International - Personal tax planning

We provide bespoke international personal tax advisory services on a wide range of fiduciary matters to individuals who are either:

  • resident but not domiciled in the UK; or
  • not resident in the UK but have ongoing UK tax implications; or
  • UK resident and have international issues.

Our Consultants can provide advice and solutions on a whole range of private client matters including:

  • Personal tax residency issues and the introduction of the new Statutory Residence Test
  • Remittance basis aspects of personal taxation for non-UK domiciled individuals
  • Introduction of UK business investment relief for non-UK domiciled individuals
  • Residential property ownership planning for non-UK residents
  • Inheritance tax mitigation for non-UK domiciled individuals
  • UK tax implications for beneficiaries of offshore trusts
  • Inheritance tax issues for spouses/civil partners where one is UK domiciled and the other is non-domiciled
  • The application of tax treaties between the UK and other tax jurisdictions and how they are applied
  • Introduction of changes to UK tax law in respect of company owned high value residential property (ATED)
  • Contractual Disclosure Facility and other offshore related tax amnestiesHow can PKF FC help?

How can PKF FC help?


“People are more internationally mobile these days and it is not uncommon for someone living in the UK to go overseas to work or to emigrate or for foreigners to come and live or spend time in the UK.

The residence status of an individual is key to their tax exposure in the UK and we have specialists that can guide you through our tax legislation. New legislation was introduced from 6 April 2013 to determine an individual’s residence status but it is long and complex.

Even individuals who live abroad can be UK resident and should be checking how the change in legislation may affect them. Where a person finds that they are resident in more than one country under local rules, it is then important to consider if there is a double tax treaty between the countries and, if so, to determine the treaty residence status of that person which will denote how they are taxed between the countries.

Non-UK domiciled individuals living in the UK may be entitled to certain tax reliefs but the legislation is particularly complex and includes a wealth of anti-avoidance statute. Bringing money to the UK can cause a UK tax charge but relief for business investment and carefully structuring the funds offshore can substantially limit the UK tax payable.

Non-domiciliaries coming to the UK to work and who undertake some of the duties of their employment overseas can often claim relief from UK tax on the overseas work for the first two or three years of becoming UK resident. However, in order to qualify for the relief, certain conditions must be met and it is all too easy for an unadvised individual to fail the conditions to claim.

PKF Francis Clark has recognised that the demand for international advice is growing and we have invested in staff with specific expertise in this area.”

In this section


    HMRC will consult later this year for unlimited penalties and prison sentences for anyone who does not declare offshore income 

    No Safe Tax Havens, 14 Apr 14

    56,000 people have come forward through HMRC’s disclosure facilities 

    No Safe Tax Havens, 14 Apr 14

    Average worker in the UK faced a tax burden on labour income of 31.5% in 2013 compared with the OECD average of 35.9% 

    OECD Taxing Wages rpt, Apr 14

    HMRC consultation document for taxation of non-UK residents disposing of UK residential property after 5 April 2015 released on 28 March 2014 


    Estimated population of UK by nationality: South West 4.5% non-British compared to 22.4% in London and 7.8% for whole of UK. 

    Commons Lib Std Note, Jan 2014

    Net emigration of UK nationals was 70,000 (highest of EU countries that published results). 

    Commons Lib Std Note, Jan 2014

    Net immigration of foreign nationals in 2012 was 286,000 (3rd highest of EU countries that published results). 

    Commons Lib Std Note, Jan 2014

    108.2 million journeys into the UK in the year to 30 June 2013, a 2% rise compared to the previous 12 months. 


    1.28 million highly-skilled British citizens now living abroad. 

    OECD, August 2013


Leading Edge Alliance Awards 2013
Taxation Awards 2014
The British Accountancy Awards 2014
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