We often advise individuals who are moving to the UK on how to structure their financial and business affairs in a tax efficient manner, prior to their arrival.
A recent case in point was a non-UK domiciled and non-UK resident individual relocating to the UK. Our client was entering the UK on a Tier 1 Investor Visa and, following an initial consultation, we prepared a detailed tax report to plan for his arrival in the UK. In particular, the client wanted to purchase a family home in the UK and our report therefore discussed the tax implications of doing so.
Initially, however, it was necessary to consider the client’s residence position between the grant of his visa and subsequent arrival in the UK, and the effect of the relevant double tax treaty. It was important that he looked to establish “clean capital” funds prior to his move to the UK in order to fund his future lifestyle and capital requirements.
The natural extension of this was to propose an appropriate structure for his UK and non-UK bank accounts, including how to segregate of investment income and gains, and practical issues such as the use of credit cards after moving to the UK.
Turning to the property, the key question was whether personal ownership or use of an offshore trust/company structure would be appropriate. This involved looking at the tax considerations at each key stage in the ownership process, i.e. funding, occupation and disposal, and the position if the client were to leave the UK at a future date. We also needed to ensure that the mortgage was structured and funded tax-efficiently.
Similar issues commonly arise for individuals coming to the UK, and the challenge is often to find a solution which is both practical and tax-efficient. If you or your client are moving to the UK, or indeed are already here and require advice in respect of your current situation, please contact us.
If you are looking to re-locate to the UK and require legal advice, we can also refer you to experienced immigration specialists.
