As the world increasingly becomes a smaller place, you need a specialist legal team you can trust.
Individuals move from country to country and financial markets are accessible from all corners of the globe. The complexities of dealing with tax rules in multiple jurisdictions can create challenges; where there are potential pitfalls, there are also opportunities.
Addleshaw Goddard's Private Capital Group has considerable expertise in advising both UK residents and non-UK residents on their UK tax position – and on offshore structures, where appropriate.
Residence determines somebody's liability to UK income tax and capital gains tax, while domicile (generally speaking) defines liability to UK inheritance tax. This is not always straightforward, though, as the law and HMRC guidelines are complex and fluctuating. Although there is a statutory test for residence, there is no statutory definition of domicile, meaning that a detailed analysis of an individual’s intentions and life patterns is required.
We are well-versed in coordinating advice in different jurisdictions and tapping into our network of international offices, to ensure a complete approach to asset protection and succession planning.
Recent work includes advising Indian clients with a UK business worth more than £100 million on restructuring offshore trusts and wills, and advising on the restructuring of a £200 million Jersey trust for a non-domiciled UK resident. This included drafting terms of a new trust, negotiating them with new trustees, and advising on the UK tax consequences of the reorganisation.
We also provide advice on the implications of the UK's Double Tax Treaties with other countries – and, in certain cases (most notably India and Pakistan), on where significant inheritance tax savings can be made, simply by restructuring clients' wills.
A number of our clients are UK residents but receive distributions or benefits from offshore trusts. We advise both UK and non-UK resident clients on the UK tax implications of these and also guide beneficiaries and trustees of offshore trusts in disputes about the competing interests of different beneficiaries and/or disputes between trustees and beneficiaries.
As well as acting for individuals, AG represents a number of institutional offshore trust companies. Here, we provide UK tax and trust advice, particularly regarding UK property holding structures.
As a full service law firm, other capabilities that may be of interest to international individuals include:
- Investor visas
- Tax advice, covering:
- Income tax
- Corporation tax
- Capital gains tax
- Inheritance tax
- Annual tax on enveloped dwellings
- Stamp duty land tax
- High-value residential conveyancing
- Commercial property sales and purchases
- Reputation management services
- Corporate and banking experience