It is crucial that individuals who are looking to move to or leave the UK, or indeed those who habitually spend any significant time here, understand their tax residency position and how this exposes their worldwide assets and income to UK taxation.

We have considerable experience advising international clients on their tax residency status, as well as developing strategies to ensure individuals legitimately secure the best tax advantages for their personal circumstances.

The FIG regime provides full tax relief on most non-UK income and gains that arise during an individual’s first four years of tax residence after a period of at least ten consecutive years of non-UK residence.

This potentially offers new arrivers to the UK the opportunity to shelter non-UK income and gains from UK taxation. Unlike the pre-2025 remittance basis, eligibility for the FIG regime is determined solely by tax residence and is therefore accessible to individuals who have previously lived in the UK more than 10 years ago, and to those born in the UK.

The FIG regime is a complicated area of taxation, and professional advice must be sought before considering whether it is appropriate for you. Dixon Wilson can guide you through this.

• Assessing your eligibility to claim the regime;
• Registration for self-assessment and assistance to file tax returns with appropriate claims;
• If you are an employee, considering your ability to claim Overseas Workday Relief and making that additional claim;
• Advice on a transition to being taxed on worldwide income and gains when entering the 5th year of UK residence, or in relation to ceasing UK residence.

A critical stage of planning for an individual moving their residence between tax jurisdictions is either before they have arrived in the UK, if they are coming to live here, or before they leave the UK, if they are moving abroad. We have experience with the vast array of issues which need to be considered, ranging from analysing double tax treaties to considering the UK tax position of offshore structures.

Tax can be saved by taking advice prior to your arrival or departure in relation to the structuring of your affairs.

All individuals who have been UK resident for at least 10 of the last 20 years will be long-term UK residents and their worldwide assets and those of trusts settled by them will be within the scope of UK inheritance tax. If a UK long-term resident ceases UK residence, there will be a tail period where their non-UK assets and those of their trusts will remain within the scope of UK IHT.

Individuals who have lived in the UK for a significant period of time but are not UK domiciled face further challenges, particularly where they have claimed the now abolished remittance basis in previous years and have not maintained a source of clean capital outside of the UK.

We can help you with areas such as:

• Tax planning in relation to mixed funds which have been partially derived from foreign income and gains;
• Understanding of the taxation of income and gains arising in your offshore structures including trusts, corporates and partnerships;
• Gifting assets, both in the UK and outside the UK, to family members, other individuals and charities;
• Borrowing funds outside the UK to remit without crystallising an immediate tax liability;
• Remitting funds to invest in UK businesses tax efficiently;
• The inheritance tax implications and planning when living in the UK in the longer term, including the implications of becoming a 'long-term UK resident'.

HM Revenue & Customs require any individual who is resident in the UK and wishes to claim the Foreign Income and Gains (FIG) regime to submit an annual tax return.

We can help you with areas such as:

• Registering your arrival in or departure from the UK with HM Revenue & Customs;
• Preparing your annual UK tax return;
• Calculating and advising you of your tax liabilities well in advance of payment deadlines;
• Liaising with HM Revenue & Customs on your behalf, including dealing with any enquiries or investigations;
• Liaising with tax authorities in other jurisdictions in relation to your UK tax position;
• Advising on the records which need to be kept.

Non-UK resident and UK resident international individuals who wish to own property in the UK are presented with a number of ownership options. We are able to advise on the implications of the various structures and how they are taxed in the UK, to help decide the most suitable solution for you.

We can also suggest the most appropriate method of funding the acquisition if funds are to be remitted from outside of the UK. Alternatively, we can review existing structures if the property has already been acquired, to ensure maximum tax efficiency.

Historically, domicile has been a key factor in determining the tax position of short-term UK residents. Although it is much less relevant since 6 April 2025, domicile still has relevance for some individuals, including those who have lived in the UK and benefitted under the old regime or where there are old structures that pre-date the 2025 changes.

Domicile is a complex concept, but we are able to provide clear advice on how this affects an individual’s UK tax position, and that of entities such as family trusts or companies.