man.
Structures and wrappers
- Discretionary trusts — assets in a properly structured discretionary trust are outside the settlor's estate for IHT (subject to the seven-year rule on transfer). Periodic and exit charges apply under the relevant property regime.
- Excluded property trusts — for non-UK domiciled settlors, overseas assets placed into trust can be permanently outside UK IHT. Post-April 2025 rules have narrowed this — advice is essential before structuring.
- Offshore investment bonds written in trust — a whole-of-life policy or offshore bond held in a discretionary trust provides immediate liquidity on death, outside the estate and outside probate.
Free tools
Assess your tax position — free tools
Statutory Residence Test
Work through the UK SRT to determine your UK tax residence status for a given tax year. Covers all three tests: automatic overseas, automatic UK, and sufficient ties.
Run the test →UK Domicile Assessment
Assess your likely UK domicile status — domicile of origin, dependence, and choice — and understand the IHT and income tax implications of your position.
Check your domicile →Tax Planning Review
Speak directly with our international tax planning team. We review your full position — residence, domicile, assets, income sources — and produce a written planning report.
Book a review →Important: tax rules change and this is not personal advice
Tax legislation changes frequently — the April 2025 non-dom reforms are a significant example. Information on this page reflects our understanding of the rules as at the date of publication and may not reflect subsequent changes. Nothing on this page constitutes personal tax advice. You should always seek advice from a qualified tax adviser who understands your full personal circumstances before making any decisions based on tax planning.
Global Investments coordinates with specialist tax counsel in each jurisdiction where our clients hold assets or reside. We do not provide legal or accountancy services directly, but we work alongside your existing advisers or can recommend appropriate specialists.
Book a tax planning review
International tax planning is time-sensitive — the decisions that make the biggest difference are usually made before a move, not after. We work with you and your tax advisers to structure your affairs efficiently before you cross any border.
Get a personalised international tax planning review
Tell us about your situation — residence, domicile, assets, and where you are moving — and our team will outline the key issues and planning opportunities for your specific circumstances.