Beyond Tax: The Trusted Adviser’s Role in Global Relocation

By Stacy Lake, Partner – Head of International Private Wealth, Bolt Burdon

Stacy Lake, Partner – Head of International Private Wealth, Bolt Burdon

With the UK’s April 2025 reforms now in force, we’re seeing a new wave of HNW families leaving the UK. But the overwhelming motivation isn't just tax; it’s about reconfiguring a life. A truly trusted adviser delivers not only technical clarity but also foresight and empathy.

1. The Tax Changes: A New Landscape

   
   

The abolition of the remittance basis and the introduction of the Foreign Income and Gains (FIG) regime have significantly altered the UK tax framework for internationally mobile individuals. Under the FIG regime, those who have been non-UK tax resident for at least ten consecutive UK tax years immediately prior to arrival may enjoy a four-year window during which foreign income and gains are not subject to UK taxation. Once that period expires, income and gains are taxed on the arising basis, and the former protections of the remittance basis no longer apply.

Meanwhile, changes to inheritance tax (IHT) rules have introduced broader and more enduring implications. Under the new long-term residence condition, triggered once an individual has been UK tax resident for ten or more of the last twenty UK tax years immediately preceding a chargeable event such as death or a lifetime transfer, worldwide assets fall within the UK IHT net, regardless of the individual’s domicile status. This effectively displaces the previous deemed domicile regime and ushers in a residence-based approach to IHT.

More consequential still is the erosion of trust protections. Previously, excluded property trusts established before acquiring deemed domicile status could shield non-UK assets from IHT, and protected trust status preserved income and gains shelter for non-domiciled individuals. Under the new rules, both concepts are being dismantled. Trusts established during a period of non-domicile may now fall within the IHT net if the settlor later becomes a long-term UK resident, potentially subjecting even historic excluded property trusts to UK IHT, and in turn undermining conventional estate planning strategies.

Even departure from the UK offers no immediate relief. A tapered IHT "tail" may follow former long-term residents for three to ten tax years, depending on the number of tax years they previously spent in the UK. Those with ten to thirteen years of UK tax residence face a three-year tail. Each additional tax year of prior residence extends exposure by a further year, up to a maximum of ten years.

Altogether, these changes demand far more than a clean break in UK tax residence. They require a careful re-timing of trust structures, evaluation of succession pathways, and an advanced strategy that aligns FIG eligibility with IHT mitigation. With UK-situs property, rebasing opportunities, and offshore trusts all facing increased scrutiny, and transitional measures such as the Temporary Repatriation Facility offering narrow, time-limited benefits, early and comprehensive planning has become not just advisable, but essential.

2. What This Means for Leavers, Arrivers, Returners and the Undecided

   
   

For leavers, the decision to exit the UK must now be timed with surgical precision. Accessing the Foreign Income and Gains (FIG) regime, available only to those who have been non-resident for at least ten full UK tax years, offers a valuable four-year exemption from UK tax on offshore income and gains. However, this opportunity hinges on cleanly breaking UK tax residence under the Statutory Residence Test (SRT), which can be undermined by lingering connections such as a UK home, family presence, or part-year work. More critically, the Temporary Non-Residence (TNR) rules remain in force: if an individual returns to the UK within five tax years, certain gains and income realised during their non-residence may be retroactively taxed in the year of return.

Even those who leave cleanly may not escape fully. Under the new inheritance tax regime, individuals who have been UK tax resident for ten or more of the previous twenty tax years are classed as Long-Term Residents (LTRs). Upon departure, their worldwide estate remains exposed to UK IHT for a tapered period, starting at three years for those with 10 to 13 years of residence and increasing by one year for each additional year of residence up to a maximum ten-year tail for those with twenty years of UK residence. The implication is stark: leaving late or misjudging residence history could leave global assets within the IHT net long after departure.

For arrivers, the question is not just whether the UK is attractive today, but whether it remains so after the FIG window closes. Newcomers who have been non-UK tax resident for at least ten tax years may benefit from a four-year exemption from UK tax on foreign income and gains. But after that, full UK taxation applies. They must also monitor their long-term residency profile. If they accumulate ten UK tax years of residence over any rolling twenty-year period, they will enter the IHT net on their global estate. Pre-arrival planning, trust structuring, and home-country treaty considerations are essential, not luxuries.

For returning British expatriates, the new rules present a paradox. Those who have stayed out of the UK for over a decade may re-enter with full access to the four-year FIG regime, even if they were previously deemed UK-domiciled. But after year four, the tax net tightens again. If they cross the 10-in-20 tax year threshold, they may face IHT on their global estate, potentially as early as year five back in the UK. Between years four and ten, individuals may find themselves taxed on worldwide income and assets without the reliefs or trust protections once available. The long view must consider not just UK tax, but bilateral treaty protections and the tax rules of their current home jurisdiction.

Then there are the undecided, families still weighing their options. Some are mid-FIG regime, unsure whether to stay past year four. Others are inching toward LTR status, unaware of the IHT implications. Still others are late in their UK tenure, holding onto property or schooling arrangements that risk tripping the SRT or undermining non-residence. Whether they stay or go, their exposure may be locked in for years unless addressed now.

In today’s framework, tax residence is no longer a formality. It is a high-stakes status with enduring effects. Leavers, arrivers, returners, and fence-sitters alike must integrate tax planning into every personal, educational, and financial decision. The cost of inaction is no longer hypothetical. It is quantifiable, and long-lasting.

3. The Human Factors Behind the Headlines

   
   

For all the focus on tax reform, relocation decisions are seldom driven by tax alone. Clients often cite education, safety, lifestyle, or even climate as primary motivations. Others are drawn back to their home country by sentiment, family ties, cultural connection, or simply the pull of familiarity after decades abroad.

In practice, timelines are shaped less by legislation than by lived logistics: children’s school terms, a spouse’s career, or the care needs of aging relatives. Immigration rules, local bureaucracy, and the realities of settling into a new community often outweigh otherwise compelling legal or financial rationales.

Some clients appear ready in principle yet remain unprepared in structure, lacking the portability of their business operations, estate plans, or governance frameworks. Others act swiftly, only to realise belatedly that the cultural and operational consequences of a move were underexplored or underestimated.

It is in these human, often unpredictable moments that the adviser’s role expands. From planner to confidant, from technician to translator. The task is not merely to interpret tax rules, but to bridge the space between law and life.

4. The Role of the Trusted Adviser

   
   

This is where trusted advisers earn their title. The best do not let the tax tail wag the dog. They integrate tax law with a deep understanding of family dynamics, business strategy, and personal priorities. They develop enduring relationships with advisers in destination jurisdictions, ensuring that transitions are not only legally sound but holistically managed.

They ask the question that underpins all others: "What does success look like for this family, not just today, but for the decade ahead?"

Trusted advisers:

• Understand the complexities of FIG eligibility, IHT tapering, trust reforms, and the SRT and TNR frameworks

• Work in tandem with international counsel, immigration advisers, education consultants, and family office professionals

• Design adaptive structures that evolve with a family’s trajectory, whether that’s driven by tax, opportunity, or personal circumstance

  
  

In a world where global mobility intersects with shifting legal sands, it is no longer enough to optimise for exit or arbitrage. The adviser’s role is to deliver clarity, continuity, and confidence across borders, generations, and life phases.

5. Conclusion: The Landscape Today

   
   

This is the reality in June 2025. The ground beneath international families is moving. Reforms are live. Options are narrowing. Decisions are becoming stickier and more consequential.

A competent adviser ensures compliance and efficiency. A great adviser helps chart a course that respects the law, serves the family, and anticipates the future. Because while tax may be the catalyst, for most, it is not the cause. The move is about more than numbers. It is about lives in motion. And in that journey, the trusted adviser remains not just relevant, but essential.

Every family’s journey is different. If you're wondering how these reforms intersect with your personal or client decisions, it may be time to ask: do you have the right strategy, and the right adviser?