In this article for the October edition of French estate planning journal Ingénierie Patrimoniale, Edward Reed and Luisa Melendez look at recent developments in the UK.

• Practical considerations for people moving to the UK under the new tax regime, including:
  • an explanation of the foreign income and gains (FIG) regime;
  • the advantages of the regime (such as no “forfait” type cost, not being dependent on a type of visa, Overseas Workday Relief, transition measures, no short-term exposure to UK inheritance tax (IHT) on worldwide assets, and planning opportunities for realising gains outside of the UK); and
  • considerations in relation to trusts, central management and control, ownership of real estate, importing personal assets when moving, double tax treaties, succession/estate planning documents and life insurance wrappers.
• Recent case law on the meaning of “exceptional circumstances” in the UK’s statutory residence test in the recent decision in A Taxpayer v HMRC [2025] EWCA Civ 106.
• Upcoming reforms to APR and BPR.

Read the full article.