Globally Speaking – April 2026

The international private client landscape continues to shift, shaped by geopolitical uncertainty, political change and increasingly divergent tax and regulatory regimes. Some internationally mobile families may find themselves outside the jurisdictions they originally expected to be living in, prompting a reassessment of where – and how – they structure their affairs. This may include re‑examining the UK alongside alternative jurisdictions offering stability, clarity and long‑term certainty.

As a result, families and their advisers are taking a more strategic approach to cross‑border planning, with renewed focus on jurisdictional choice, long‑term governance and resilience.

In this edition of Globally Speaking, our Private Client team shares practical insight into the issues we are seeing across our international practice.

In this issue

• British expatriates returning to the UK from the Gulf: key tax and residency considerations — as British expats return to the UK from the Gulf there is a risk of inadvertently becoming UK tax‑resident. Understanding how the Statutory Residence Test works and the potential tax exposure that can follow for returning expats is key to avoiding costly surprises.
• Are non-dom tax reforms inhibiting philanthropy in the UK? — with donors reassessing where they live, invest and give, the UK’s cultural sector is feeling the impact. We explore how tax reform, heightened scrutiny and global competition are reshaping support for museums and galleries — and what can be done to keep philanthropy thriving.
• The Temporary Repatriation Facility (TRF): act now or regret it later — the end of the remittance basis has reshaped the UK tax position for many internationally mobile individuals. We look at how the TRF may provide a strategic window to regularise historic foreign income and gains, manage mixed funds, and remit capital with greater certainty before the regime expires.

Jurisdiction Focus: Italy

Italy is an increasingly popular destination for internationally mobile private clients, combining lifestyle appeal with flexible residence options. In terms of immigration, the Italian Investor Visa (sometimes referred to as the “Italian Golden Visa”) route allows HNWIs to secure residency through a qualifying investment of €500,000 into an Italian company, €250,000 into an innovative start up, the purchase of €2 million in Italian government bonds, or a €1 million philanthropic donation. There is no minimum stay requirement, making this particularly attractive for families and principals with global commitments.

In terms of tax, Italy offers one of Europe’s most competitive regimes for high-net worth individuals, known as the “lump sum regime”. Foreign source income and assets can be excluded from Italian taxation and instead subject to a flat annual charge of €300,000 for up to 15 years, regardless of overseas income levels. The regime may be extended to family members for an additional fixed charge of €50,000. Foreign assets are not subject to Italian wealth taxes, and non Italian assets may fall outside Italian inheritance and gift tax, offering valuable succession planning advantages.

Italy also permits a high degree of flexibility, allowing individuals to tailor the regime by excluding selected income streams where this better aligns with existing structures or treaty positions. Combined with Italy’s extensive double tax treaty network, this enables careful coordination with UK and international tax exposure.

Our Private Client team works closely with tax and corporate specialists, and trusted Italian advisers, to ensure Italian interests are fully aligned with a client’s broader global strategy. We have particular experience in the relocation of senior professionals in the finance industry, often with complex carry arrangements. We deliver clear, commercially grounded advice, helping clients relocate with confidence while protecting wealth across generations.

In the press

• Partner Matt Braithwaite was quoted in eprivateclient commenting on the UK tax risks facing expatriates returning from the Middle East amid ongoing regional instability. He highlighted how easily individuals can inadvertently trigger UK tax residence, even where a return is driven by safety or necessity rather than choice. 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

   Visit Matt's profile

View the whole team