# Planning before UK residence > Legal guide to pre-arrival UK tax planning for FIG, OWR, foreign companies, offshore funds, trusts, IHT and residence evidence. Author: Мария Плотникова — юрист, Family Office (https://wiki.private.law/authors/plotnikova) Last modified: 2026-07-14T09:29:00.000Z Canonical: https://wiki.private.law/en/uk-planning-before-residence Topics: investments Jurisdictions: uk Product tags: wealth-planning, tax-regime, trust, cfc Semantic tags: wealth-planning, tax-regime, trust, cfc --- ## Concept > 🔗 **Related** > [Statutory Residence Test](https://wiki.private.law/en/uk-tax-residence) · [worldwide income and gains](https://wiki.private.law/en/uk-worldwide-income-gains) · [four-year FIG regime](https://wiki.private.law/en/uk-fig-regime) Pre-arrival planning is the legal design of facts before the UK tax year begins or before residence is triggered. It is not avoidance packaging. The aim is to identify the consequences, remove avoidable ambiguity, and avoid entering UK residence with unmanaged structures. The residence start date runs off the Statutory Residence Test, and since 6 April 2025 a UK resident is taxed on the arising basis on worldwide income and gains under RFIG41000 unless a relief such as the four-year FIG regime applies. This is general legal information, not individual tax advice. UK residence, treaty position, trust attribution, company residence and IHT exposure turn on facts and documents. > 🍓 Almost everything here is cheaper to fix before the residence start date than after it. Once the SRT clock starts, embedded gains, fund status, company management, trust benefits and the FIG window are facts rather than choices. Fix the residence date first, then the four-year FIG window, then the portfolio, the governance and the IHT long-term-residence clock. ## What pre-arrival planning fixes **Residence and the FIG window** The SRT decides the residence start date and any split-year case. A qualifying new resident — broadly UK resident after at least 10 consecutive non-resident tax years — can claim the [4-year FIG regime](https://www.gov.uk/guidance/check-if-you-can-claim-the-4-year-foreign-income-and-gains-regime), and foreign employment income runs through [Overseas Workday Relief](https://www.gov.uk/government/publications/globally-mobile-employees/overseas-workday-relief). The window opens on residence, so the date is the first lever. **Portfolio, companies and trusts** Offshore fund status under [IFM12144](https://www.gov.uk/hmrc-internal-manuals/investment-funds/ifm12144) decides whether a disposal is a gain or an offshore income gain. A foreign company's central management and control and the transfer-of-assets-abroad rules decide whether company income reaches the founder. Trust benefits and matching, and the [IHT long-term-resident clock](https://www.gov.uk/guidance/inheritance-tax-if-youre-a-long-term-uk-resident), all start counting from residence. ## The planning test The test asks what happens if the client becomes UK resident in the intended tax year. It then asks whether the outcome changes if arrival is delayed across a tax-year boundary, assets are sold before arrival, non-reporting funds are switched, a company is governed from outside the UK, trust benefits are deferred, or a treaty residence position is preserved. Each answer should rest on a document, not an intention. ## Scope The page covers individuals and families before arrival: founders with companies, investors with foreign funds, trust settlors and beneficiaries, executives with deferred compensation, and families approaching the 10-year long-term-residence mark for inheritance tax. ## Consequences > 🔗 **Related** > [FIG regime](https://wiki.private.law/en/uk-fig-regime) · [offshore income gains](https://wiki.private.law/en/uk-offshore-funds) · [central management and control](https://wiki.private.law/en/uk-foreign-companies) Pre-arrival decisions decide whether the FIG regime is available and whether a gain falls inside the four-year window; whether a portfolio throws off offshore income gains instead of capital gains; whether a foreign company's residence is challenged through central management and control; whether trust income is attributed to a UK-resident settlor; and when the IHT long-term-residence clock starts to bite. ## Examples > 🔗 **Related** > [Overseas Workday Relief](https://wiki.private.law/en/uk-overseas-workday-relief) A client holding non-reporting funds may switch before UK residence or rely on FIG timing instead. A founder may move the central management and control of a foreign company away from the UK before arrival, on real facts rather than minutes. An incoming executive may model Overseas Workday Relief before a start date that fixes the qualifying year. A trust beneficiary may defer distributions until the residence and FIG position is documented. ## The 2025 regime in one view > 🔗 **Related** > [remittance basis](https://wiki.private.law/en/uk-remittance-basis-after-2025) · [four-year FIG regime](https://wiki.private.law/en/uk-fig-regime) · [Temporary Repatriation Facility](https://wiki.private.law/en/uk-non-dom-2025) The remittance basis closed on 6 April 2025. A UK resident is now taxed on the arising basis on worldwide income and gains, and the only general shelter on arrival is the four-year FIG regime: someone who becomes UK resident after at least ten consecutive non-resident tax years can elect, for the first tax year and the following three, to keep designated foreign income and gains out of UK charge. The election has a price: it costs the income tax personal allowance and the capital gains annual exempt amount for each year claimed. So the four-year window is something to model against expected foreign income rather than claim by reflex. Anyone who was UK resident on the remittance basis before 6 April 2025 sits in a different position. The Temporary Repatriation Facility lets pre-2025 foreign income and gains be designated and brought onshore at a flat 12% for 2025/26 and 2026/27, rising to 15% for 2027/28, after which the facility closes. Former remittance-basis users may also, subject to conditions, rebase certain foreign assets to a 2017 value on a later disposal. Neither feature helps a true first-time arrival, but both shape the order in which a returning resident should remit, realise and restructure. ## Inheritance tax now follows residence > 🔗 **Related** > [Settlor-interested trusts](https://wiki.private.law/en/trusts-inheritance-tax) · [exit plan](https://wiki.private.law/en/uk-leaving) Inheritance tax changed basis on the same date. Domicile no longer decides exposure; residence does. Non-UK assets fall inside the IHT net once someone is a long-term resident — UK resident in at least ten of the previous twenty tax years — and a departure tail can keep worldwide assets in charge for several years after residence ends, up to ten for the longest-staying. Settlor-interested trusts lose their old excluded-property protection on the same long-term-resident test, which is why the inheritance-tax clock belongs in the arrival plan rather than the exit plan. > 💡 Overseas Workday Relief now runs across the four FIG years and is capped at the lower of 30% of qualifying employment income or £300,000 a year. For an incoming executive, the start date and the split between UK and overseas workdays are worth modelling before the contract is signed, not after the first payslip. ## Checklist - Model the SRT residence start date and any split-year case before the move. - Test FIG eligibility and the four-year window, and OWR for foreign employment income. - Review the portfolio for offshore fund status and excess reportable income by ISIN. - Decide company governance so central management and control sits where intended. - Map trusts, benefits and matching, and plan the timing of distributions. - Project the IHT long-term-residence clock and the departure tail. ## Common mistakes - Leaving planning until the first UK tax return, when asset timing and governance are already fixed. - Treating artificial arrangements or false residence evidence as planning. - Reviewing the portfolio only after arrival, after non-reporting gains have crystallised as income. - Changing company minutes without changing where decisions are actually taken. - Ignoring transfer of assets abroad and CFC rules as if they were peripheral. ## Advisor trigger A tax adviser can coordinate a clean arrival where the facts are simple and documented. A UK tax solicitor should lead where there is a foreign company with UK management questions, a settlor-interested trust, large embedded gains, a treaty residence position, or a structure that needs to be re-papered before the residence start date. ## Q&A > 🔗 **Related** > [FIG regime](https://wiki.private.law/en/uk-fig-regime) · [UK tax residence](https://wiki.private.law/en/uk-tax-residence) · [Overseas Workday Relief](https://wiki.private.law/en/uk-overseas-workday-relief) · [Offshore funds](https://wiki.private.law/en/uk-offshore-funds) · [Foreign companies](https://wiki.private.law/en/uk-foreign-companies) · [Trusts and inheritance tax](https://wiki.private.law/en/trusts-inheritance-tax) · [Leaving the UK](https://wiki.private.law/en/uk-leaving) ### Is pre-arrival planning avoidance No. Legal planning identifies consequences and structures facts honestly before residence. False residence evidence or artificial arrangements are a different thing, and the transfer-of-assets-abroad and CFC rules treat them as such. ### Which issue should be reviewed first The residence start date. It controls the tax year, the four-year FIG window, the split-year analysis and the IHT long-term-residence count, so every other decision keys off it. ### Should portfolios be reviewed before arrival Yes. Offshore fund status and excess reportable income can materially change the UK result, and selling non-reporting funds after arrival can convert capital growth into income. ### Can a foreign company simply be run from abroad after arrival Only if the central management and control genuinely sits abroad. Moving the minutes while the decisions stay in the UK does not move residence, and transfer of assets abroad can still attribute income to the founder. > 🍓 The thread through all of it is evidence. A board minute only helps if decisions are actually taken where it records them; a pre-arrival disposal only helps if it is dated and real; a fund's character depends on its reporting status, not its prospectus. Pre-arrival planning is the work of making the facts true before the residence start date, so that the first UK return simply reports them. --- --- ## FAQ ### Is pre-arrival planning avoidance No. Legal planning identifies consequences and structures facts honestly before residence. False residence evidence or artificial arrangements are a different thing, and the transfer-of-assets-abroad and CFC rules treat them as such. ### Which issue should be reviewed first The residence start date. It controls the tax year, the four-year FIG window, the split-year analysis and the IHT long-term-residence count, so every other decision keys off it. ### Should portfolios be reviewed before arrival Yes. Offshore fund status and excess reportable income can materially change the UK result, and selling non-reporting funds after arrival can convert capital growth into income. ### Can a foreign company simply be run from abroad after arrival Only if the central management and control genuinely sits abroad. Moving the minutes while the decisions stay in the UK does not move residence, and transfer of assets abroad can still attribute income to the founder. --- ## Factual claims - The remittance basis closed on 6 April 2025. - Anyone who was UK resident on the remittance basis before 6 April 2025 sits in a different position.