Jurisdiction · United Kingdom
United Kingdom: tax, residence, structures and banks
From 6 April 2025 the UK moved from the non-dom regime to a residence-based system: a FIG relief on foreign income and gains for the first years, then worldwide income tax, with inheritance tax tied to long-term residence. This hub gathers everything we write on the UK for private capital — tax and succession, holdings and funds, banks and relocation.
tax regime
residence-based (SRT)
newcomer relief
FIG — 4 years
inheritance tax
40% · 10/20-year test
structures
holding · fund · host-AIFM
library
banks & neobanks
Licensed banks and neobanks for corporate, personal and private banking accounts.
3S Money: British account for cross-border companies and RUB inbound3S Money is a London fintech for cross-border companies using multi-currency accounts, RUB intake, and operations across the UK, EU, UAE, and Hong Kong.read →Airwallex: business neobank for multi-currency accountsAirwallex is a business neobank for multi-currency accounts, cards, payment acceptance, API payouts, safeguarding and sanctions-sensitive onboarding checks.read →Barclays Premier Banking and Barclays Private Bank: £75k Entry and UHNW Tier of the British Retail-Premium BankBarclays Premier (from £75k) and Barclays Private Bank for UHNW: tiers, thresholds, and structure after UK ring-fencing 2019. Who suits this British premium bank.read →BCB Group: Payment Infrastructure for the Crypto IndustryBCB Group: FCA authorised payment institution, French EMI, BLINC 24/7 settlement network, fiat on/off-ramp, FX and custody for exchanges and funds.read →C. Hoare & Co: UK's Oldest Family Bank Since 1672 — 12 Generations of One FamilyC. Hoare & Co, Britain's oldest private bank since 1672: who it suits, entry thresholds, family ownership and client selection logic.read →Clear Junction: Banking Infrastructure for Payment CompaniesClear Junction: FCA-licensed EMI and VASP. Correspondent accounts, vIBANs, SEPA, Faster Payments and CHAPS rails for PSPs, EMIs and crypto firms.read →ClearBank: The Clearing Bank for Fintechs and EMIsClearBank: the UK's first new clearing bank in 250 years — FSCS protection, Faster Payments and CHAPS via API, embedded banking, ECB-licensed EU arm.read →Coutts & Co: British Private Bank Since 1692, £3M+ Threshold and NatWest GroupCoutts & Co — British private bank since 1692, part of NatWest Group, supervised by PRA and FCA. £3M+ threshold for HNW and UHNW: terms and wealth management.read →CurrenxieCurrenxie is a Hong Kong fintech offering multi-currency payment accounts, local details, FX, and bank-alternative routing for cross-border companies.read →Equals Money: British account for Americans and companies with significant FX demandEquals Money is a UK fintech for companies and US-linked clients with significant FX needs: account features, currency operations, and suitability limits.read →Evelyn Partners (formerly Tilney Smith & Williamson): UK wealth manager with £68B AUM and NatWest acquisition 2026Evelyn Partners, formerly Tilney Smith & Williamson: UK wealth manager with GBP68B AUM, NatWest acquisition 2026, tax and investment services.read →Goldman Sachs Private Wealth Management UK: $10M+ Entry and Institutional UHNWGoldman Sachs Private Wealth Management UK: London UHNW service under FCA/PRA, $10M+ threshold and fit for private clients.read →HEVN: Cross-Border Business Banking API Platform – Local EU/US/UAE Accounts, Stablecoins & PayrollHEVN is a Y Combinator fintech for cross-border business: named local accounts in EU, US, and UAE via partner banks, SEPA/ACH/SWIFT/UAEFTS and stablecoin payments, API and cards. Not a bank.read →HSBC UK Premier and HSBC UK Private Banking: £100k Entry and Path to UHNW TiersHSBC UK Premier and Private Banking: GBP100k entry, UHNW path, PRA/FCA ring-fenced entity, FSCS protection and access rules.read →J.P. Morgan Private Bank UK: US-origin UHNW in London — investment banking expertise and £10M+ entryJ.P. Morgan Private Bank UK: London UHNW hub with GBP10M+ threshold, investment-bank integration, UK regulation and client selection.read →J.P. Morgan: Corporate & Investment Bank and Private Bank of JPMorgan ChaseJ.P. Morgan is the corporate, investment, and private banking arm of JPMorgan Chase, the largest U.S. bank (G-SIB): private bank for UHNW from $10M, USD clearing network.read →Lloyds Private Banking: £250k Entry Threshold and Schroders Personal Wealth IntegrationLloyds Private Banking in Lloyds Banking Group: GBP250k threshold, Schroders Personal Wealth link and fit for affluent/HNW clients.read →NatWest Premier Banking: £100k Entry and Investment Platform via CouttsNatWest Premier Banking from GBP100k: entry UK premier banking, Coutts-linked investment access and differences from affluent banking.read →Revolut Business: multi-currency account from UK PRA bank and EU ECB-licensed Revolut Bank UABRevolut Business offers multi-currency accounts through UK and EU regulated entities. Banking licenses, boundaries, and fit in corporate payment structures.read →Revolut Private Bank: What Is Known Before LaunchRevolut announced a private bank for UK and EU clients: £500K threshold, summer 2026 launch. What is known, the licensing picture and open questions.read →Rothschild & Co Wealth Management UK: Family Financial Dynasty + M&A Advisory for Founder-Led UHNWRothschild & Co Wealth Management UK: strength lies in the Global Advisory + Wealth combination for founder-led UHNW. Who it suits and selection logic.read →Standard Chartered UK: £-listed HQ and emerging-markets wealth gatewayStandard Chartered UK: London-listed emerging-markets bank, how it differs from Coutts, who benefits and which markets it covers.read →StatrysStatrys is a Hong Kong fintech for SMEs with multi-currency accounts, local payments, SWIFT transfers, FX, and use cases for international structures.read →UK Bank Account for Non-ResidentsHigh street banks need a UK address. Non-resident routes in 2026: HSBC Expat from £50,000, Barclays International from £100,000, plus digital options.read →Wise BusinessWise Business is a multi-currency payment account for companies, with local account details, onboarding, FX, and limits for cross-border settlements.read →
library
tax & investments
Tax regimes, investment transactions, CFC, ESOPs, secondaries and private capital.
Carried interest 2026: the jurisdiction map for fund principalsHow carried interest taxation changed in 2026: the UK moves it into trading profits (34.1%/47%) and reaches non-residents, Luxembourg offers 11.45% or exemption, Italy 26%, France the 31.4% PFU, and the US keeps § 1061 intact.read →CFC in the United Kingdom: TIOPA 2010 Part 9A, TOAA and the FIG RegimeBritish CFC rules: TIOPA 2010 Part 9A, gateway tests, charge calculation and interaction with Transfer of Assets Abroad and the FIG regime.read →CRS, FATCA and HMRC dataLegal guide to CRS, FATCA-style reporting, HMRC offshore data, Self Assessment consistency and family office evidence.read →Foreign Companies and UK TaxLegal guide to UK risks for foreign companies: residence, central management and control, CFC, TOAA, gains attribution and founder structures.read →Foreign tax credit and treatiesLegal guide to UK foreign tax credit relief, double tax treaties, treaty residence, withholding tax and Self Assessment reporting.read →HMRC enquiries and cleanupLegal guide to HMRC offshore enquiries, CRS data, Worldwide Disclosure Facility, penalties, amended returns and evidence repair.read →Leaving the UK: Tax on DepartureLegal guide to leaving UK tax residence, P85, SA109, split year, temporary non-residence, UK property and IHT tail risk.read →Offshore Funds and UK TaxLegal guide to UK reporting fund status, non-reporting funds, offshore income gains, foreign ETFs and investment portfolios.read →Overseas Workday ReliefLegal guide to UK Overseas Workday Relief after 6 April 2025, foreign workdays, employment income, RSUs, bonuses and evidence.read →Planning before UK residenceLegal guide to pre-arrival UK tax planning for FIG, OWR, foreign companies, offshore funds, trusts, IHT and residence evidence.read →Purchasing London Property as a Non-Resident: SDLT, ROE and Inheritance TaxNo restrictions for foreigners, but SDLT with 5% + 2% surcharges reaches ~17%, companies pay ATED and disclose in ROE, and UK property always faces 40% IHT. Transaction breakdown.read →Remittance basis after 6 April 2025Legal guide to the abolition of the UK remittance basis, pre-6 April 2025 pools, TRF, mixed funds and transitional rules.read →Roth abroad: the one US wrapper that survives relocationWhy qualified Roth distributions stay tax-free in the UK under Article 17 of the US-UK treaty even after HMRC's 2025 tightening, how the FEIE kills your contribution room (and FTC fixes it), how Canada and France differ, and where §4975 breaks the Thiel play.read →Split-year treatment: tax year of relocation to the UKHow UK split-year treatment divides the tax year of relocation into UK and overseas parts: eight SRT cases, automatic application, and common pitfalls.read →UK deemed domicile: what it was and what replaced itThe British deemed domicile rule (15 out of 20 years) and its abolition from 6 April 2025: transition to the four-year FIG regime and long-term residence test for inheritance tax.read →UK Family Office Records and Tax EvidenceLegal guide to UK residence files, ownership maps, source-of-funds records, CRS self-certifications and evidence architecture.read →UK FIG Regime: Foreign Income and GainsThe UK Foreign Income and Gains (FIG) regime from 6 April 2025: relief from UK tax on foreign income and gains for the first 4 years of residence; 10-year non-residence condition; replaced the remittance basis.read →UK Non-Dom Reform 2025: FIG Regime, TRF and Your OptionsThe remittance basis ended on 6 April 2025. How the new FIG regime and Temporary Repatriation Facility change planning for internationally mobile private capital.read →UK Tax on Worldwide Income and GainsLegal guide to UK taxation of foreign income, gains, cryptoassets, Self Assessment, SA106, SA108 and SA109.read →UK tax residenceLegal guide to the UK Statutory Residence Test, day counting, ties, split years, temporary non-residence and treaty residence.read →
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companies & funds
Companies, funds, SPVs, holdings and investment vehicles in key jurisdictions.
Appointed Representative and Regulatory Hosting: Fund Without Own FCA LicenceHow to launch a fund and raise capital in the UK without your own FCA licence: appointed representative under FSMA s.39, host AIFM, third-party ManCo in the EU, risks and AR reform after Greensill.read →Intestate Succession in the UK: Intestacy, Freedom of Testation and PlanningHow estates are divided without a will in England and Wales: £322,000 statutory legacy for spouse, freedom of testation and the 1975 Act, 40% inheritance tax and residence-based regime from April 2025.read →Solicitor — English Lawyer for Private CapitalSolicitor in the English tradition: reserved activities, legal professional privilege, client account, undertakings, trust practice, and recognition of status outside England.read →Trusts and Inheritance Tax: UK IHT After the 2025 ReformHow UK inheritance tax (40%) affects trusts and non-residents after the 6 April 2025 reform: transition to residence-based regime, long-term resident 10 of 20 years.read →UK LLP for International PartnershipsLimited Liability Partnership in the UK: limited liability, tax transparency, salaried member rules, and application for international partnerships and funds.read →Why a South Dakota dynasty trust does not save the American living abroadA South Dakota dynasty trust for an American who becomes UK-resident: how the Settlements Code, ToAA and s.86/s.87 TCGA collapse deferral, and how residence-based IHT from 6 April 2025 pulls trust assets into relevant property — and what the trust still delivers.read →
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residency & citizenship
Residency and citizenship: Spain Digital Nomad, Beckham regime, Andorra, Monaco and Singapore PR.
Remote Notarisation: Russia, England, USA – One TouchHow remote notarisation works: Art. 44.3 and two-notary transactions in Russia, remote notarisation and e-Apostille in England, RON in the USA – and how Private.law makes it one touch.read →UK Global Talent: the British Talent Visa Without an EmployerHow the UK Global Talent visa works: endorsement by Tech Nation, the Royal Society or Arts Council, or a listed prize; full work freedom with no sponsor, ILR after 3 or 5 years and the 4-year FIG tax window.read →UK Innovator Founder: the Founder Visa With No Minimum CapitalThe UK Innovator Founder visa: endorsement of an innovative business plan with no £50k minimum, checkpoint meetings, the 3-year ILR criteria and how the route compares with Global Talent.read →
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Other
FAQ
What changed for UK non-doms from 2025?
From 6 April 2025 the non-dom regime was abolished and replaced by a residence-based system. New arrivals get a 4-year FIG (foreign income and gains) relief, after which worldwide income is taxed.
Does a UK non-resident pay inheritance tax?
After the 2025 reform inheritance tax (40%) is tied to long-term residence (a 10-of-20-years test) rather than domicile. UK-situs assets are taxed regardless.
Why use the UK for a holding or fund?
A wide treaty network, mature corporate and fund infrastructure (including regulatory hosting / host AIFM) and a strong banking layer.
Contact information
If you have questions or need a consultation, our experts will be glad to help.