The International Tax Round Winter 2025

Editor’s message

There is something quite distinct about December. Evenings lengthen, lights glow brighter and memories of times passed seem easier to surface. Somewhere between the cheer and sparkle of parties, the end of the year feels like an overdue exhale, releasing a paradox of emotions.

Conscious of where I have placed my energy this year, I take this moment recalibrate and look ahead, despite the undeniable undertone of loss and longing. I quietly continue to carry the ache of losing my mum earlier this year, all the while feeling deep gratitude for what this season offers – togetherness. This helps me remember the inspirational people, rich opportunities and memorable experiences that have shaped my year. It also makes my mum’s legacy clear as I feel her inner strength and values engrained in me.

Looking at the world of tax, the changes in budget last year have had a remarkable impact on the volatility and challenges this year. With another year and budget behind us, there has been no dramatic change in direction in the offshore and international space. This year’s conversation has been less about rules and where to pay the least tax. Instead it has been future-focused, with curiosity shifting to how, where and in whose hands our wealth sits and how families and wealth can thrive over the next five, 10 and 20 years. It’s this change in narrative that shape and strengthen the international community that I am fortunate to work alongside.

For now, I look forward to a well-earned break. Earlier, and further from home than usual, I’ll head to Singapore and Australia with a brief stopover in Qatar. I’m most excited about a reunion with a close cousin in Singapore, after which I will meet my rock in every sense – my precious dad. This trip will allow me the welcome opportunity to spend time with my maternal cousins for a family wedding. I know my mum would have loved to be there celebrating this special occasion.  She will be front of mind and there in spirit.

I’ll be away but I’ll no doubt find myself connecting with members of our wider international network – a reminder that work isn’t always work, and these relationships reach a place beyond business. Exciting plans await in 2026, both professionally and with travel, so stay tuned for updates.

My intention for the year ahead is simple: to build with purpose, to deepen the relationships that matter, and to continue growing, both professionally and personally, with clarity and courage.

Christmas in the southern hemisphere with a beach involved feels different, but I wouldn’t have it any other way.

However, and with whoever, you choose to spend the festive season, I wish you peace, rest and joy. Merry Christmas and a Happy New Year to one and all!

Contents

• The rise of ‘Plan B’ residencies.
• Family Investment Companies vs offshore structure.
• Autumn Budget 2025 – Labour of love?
• UK VAT refunds for non-UK businesses.
• Temporary Repatriation Facility – are you ready to bring funds to the UK?
• Singapore – Tax on capital gains from disposal of foreign assets by Fiden.

The rise of ‘Plan B’ residencies

High net-worth individuals are no longer relying on single passport or single country strategy. We are seeing a rise in ‘Plan B’ arrangements; alternative residencies, second citizenships, and long-term visas secured, not for immediate use, but as a defensive and strategic option.

This is driven by a combination of political uncertainty, tax policy risks and lifestyle motivations (education, climate safety, access to healthcare and global mobility). Increasingly, tax residency is viewed not as permanent status but as a flexible strategic choice.

Mobility has quietly become one of the most important tools in modern tax planning. More clients are blending lifestyle decisions with tax planning – rather than asking “where do I pay least tax?” the emerging question is becoming “where can my family and wealth thrive over the next 20 years?”.

This is making international tax advice more personal and even more strategic than ever before.

When leaving the UK and taking residence elsewhere, care must be taken with future tax planning in mind as there are several tax considerations to account for. The move can quickly become a costly one if not planned properly.

An important consideration is to the Temporary Non-Residence (TNR) rules, whereby if you leave the UK for five or less years a multitude of income and assets may become chargeable on your return if these were held at departure such as capital gains, pension income, and dividends amongst others. Furthermore, announced at the recent Autumn Budget, distribution or dividend made from ‘post departure trade profits’ will now be caught under the TNR rules effective 6 April 2026.

Family Investment Companies vs offshore structure

There has been a noticeable pivot back towards UK-based Family Investment Companies (FICs) as an alternative to traditional offshore structures. Clients are attracted by:

• Corporate governance clarity.
• Greater control.
• Easier access to capital.
• More predictable UK tax treatment (in contrast to potential trust reform risks).

While FICs may not be a perfect solution, for some family groups they now offer a more stable and transparent long-term solution.

FICs require a long-term vision and thought towards the future and as such a large part of the tax advantages is related to the initial phase of the FIC, where gifting of shares prior to the first purchase of FIC assets means growth is accrued to the next generation.

FICs can create challenges and there is no one size fits all approach to efficient tax planning. Whether a FIC is the right strategy for you and your family cannot be simply answered by a Google search! Should you wish to explore the idea of a FIC, careful planning is needed and a review of your goals should be undertaken. If you require assistance with this, please do get in touch.

Autumn Budget 2025 – Labour of love?

The highly anticipated Autumn Budget, despite being undercut by the OBR dropping the ball, was presented by Rachel Reeves on 26 November 2025 and has brought a raft of new measures. But what are the headline tax changes for non-residents, landlords and former non-doms?

One of the main changes across the board is the increase in Income Tax on savings, dividends and property income by 2%, a sweeping adjustment that leaves employment income at the same rate.

A Council Tax surcharge is to be introduced of £2,500 for homes worth more than £2,000,000 and £7,500 on homes worth more than £5,000,000. A costly increase for the landlord effective April 2028.

Whilst the details are yet to be released, legislation to make minor corrections to the residence-based tax regime brought in by the Finance Act 2025 will be introduced. These changes are technical and should supposedly have minimal impact on individuals. This will be retrospective and in force from 6 April 2025 once enacted.

Until now, dividends received shortly after leaving the UK from trade profits after departure were not subject to Income Tax under the Temporary Non-Residence (TNR) rules. However, now all dividends will be taxable if you are caught under the TNR rules.

Those taxpayers previously benefiting from an Overseas Workday Relief claim will also be hit, whereby the government intends to limit the amount of income that can be excluded from PAYE under such provisions to 30%.

Tucked away in the measures are provisions that will apply to trusts funded by non-UK domiciled individuals before 30 October 2024. Those trusts now fall within the relevant property regime where the settlors are long term resident and subject to IHT charges and such charges will be capped at a maximum of £5 million. This would result in a saving for any trusts holding taxable assets worth more than £83 million.

As they say, the devil is in the details. Watch this space. You can find our full budget summary here.

UK VAT refunds for non-UK businesses

It is not widely known, but many non UK businesses can potentially recover VAT they incur when in the UK on business.

The UK are quite generous on what VAT can be reclaimed. For example, VAT on hotel stays or short term car hire is recoverable. It is also possible to recover VAT on other substances, such as meals and, in some cases, basic entertaining. In certain circumstances, the UK even allows VAT to be recovered on goods that are imported into the UK.

There are a number of rules that apply, for example the country where the non UK business is established must have a similar arrangement with the UK. There are also some expenses that cannot be reclaimed but these are quite minor.

Finally, there are time limits for when a claim can be made. The year runs from 1st July to 30 June and a claim must be submitted within six months, being 31 December. Once this deadline has passed, a claim cannot be made.

The Gerald Edelman VAT team can advise further and even prepare the claim for you.

Temporary Repatriation Facility – are you ready to bring funds to the UK?

I’m sure many of you by now have heard us wax lyrical about the changes to the non-dom regime and the treatment of overseas income and gains. One such new addition we are focusing on is the Temporary Repatriation Facility, which is available to be claimed in respect of the 25/26, 26/27 and 27/28 tax years.

This facility allows former remittance basis users to pay a flat charge of 12% in the first two years, and 15% in the last year on any and all untaxed unremitted income and gains. This designation is not limited solely to liquid funds, as you can designate ‘non-clean’ funds that have been used to purchase assets such as property and securities. Once designated, they can be freely brought to the UK without charge.

The funds do not have to be remitted once the charge has been paid and can be brought to the UK whenever you deem appropriate – it just has to be designated within these three years. It is therefore paramount that a review of untaxed, unremitted income and gains is performed in conjunction with your future obligation and tax planning in the UK. If you require assistance with this, please do get in touch.

Singapore – Tax on capital gains from disposal of foreign assets by Fiden

Singapore has traditionally not taxed capital gains. However, from 1 January 2024, Section 10L of the Income Tax Act 1947 introduced tax on gains from disposals of certain foreign assets when the proceeds are remitted to Singapore.

Section 10L primarily targets Singapore-incorporated entities that are part of multinational groups. An ‘entity’ includes companies, partnerships and trusts (but not individuals). ‘Foreign assets’ include overseas real estate, shares, debt instruments and other movable or immovable property. The tax applies to entities within ‘relevant groups’ that lack sufficient economic substance in Singapore.

Entities may be exempt if they demonstrate adequate substance, such as carrying out core income-generating activities, employing staff, and maintaining operating expenditure locally. The Inland Revenue Authority of Singapore has published guidance on these requirements.

Section 10L reflects Singapore’s response to global scrutiny of foreign source income exemptions and the emphasis on substance over form in international tax planning. It highlights the importance of reviewing holding structures and investment strategies to ensure compliance with evolving tax rules.

For more information, please reach out to Fiden.