Private Wealth Tax
High and Ultra high net worth individuals, non UK domiciled individuals, shareholders and their trustees and family foundations all need to be able to manage their tax affairs to best effect for their businesses, their families and themselves.
We advise a wide range of clients including UK and internationally-based entrepreneurs and high net worth individuals (including royalty), company directors, investors, trustees, family offices and banks on income tax, capital gains tax, inheritance tax and stamp tax mitigation.
Our services include:
- Coming to the UK - We advise on tax issues around immigration. We have particular experience in advising on the tax implications for executives working in the UK and on tax planning for non-UK domiciled individuals.
- Leaving the UK and disposal of UK assets – We advise those leaving the UK, both permanently and on a temporary basis, on the most tax efficient way to do this. We have particular experience in managing the mobility of key executives.
- Family businesses and shareholder directors - We can guide you through the tax aspects of offshore investment holding structures (including trusts and foundations), private equity transactions, share sales, initial public offerings and full listings.
- Investing in other people - We can help you to manage the risks of business angel-type investments, taking advantage of any available tax breaks or spreading the risks of larger investments through joint ventures, investment funds or other collective investment structures.
- Tax enquiries and investigations - Our market-leading team of lawyers, accountants and former senior tax inspectors can help you to minimise your tax liabilities and manage any enquiries by the UK tax authorities. We have particular expertise in settling tax irregularities arising from assets held offshore, using disclosure facilities such as the Liechtenstein Disclosure Facility (LDF) or the UK/Switzerland agreement.
- Estate Planning - We can help you to ensure your wealth is protected, that tax liabilities are minimised, and that your dependents have been properly provided for, both now and in the future. When appropriate this can include advice on family charters, private trust companies and tax efficient structuring and domicile issues.
- Asset protection – We can advise on trust or other structures to protect against unforeseen business liabilities, family disputes or for succession planning.
- Philanthropy - Whether you are looking to make a one-off donation or are considering setting up your own charitable trust, we can help you support the projects you care passionately about.
- Real Estate - Our experts will ensure that you structure, acquire, hold and manage your Real Estate in the most advantageous way possible, both from a tax and estate planning perspective.
- Advice to HNW client on investment by him, and trustees of family UK and offshore trusts into "private" OEIC. Including advice on tax treatment, reviewing draft documentation to identify areas of concern and liaising with manager to address these
- Technical and strategic advice to Isle of Man lawyers in context of client's divorce, concerning spouses interests under an offshore remuneration trust and potential tax treatment of payments out.
- Managing advice to ultra-HNW US resident on tax treatment of family trusts (and benefits provided or deemed to be available) in context of UK resident daughter's divorce proceedings
- Advising UK and non UK resident beneficiaries of offshore trusts in respect of issues arising from inadvertent "import" of offshore trusts – including action against the trustee
- Advice to HNW individual on risks under anti-avoidance legislation on establishment of offshore holding company structure (including rules on transfer of assets abroad and attribution of gains of close companies)
- Advising a group of UK and non-UK domiciled managers on new investment structured through Luxembourg company and Dutch Stichting, including on the transparency or otherwise of the Stichting, whether the structure could prejudice the ability of the non domiciled managers to keep their income and gains out of the UK tax net, and implications of Dutch tax requirements for the investment to be structured through an Isle of Man holding company
- Advice to UK entrepreneur relocating to US/Cayman on securing break in UK residence and tax-efficient structuring of employment arrangements going forward.
- Advising a non-UK domiciled individual on establishment of non-UK structure to hold UK investment and trading properties
- Advising consortium of landowners (including both UK and non-UK residents) on complex land pooling arrangements prior to sales of land to developers
- Complex restructuring of high value offshore trusts for several major entrepreneurial families
- Advising offshore trustees and beneficiaries of the structures they administer on the UK tax technical analysis of complex offshore structures including advising on disclosure to HMRC of UK tax irregularities and advising on the most tax efficient structure going forward.