Matthew Braithwaite
- Partner
- Private Client
Welcome to the March 2025 issue of our international e-bulletin for private client, family office, and trustee clients and contacts.
It’s been a busy start to the year, in anticipation of the upcoming changes to the taxation of non-UK domiciled individuals (“non-doms”) which take effect on 6 April 2025. Since the reforms were first announced in the March 2024 Budget, the industry has been lobbying the government for amendments to avoid non-doms leaving the UK which could ultimately defeat the revenue raising rationale of the policy. Despite some encouraging remarks from Chancellor, Rachel Reeves, in her January 2025 speech at the annual World Economic Forum meeting in Davos, the final amendments include only minor technical adjustments that do not significantly alter the policy direction or extend any transitional concessions.
As ever, in this edition we cover various issues impacting the international private client community. We hope you enjoy reading it and we look forward to advising and seeing you soon.
In this issue…
- Government confirms IHT reforms: what farmers and business owners need to know – set to take effect from 6 April 2026, the proposed reform of the inheritance tax regime for business and agricultural property, which will cap the unlimited relief currently available, has sparked controversy and concern. As the government now seeks technical feedback, we examine the proposals in detail including the seven-year rule, transferability of allowances, gifts, and the impact on trusts.
- New development – first decision involving usufructs and inheritance tax – usufructs allow a person to occupy a property and receive income, usually for their lifetime. It is common for inheritance laws outside the UK to control how a person must leave their assets. Many of these laws require a usufruct to be left to the surviving spouse, with the children inheriting the bare ownership. To families from the UK, the concept of the law dictating how one’s inheritance should pass can seem surprising.
- The Register of Overseas Entities: widened protection regime and the public disclosure of trust information – the Register of Overseas Entities (ROE) requires overseas entities holding UK land to register and disclose information about their beneficial owners. New regulations effective from 28 February 2025 expand the ability to protect individuals’ information, including that of trust beneficiaries, from public disclosure. From 31 August 2025, trust information will also become accessible to the public on application. Entities should consider protection applications for vulnerable individuals before these changes take effect to safeguard sensitive information.
Jurisdiction Focus: East and South-East Asia – Singapore and Hong Kong
Like other international private clients, those based in East and Southeast Asia with UK connections face challenges, particularly in areas of taxation, estate planning, and regulatory compliance.
Wedlake Bell has extensive experience working with clients based in these regions and in November 2024, Private Client Partner, Matthew Braithwaite, and Residential Property Partner, Nick Stone, visited the region to catch up with clients and professional advisers. During their visit, there was understandably a significant interest in the upcoming changes to the UK taxation of non-domiciled individuals (“non-doms”) and the potential impact on clients with UK interests, substantial ties, or children working or studying in the UK. There were also numerous conversations on how to assist clients with UK property interests, as the UK property market remains a lucrative option for overseas investors due to its stability, high rental yields, and diverse investment opportunities.
At a client and intermediary event hosted by Hugill & IP in Hong Kong, Matthew provided insights to attendees into how these non-dom tax reforms are likely to affect wealth holders and their families, as well as commenting on the shifting landscape for international investors considering the UK as a destination. Read more here.
Wedlake Bell offers expert advice on UK wealth structuring, estate planning and succession matters for its global client basis, including Hong Kong and Singapore, as well as acting on behalf of UK property investors in these and many other jurisdictions. Our client-centric, partner-led approach ensures a personalised service, ensuring we deliver exceptional value and client service to private clients and their advisers. If you would like to know more about how we support clients in Singapore or Hong Kong or any other regions, please contact us.
In the press…
- Matthew Braithwaite has had the privilege of co-authoring a chapter in the latest edition of Business Families and Family Businesses, entitled “Understanding the Wealth Holder Spectrum”. This third edition, co-published with STEP – Advising Families Across Generations, and due to be published in April, looks at developments within the approach to family business advising since 2018, taking account of the current geopolitical backdrop and the shift in attitude in a growing number of clients towards succession, philanthropy and investments.
- Congratulations to our Senior Partner Camilla Wallace on winning Tax & Trusts Lawyer of the Year at The Spear’s Magazine Awards. Her dedication to clients and commitment to preservation of mental health in the workplace earned her top prize at one of the most prestigious award ceremonies in the private wealth space.
- Matthew Braithwaite features in The Family Business Podcast to discuss the findings of the Society of Trust & Estate Practitioners’ latest research into family business succession. Matt discusses the importance of succession planning for family businesses and the impact of the UK’s Autumn Budget 2024. Listen here.
This article is for general information only and does not seek to give legal advice or to be an exhaustive statement of the law. Specific advice should always be sought for individual cases.
Meet the team: