Globally Speaking – June 2026

Not a day goes by without some shift in the UK economic landscape. Against a backdrop of continual tax reform, evolving regulation, and an ever-present political undercurrent, stability can often feel elusive. As we look ahead to the remainder of 2026 — whilst awaiting the appointment of a seventh Prime Minister in just ten years followed by a newly formed cabinet — the question of certainty looms larger than ever.

For internationally mobile, high-net-worth individuals, this raises a critical consideration: what will the UK offer next? Beyond its historic appeal, how will any incoming government seek to attract individuals to live, work and spend time here — and in doing so, support the businesses, cultural institutions and heritage sectors that thrive when the economy is strong?
 
In this edition of Globally Speaking, we navigate around the political landscape and focus on practical insight, as our Private Client team shares what we are seeing across our international practice.

In this issue

• International mobility and UK tax: planning for two critical milestones — for internationally mobile individuals, the UK’s new tax landscape is defined by timing. The end of the foreign income and gains regime and the onset of long-term residence for inheritance tax purposes can reshape tax exposure overnight. We explore how careful, forward-looking planning can make a material difference.
• Potential changes to the taxation of Limited Liability Companies in the UK — proposed reforms to the UK tax treatment of US Limited Liability Companies could address long-standing double taxation issues, potentially making the UK a more attractive destination for internationally mobile investors.
• Goodbye cards, hello codes: the shift to UK eVisas explained — cards and stamps are giving way to digital records as the UK moves to eVisas. The new system offers a more streamlined approach to proving immigration status, but requires individuals to actively manage and demonstrate their rights online
• Wide or narrow: what role does the protector play in an offshore trust? — the recent Privy Council decision in A and others v C and others has brought welcome clarity to a much-debated question in trust law: what role does a protector play when trustee decisions require their consent, but the trust deed is silent on how that consent power should be exercised? The ruling is likely to have significant implications for offshore trust practice and highlights the importance of carefully drafted protector provisions.  
• Update on the UK’s Trust Registration Service and Register of Overseas Entities — recent reforms and proposed changes will significantly expand disclosure obligations for offshore structures with UK connections, creating greater transparency. Trustees and advisers should act now to understand the shifting landscape and prepare for increased scrutiny.

Jurisdiction Focus: Switzerland

Switzerland continues to be a very popular relocation destination for internationally mobile UHNW families. Long associated with discretion, privacy, safety and stability, it offers a highly attractive proposition for UHNW individuals and families who are looking to relocate for lifestyle and/or tax reasons.

A key driver of inbound interest is Switzerland’s highly competitive tax framework for UHNW individuals. This includes the following: 

• The lump-sum taxation (forfait) regime whereby eligible foreign nationals who do not undertake any professional activity in Switzerland are levied tax on deemed income that derives from their annual living expenses or a multiple of the annual rental costs.
• Switzerland operates a cantonal tax system, with cantons having their own rates and approaches to lump-sum taxation, which can materially affect overall exposure to Swiss tax.
• The annual lump sum tax is negotiated with the relevant cantonal authorities on a case by case basis which, when concluded, offers the taxpayer certainty and efficiency.
• Advance tax clearances can be obtained to confirm the Swiss tax treatment of existing trust and other asset holding structures that a taxpayer may have as part of their Swiss pre-arrival planning.
• Other Swiss taxes such as wealth tax and gift and inheritance taxes are also relevant considerations when choosing an appropriate Swiss canton.

We regularly advise clients based in the UK and who wish to relocate to Switzerland, making sure that their Swiss pre-arrival planning is fully co-ordinated with their departure from the UK.

We are also advising international clients who wish to establish asset holding structures with Swiss fiduciary providers or move existing structures to such providers, and often working alongside the clients’ long-standing network of financial intermediaries in the country.

We maintain strong, on-the-ground relationships in Switzerland with lawyers, fiduciaries and private banks to ensure that we are well placed to provide the tax, estate planning and structuring advice that our clients need on a cross-border basis in a fully comprehensive, collaborative and seamless manner.

In the press

• Camilla Wallace was quoted in the Financial Times on global wealth trends. New research shows a slowdown in high-net-worth individuals changing tax residence, as earlier political and tax-driven moves begin to settle. Camilla notes that much of the initial relocation activity following the abolition of the UK’s non-dom regime has already taken place. Read more here.
• George Merrylees has authored an article for FT Adviser, examining why the temporary repatriation facility (TRF) has seen limited uptake since its introduction. The article considers how, despite being a generous and simplified mechanism designed to encourage the use of offshore funds in the UK, wider economic and political uncertainty has meant many taxpayers have either delayed decisions or left the UK altogether. Read more here.
• Petra Warrington and Sanjvee Shah are quoted by thewealthnet in their article on how some family offices are increasing investment diversification into luxury assets as next generation priorities reshape investment decisions. Read more here.

This article is for general information purposes only and does not constitute legal advice or a comprehensive statement of the law. Specific legal advice should always be sought in relation to individual circumstances.

Meet the team:

1. 

   • Matthew Braithwaite

   • Partner
   • Private Client

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