Ahead of PCD's annual Geneva networking dinner, our fringe seminar with HIGHVERN brought together four leading voices in cross-border wealth planning. Across three sessions, one theme ran throughout: the UK and Switzerland are each going through significant structural change, and families moving between them need advisors who are coordinated across both jurisdictions, not just expert in one. The discussion moved from technical tax reform, through the practicalities of running a family's affairs day to day, to the lived experience of actually relocating.

1. UK non-dom reform — the trust protection is gone, but domicile still matters

Claire Randall (Farrer & Co) set out how the UK's shift from domicile to a residence-based regime has reshaped planning for internationally mobile clients. The new FIG regime offers genuine four-year relief on foreign income and gains, but the loss of indefinite trust protection from inheritance tax — combined with business property relief being halved — is now a leading driver of clients leaving the UK. For many long-established non-dom families, this combination alone has outweighed every other factor in the decision to relocate.

Domicile has not disappeared as a concept: HMRC retains 12- and 20-year lookback windows, and courts are taking an increasingly strict view of long-stayers' claimed intentions to return "home," even where that home holds no genuine remaining connection for the client. Randall also flagged that the three-year IHT tail available to non-doms who left before April 2025 is a wasting asset — many of those windows close from April 2028, triggering exit charges on associated trusts. The Statutory Residence Test, by contrast, is a clear day-count exercise, and Randall noted that many clients now arrive with inaccurate, AI-sourced assumptions about how many days they can spend in the UK.

2. The outsourced family office — service, not structure

Richard Joynt (HIGHVERN) resisted offering a fixed definition of "family office," noting that even regulators have abandoned the attempt after concluding the term covers everything from a single dedicated assistant to a thirty-person institutional team. His practical distinction: family office work is led by client service rather than legal structuring, with the advisor acting under instruction rather than managing a structure independently — and always stopping short of investment decision-making, which he sees as the clearest line a service provider can draw.

Real client examples ranged from replicating institutional-style support for a former private equity executive, to guiding a suddenly wealthy pandemic-era family through their first cross-border ownership, to coordinating UK subsidiary launches so overseas families could qualify for residence after the investor visa route closed. The session's clearest warning was about longevity: as family offices professionalise, they can accumulate more influence than any individual family member, creating a structural incentive against ever recommending their own wind-down — so principals should build an end point and family governance into the model from the outset. Joynt also pointed to the rise of the informal "virtual family office" — a trusted network of advisors functioning collectively as a family office without any formally holding that title.

3. Cross-border planning for Swiss-based families — trusts, succession and relocation

The closing panel — Guillaume Grisel (Schellenberg Wittmer), Vincent Roduit (LeoVest), Claire Randall and Richard Joynt — worked through the practical mechanics of the Swiss side. Trusts remain far more favourable than foundations under Swiss law and tax practice, largely because Swiss maintenance foundations are prohibited outright and private foundations may trigger a gift tax of up to more than 50 per cent in certain cantons on establishment, whereas trusts face neither restriction. The use of offshore companies creates tax risks in Switzerland if they are not clearly managed from abroad. In particular, the federal withholding tax on interest and dividends (including those in kind) must be taken very seriously.

Switzerland's 2023 and 2025 succession reforms have reduced forced heirship and opened up succession law elections for dual nationals, giving families more flexibility to route wealth into trust or make direct bequests. The incoming UBO register applies to Swiss companies, not trusts, and will not be publicly accessible. Roduit's relocation case study showed both how fast a well-prepared move can go — one client achieved Swiss residency within 48 hours of paperwork being submitted — and the pitfalls that slow others down: joint accounts creating unexpected capital gains exposure, delayed vehicle re-registration undermining a clean day-count position, and buying property before a residence permit is secured, which forecloses options under Switzerland's Lex Koller restrictions.

The takeaway

Whether the starting point is a UK domicile question, a family office mandate, or a Swiss relocation, the panel's shared advice was the same: coordinate early across jurisdictions, treat departure and arrival planning as ongoing rather than one-off exercises, and be alert to how much client assumptions — increasingly shaped by generic AI guidance — now need correcting before real planning can begin. For PCD's network, the throughline is that these three areas are converging into a single, continuously managed planning exercise, and the advisors best placed to help are those already working across all three.