Beyond Residence - Navigating UK Tax Exposure for Internationally Mobile Individuals & Non-Resident Companies

Introduction

This webinar examines the complex intersection of UK tax rules with internationally mobile individuals, owner-managed groups and investment structures that have UK connections. It takes a practical approach to issues such as residence, the four-year FIG regime and legacy remittance issues, trusts, investment holdings and the often-overlooked exposure of non-resident companies to UK tax through central management and control, UK permanent establishments and remote board decision-making.

Drawing on real-world patterns, risk ‘red flags’ and modern safeguards, this webinar provides guidance that advisers can apply when working with mixed private-client and corporate audiences.

Designed for tax advisers, accountants and lawyers supporting internationally mobile individuals, family-owned or owner-managed groups and investment structures or overseas companies with UK influence, this webinar offers actionable insights, case studies and clear guardrails to help navigate UK tax exposure effectively for both individuals and non-resident companies.

What You Will Learn

This webinar will cover the following:

• UK tax residence for individuals - current landscape
• Concise refresher on the statutory residence test (SRT): automatic tests, sufficient ties and common pressure points
• How lifestyle changes (hybrid work, global mobility, second homes) create unplanned UK residence
• Documentation and behavioural evidence advisers should encourage (travel logs, employment contracts, board packs)
• The four-year FIG regime and legacy remittance issues
• Eligibility for the four-year FIG regime, the ten-year non-residence condition, claims and practical limitations
• Treatment of pre-6 April 2025 foreign income and gains of former remittance-basis users
• Temporary Repatriation Facility, mixed funds, ordering rules and evidential safeguards
• Practical banking and file-management steps to distinguish current-year funds, taxed capital and legacy pools
• Trusts, foundations and family investment structures
• Key UK concepts: settlor-interested trusts, the post-6 April 2025 position, including the removal of trust protections for current foreign income and gains, legacy protected income and gain pools, onward gifts and matching rules
• Aligning trust distributions, loans and benefits with residence profiles of beneficiaries
• Governance essentials: trustee minutes, letters of wishes, investment policies and communication with UK advisers
• Non-resident companies with UK touchpoints
• Central management and control (CM&C) in practice: what still matters (board location, strategic decisions, documentation)
• Remote and ‘virtual’ boards: when UK-based decision-makers start to shift corporate residence or create PE risk
• Interaction of corporate residence risk with UK PEs, DAPE rules and MLI changes
• PE exposure for investment and trading structures
• Typical risk cases: UK directors of offshore companies; UK investment advisers and fund principals; UK-based senior executives of ‘overseas’ holding vehicles
• How to separate advisory functions from decision-making; drafting mandates and engagement letters carefully
• Consistency between company secretarial records, board packs, email trails and tax filings
• Anti-avoidance guardrails
• Overview of relevant UK anti-avoidance measures at a high level (e.g. transfer of assets abroad, targeted rules, substance expectations)
• How these interact with offshore structures and former remittance-basis arrangements, offshore companies and trusts
• Framing ‘do/don’t’ guidance that is defensible but usable for clients
• Case studies and practitioner toolkit
• Case studies:
• A mobile executive with offshore investments
• A family trust with UK-resident beneficiaries
• An ‘offshore’ holding company effectively run from London
• Practical checklists:
• Residence and remittance risk review
• CM&C and PE risk review for non-resident companies
• Trust/beneficial ownership documentation essentials
• How to communicate these issues to clients in clear ‘rules of engagement’ language