Globally Speaking – October 2025

As the Autumn Budget approaches on 26 November, the private client sector is poised for further change amid uncertainty over the UK’s evolving political and economic landscape. Tax reforms affecting UK-based individuals — and potentially those with UK connections — are anticipated. Much of the government’s recent focus has been on immigration policy, with measures aimed at tightening borders and managing inflows. We hope the narrative will soon shift towards attracting overseas talent — a critical driver of innovation and growth across key sectors. Whether the Chancellor will use the Budget to introduce incentives for international high-net-worth individuals or address broader concerns around the UK’s competitiveness remains to be seen.

Whether you are navigating the current uncertainty, advising globally mobile families, or planning for generational transition, this edition offers timely insights and practical guidance from our international private client team.

In this issue

• Private equity and carried interest: preparing for the new rules — the Autumn Budget 2024 signalled a seismic change in UK tax treatment of carried interest — moving from a capital gains tax to an income tax regime which will reshape effective rates of tax and also impact treaty reliefs, especially for those with cross-border connections. We explore the implications for fund managers, cross-border tax planning, and the considerations around returning to the UK.
• Finance Bill 2025/2026: Government confirms Agricultural Property Relief (APR) and Business Property Relief (BPR) reforms effective from April 2026 — significant changes are coming that affect owners of interests in businesses that qualify for inheritance tax reliefs. As confirmed in the Finance Bill 2025/2026, the UK Government will implement major reforms to “APR” and “BPR” from 6 April 2026 which will have wide-reaching implications for international families with UK-connected business interests.
• Public disclosure of trust information: reforms to the ROE regime affecting non-UK trusts — from 31 August 2025, trust data reported under the UK’s Register of Overseas Entities (ROE) may be publicly disclosed — posing new considerations for non-UK trusts holding UK property. Now is the time to review what information could be disclosable and consider protection options.
• Expansion of the UK Trust Registration Service: implications for non-UK trusts — the UK Government has proposed important changes to the Trust Registration Service (TRS), expanding registration requirements for non-UK trusts and widening the scope of disclosure requests. With final regulations expected in early 2026, trustees of non-UK trusts should act now to assess the trust’s exposure, update beneficial ownership records, and prepare for increased scrutiny in some cases. Read our full update to understand what is changing and what trustees need to consider before the regulations are implemented.
• Shares of an estate under Islamic inheritance — Islamic inheritance follows a structured framework rooted in the Qur’an, allocating fixed shares to key heirs such as spouses, children, and parents. This article breaks down the principles behind Qur’anic and residuary heirs, clarifying how estates are divided and what factors influence each heir’s entitlement.

Jurisdiction Focus: AFRICA

Wedlake Bell advises a number of entrepreneurial high-net-worth and ultra-high-net worth families in Africa with their estate and succession planning objectives, often as a result of the early stages of a transition of wealth from one generation to the next and/or a substantial liquidity event.

We are ideally positioned to support families, often with members residing in several jurisdictions with the creation of optimal cross-border asset-holding structures for their legacy assets. We work collaboratively with their local advisers to ensure that any structuring incorporates any necessary legal nuances and cultural dynamics. We maintain strong relationships with leading lawyers and other professional advisers in several African countries, and with trusted intermediaries outside Africa who consistently support African-connected families and businesses with their legal, financial, and fiduciary service needs.

Partner, Sanjvee Shah visits the continent several times a year, where there is a growing need for well-considered, tailored advice for families with increasingly complex needs. These include medium to long-term wealth and estate planning objectives, family office structuring, governance frameworks, and philanthropic strategies

In the press

• Wedlake Bell has welcomed Partner Sophie St John, to its Private Client team, bringing deep expertise in UK and international estate planning, tax, and wealth structuring for globally mobile families. Read more here.
• Partner Kate Johnson is quoted in City AM on the “unreliable” data surrounding non-doms leaving the UK. 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