Beyond Residence - Navigating UK Tax Exposure for Non-Doms & 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, remittance traps, 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 remittance basis - traps and planning boundaries
• Core mechanics of the remittance basis and interaction with UK-dom vs non-dom status (high-level and policy-consistent)
• Frequent problem areas: mixed funds, loans to/remittances via companies and trusts, use of credit cards, offshore portfolios funding UK expenses
• Practical file notes and bank instructions that reduce accidental remittances
• Trusts, foundations and family investment structures
• Key UK concepts: settlor-interested trusts, protected settlements, onward gifts, matching rules (high level, concept-driven)
• 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 non-dom structures, 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
Aa 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

This pre-recorded webinar will be available to view from Monday 28th September 2026

Alternatively, you can gain access to this webinar and 2,101 others via the MBL Webinar Subscription. Please email webinarsubscription@mblseminars.com for more details.