International private client tax services

If you have not done so already you must inform your employer of your plans and seek their agreement as there are a number of areas that they must consider, for example – the operation of payroll, National Insurance Contributions (social security), employment law, as well as potential corporation tax implications for the company depending on the duties you will perform overseas.

From your personal perspective, it will broadly depend on your tax residence status and where you are performing your duties as to how your salary will be taxed going forwards.

Our Global Mobility Team can provide advice to your Employer and our Private Client Tax Team can advise individuals.

Your tax position is broadly dictated by your tax residence status.  With this in mind you must be clear on how to cease UK tax residency (in accordance with the UK Statutory Residence test) and be able to manage this going forwards if you plan to make trips back to the UK. 

Therefore, you would want to choose a jurisdiction that you would be happy to spend the majority of your time in so this can be achieved.

If you wished to take advice on this it is recommended that you compile a list of potential countries that you would consider living in full-time, along with your current and potential future sources of income and gains so we can consider this further.

A gift of cash to an individual based in the UK will typically not attract any UK tax charges nor reporting requirements.  

If the funds are from overseas but are gifted to you from a long-term resident* of the UK, you may be liable to UK inheritance tax if they pass away within 7 years of making the gift to you.

It may be that the UK beneficiary is liable to gift or estate taxes on receipt of the gift in the applicable overseas jurisdiction and if in doubt it is recommended that you seek local tax advice. 

Depending on what you do with the funds in the UK, they may then be liable to UK inheritance tax if held in your estate on death, or the funds may generate income or gains that are taxable in the UK during your lifetime.

*A long-term resident is an individual who has been resident in the UK for at least 10 out of the previous 20 tax years.

If you are UK tax resident the starting point is that you are taxable on worldwide income and gains.  It is therefore highly likely that this income would be taxable in the UK also.

There may be the possibility to claim a tax credit in the UK for tax paid overseas, but please note this may not be creditable in full and would be subject to the terms of the Double Tax Treaty between the UK and the overseas jurisdiction in which you have paid the tax.

If you are selling your ‘main residence’ in the UK then often no UK capital gains tax is due if you have occupied it as such throughout the entire period of ownership.  Complications can therefore arise if you have multiple residences and your ‘main’ property is unclear. Between spouses or civil partners, there can also only be one main residence for tax purposes.

If you have multiple homes globally, your tax residence status may be unclear if you spend time in each home.  Furthermore, if you are performing work whilst in those homes this could trigger a tax reporting requirement and potential tax liability in the jurisdiction that you are performing these duties.

Your exposure to UK IHT depends on how long you have been tax resident in the UK.  If you have been UK tax resident for at least 10 out of the previous 20 tax years, you will be classed as a long-term resident and therefore liable to UK inheritance tax on your worldwide assets. Broadly, it will then require 10 years of non-UK tax residence for non-UK assets to fall outside the scope of UK IHT.*

Certain gifts made during an individual’s lifetime can trigger immediate UK inheritance tax charges, or potential inheritance tax charges if you were to pass away within 7 years of making the gift.

Further information on the UK inheritance tax regime can be found here.

*Please note that there has been a recent reform to how exposure to IHT is determined, so if you have previously received advice on this, it might need to be revisited.

If you wish to gift away assets in order to mitigate your exposure to UK Inheritance Tax, the main point to raise is that you must no longer retain a benefit from that asset following the gift, or it may still remain in your estate (and be in the estate of the beneficiary of the gift also).

There can be structures put in place that mean you retain legal but not beneficial ownership if you wished to still remain in control of who can benefit from these assets going forwards, but it cannot be you.

Certain gifts made during an individual’s lifetime can trigger immediate Inheritance Tax charges, or potential Inheritance Tax charges if you were to pass away within 7 years of making the gift.

If you are UK tax resident and are considering withdrawing from overseas pensions, the tax position on this is typically dictated by the terms of the Double Tax Treaty between the UK and the jurisdiction in question. 

If there is a Double Tax Treaty in place, this will often state which jurisdiction holds the taxing rights and this can also differ depending on whether you take a lump-sum or an income drawdown.  A formal claim under the Double Tax Treaty may be required to be made in the UK.

There may also be scope to consolidate these pensions, this would require further review and specialist advice and is often an expensive process so it may depend on the size of the pension pots as to whether this is worthwhile pursuing.

The taxation of overseas trusts is a complex area of UK tax legislation. There are some general rules that can apply but the UK tax treatment will depend on the type of Trust structure that is in place.

If you are in receipt of distributions from an overseas trust you may need to file a UK tax return to report the distributions and may be liable to UK income tax and/or UK capital gains tax.

The Trustees and Settlors may also be liable to UK taxation and have UK filing requirements. We would recommend that a review is undertaken if you are unsure of the UK tax position.

The Trustees and Settlors may also be liable to UK taxation and have UK filing requirements. We would recommend that a review is undertaken if you are unsure of the UK tax position. Further comments on the treatment of overseas trusts can be found here.

Once you become UK tax resident, you will have to pay UK tax on your worldwide income and gains. Therefore, careful consideration needs to be given to determine when your tax residence changes, both under UK domestic legislation and against the criteria of any Double Taxation Treaty, if you are also tax resident elsewhere.

If you have not been UK resident in any of the previous 10 tax years, you may qualify for the Foreign Income and Gains (FIG) regime. The FIG regime allows you to exempt your non-UK sourced income and gains from UK taxation for the first four tax years of your UK tax residence.

There may be planning opportunities ahead of or following your move to maximise the benefits of the FIG regime. Additionally, consideration should still be given to tax levied on the foreign income and gains in the country of source, as well as the relevant Double Taxation Treaties with the UK to ensure cross-border compliance.

Since 6 April 2025, the UK has moved to a residence-based tax system, meaning individuals resident for more than four years are taxed on their worldwide income and gains, while those resident for ten years are subject to UK Inheritance Tax (IHT) on global assets.

For 2025/26, only 50% of foreign income is taxable for individuals moving from the remittance basis, though this does not apply to foreign gains. Additionally, Capital Gains Tax rebasing allows eligible individuals to rebase foreign assets to 5 April 2019 values, potentially reducing taxable gains.

New arrivals to the UK can benefit from the FIG Regime, which exempts foreign income and gains from UK tax for four years, provided they were non-UK residents for the previous ten years. However, electing into the FIG regime results in the loss of personal allowances and Capital Gains Tax exemptions.

With worldwide taxation now in effect, double taxation risks are a growing concern for individuals with cross-border financial interests. Strategies such as double taxation agreements (DTAs), tax credits and exemptions can help mitigate these risks and ensure compliance.

Navigating cross-border tax challenges requires strategic tax planning to minimise liabilities and structure tax-efficient investments. Seeking expert guidance ensures individuals comply with evolving regulations while safeguarding global wealth.