What we cover
Cross-border tax, done properly.
We advise on the areas where UK tax meets other jurisdictions. Every conclusion is set out by reference to the legislation and, where relevant, the treaty and case law.
Our services
Residence & the Statutory Residence Test
Day-count, ties and split-year analysis, documented so your position holds up if HMRC asks. Planning for arrival and departure years.
The FIG regime
The four-year foreign income and gains relief for new arrivals, eligibility and claims, and managing the transition from the former remittance basis.
Inheritance tax & long-term residence
Excluded property, the residence-based IHT rules, trusts and estate planning for internationally mobile families and their assets.
Corporate residence & permanent establishment
Central management and control, PE risk, and determining where a company is genuinely taxable. Structuring for groups operating across borders.
Treaties & double tax relief
Residence tie-breakers, withholding taxes, relief claims and ensuring the same income or gain is not taxed twice.
Exits & cross-border transactions
Disposals of businesses and assets with an international element: available reliefs, reorganisations and timing.
Offshore trusts & holding structures
Settlement, migration and reporting for trusts with a UK connection, and holding structures that are robust and defensible.
Not sure which of these fits your situation? Tell us what is happening and we will point you the right way.