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February 20, 2013

International and Cross-Border Tax

International and Cross-Border Tax

Lifetime Tax planning and advice

We advise our clients (who include UK and non-UK nationals as well as UK domiciled and non UK domiciled individuals – non-doms) on UK inheritance tax and capital gains tax issues.

In particular we advise our clients which of their assets will be taxed on their death by the UK tax authorities and which assets will not be taxed.

For our clients who are not-domiciled in the UK (non-doms), or not yet domiciled in the UK, we advise how to structure their assets so that they remain outside the UK inheritance tax net as ‘excluded property’.

We also provide capital gains tax advice to non-residents on their UK property and the advantages of rebasing value or time apportionment.

Tax on death

A key strength is our ability to analyse, build, prepare and present comprehensive domicile cases to the UK tax authorities, making it faster and easier for them to agree a deceased individual’s domicile.

This is especially important for the estates of individuals who did not consider themselves to be UK domiciled at the end of their life, as a UK domicile will mean their worldwide estate will be assessed for UK inheritance tax purposes.

Domicile and Residence (The Statutory Residence Test)
Other than the location of our client’s assets, domicile and residence are the two ‘connecting factors’ in the UK that connect our clients to the UK tax regime, while in other jurisdictions, such as the USA, nationality is a connecting factor.


Understanding domicile and residence for tax purposes is essential to our clients and we are adept at analysing and explaining these complex subjects in clear, understandable terms including:

  • Common law domicile.
  • Deemed domicile.
  • Civil law domicile.
  • Domicile elections.
  • The Statutory Residence Test.