Non-Domiciled and Non-Resident Tax Planning

Cross-border tax planning under the new residence-based rules

  • 4-year FIG regime - Relief on foreign income and gains for new UK residents
  • Long-term residence test - When the 10-out-of-20-year rule brings worldwide assets into Inheritance Tax
  • Offshore trusts - Reviewing existing trust structures after the April 2025 changes
  • Split-year treatment - Applying the Statutory Residence Test when you move part-way through a year
  • Foreign income reporting - SA106 disclosures and foreign tax credit relief
  • Double tax treaties - Tie-breaker rules where you are resident in two countries

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