Your home is in Dubai, a rental flat sits in London, a business is up for sale and your children live in a third country. Each adviser you use is right about their own country, and tax planning done that way still leaves gaps nobody is paid to see.
The belief behind those gaps is that tax is settled one country and one tax year at a time. It is not. Several States can hold a claim on you at once, for different reasons, and a move changes only one of those reasons. Those claims can be mapped, and they can be shaped only while an event is still ahead of you.
Tax planning is deciding, before an event, where, when and in whose hands your income, gains and assets will be taxed. It works with the rules as written.
Three activities get confused. Compliance is reporting correctly what has already happened. Planning is the decision taken before the event. Optimisation is the choice of levers inside a plan, and it comes last.
Compliance looks back at a closed year, and planning looks ahead at an event that has not happened yet.
HMRC's glossary draws the outer line. Tax planning uses reliefs “for the purpose for which they were intended”. Avoidance bends the rules to gain an advantage Parliament never intended, and evasion “is always illegal”.
In HMRC's 2026 edition of its tax gap estimates, avoidance accounts for 1% of the UK tax gap, £0.8 billion out of £59.2 billion for 2024 to 2025. Nor is planning concealment. According to the OECD Global Forum (2025), information on over 171 million financial accounts worth nearly €13 trillion was exchanged automatically in 2024. Where the line falls for an account held abroad is covered in our guide on whether offshore accounts are legal.
An international estate meets four families of tax: income tax, capital gains tax, inheritance, estate and gift taxes, and net wealth tax. The more useful question is why any of them applies to you. A State does not tax a person in general: it taxes because one of four connecting factors is present, and several can be present at once, in several States.
| Trigger | What the State looks at | Taxes it can switch on | Does leaving switch it off? |
|---|---|---|---|
| Residence | Where you live, under that State's own test | Income and capital gains tax on worldwide income and gains. In the UK, inheritance tax on foreign assets after long-term residence | Not always at once: a long-term UK resident stays in scope for 3 to 10 tax years after leaving |
| Source | Where the income arises | Income tax on what arises there, such as rent from a UK property paid to a non-resident | No: the claim follows the income |
| Situs of the asset | Where the asset is located | Tax on gains from local property and estate tax on local assets. The IRS requires an estate return where a non-resident non-citizen's US-situated assets exceed $60,000 | No: the claim follows the asset |
| Nationality | Citizenship, in a State that taxes on it | US rules for filing income, estate and gift tax returns stay generally the same for a citizen living abroad | No: it ends only with the citizenship, and giving that up can carry its own charge |
Moving home acts on the first row only.
“tax-free Dubai” is a statement about individuals' income. The UAE does not levy income tax on individuals, but it levies VAT, excise tax and corporate tax, at 9% on taxable income above AED 375,000 for financial years starting on or after 1 June 2023 (UAE government portal, March 2026). A move there leaves other States' source, situs and nationality claims untouched.
A State does not tax a person in general. It taxes because a connecting factor is present, and several can be present at once, in several States. Moving home changes only one of them.
Four of the nine planning areas depend on where you live and where your income arises.
Double taxation. Can one income carry two tax bills? It can, when two of the triggers above fire on it, or when a company and then its shareholder are taxed on the same profit. Relief usually exists, but it has to be identified and claimed. For the two cases side by side, see double taxation explained.
Tax residency. Where are you resident, and can it be two places? Each State applies its own test. The UK uses the Statutory Residence Test. The UAE has had a formal test for individuals since 1 March 2023, and on a reading of that test a residence visa does not by itself make you a UAE tax resident.
Becoming resident in one country does not end your residence in another.
Expat taxation. What does the country you left still claim? According to GOV.UK, you may be non-resident the day after you leave the UK, depending on how split-year treatment applies, and you may still need to pay UK tax on UK income. Tax is one part of the picture set out in our expat financial planning guide.
Planning a move between countries. Does the order of events matter? It can: whether a move, a disposal and a distribution happen in one order or another may change which State taxes them. The 2025 Update to the OECD Model Tax Convention, approved on 18 November 2025, addresses remote working and permanent establishment.
Capital gains tax. When is a gain taxed, and at what rate? Gains are generally taxed when realised, often at a lower rate than earned income. According to an OECD working paper (2025), 19 OECD countries raised their top rate on long-term capital gains between 2000 and 2021 and nine lowered it.
Inheritance, estate and gift taxes. What will your heirs owe, and to which State? According to the OECD (2021), 24 OECD countries levy an inheritance or estate tax, raising about 0.5% of total tax revenue on average among those that do. Exposure follows the person's residence and the location of the assets, and the levers are set out in inheritance tax planning strategies.
It is a small tax for States and a large one for the estates it reaches.
Tax havens. Does low tax mean no rules? According to the UAE Ministry of Finance (accessed October 2026), a Domestic Minimum Top-up Tax applies to members of multinational groups with annual global revenues of €750 million or more, for financial years starting on or after 1 January 2025. A jurisdiction chosen for its rates still has rules, and those rules change.
Planning through offshore structures. Is holding assets through a structure useful? A structure changes who holds an asset and where, which can help only if it has real substance and is declared. Anti-abuse rules stand behind that condition: the EU's Anti-Tax Avoidance Directive, a corporate tax instrument, binds every Member State to such measures, most of them in force as of 1 January 2020.
Optimisation levers. Which levers are available inside a plan? They fall into a few families, among them tax-advantaged wrappers, annual allowances and the place where each asset is held. HMRC's own examples of legitimate planning include saving in a tax-exempt ISA or contributing to a pension scheme. Which one is relevant depends on your circumstances.
A planning window opens before an event and closes when it happens, not at the filing date.
Once the event has happened, planning can still report correctly and claim what is due. It can no longer choose the date, the owner or the place.
Every wealth journey starts with a conversation. Our advisers are ready to understand your objectives, assess your circumstances, and build a strategy tailored to your goals.
Begin Your Journey With UsHMRC's warning signs of an avoidance scheme include an offer that sounds too good to be true and a promoter describing it as “HMRC approved”, which HMRC never does.
A tax plan follows events, not filing seasons, and it runs in three steps.
Tax years do not line up, which complicates each step:
Changes are already dated: the UAE has committed to the updated Common Reporting Standard from 1 January 2027 (UAE Ministry of Finance, November 2025), and first exchanges under the Crypto-Asset Reporting Framework are planned from 2027.
A tax plan follows events, not filing seasons. It runs in three steps: diagnose where you are resident and where each asset sits, sequence the events ahead of you, then review at least once a year and at every life event.
Each adviser answers for one jurisdiction, and a plan tends to fail at the joins. Nothing can be assumed from one country to the next: HMRC tells its own officers that “it is essential to look at the text of the particular agreement in point”.
Coordination matters most where:
It matters little with one country, one source of income and no event ahead. Tax advice itself is given by qualified tax advisers in each jurisdiction, and the role described here is keeping them on one plan. Which structures can carry that plan is a separate subject, covered under wealth structuring vehicles.
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Tax planning means settling in advance how your income, gains and assets will be taxed, using reliefs and rules as they were intended. It differs from compliance, which reports the past, and from avoidance, which HMRC describes as bending the rules for an advantage Parliament never intended.
Tax preparation looks back: it reports a closed tax year correctly and on time. Tax planning looks ahead, at an event that has not happened yet, while its date, owner and place can still be chosen. Both are needed. Contact us for more information.
As a general rule, review it:
Yes, within a clear split of roles. Qualified tax advisers give the tax advice in each jurisdiction. A wealth adviser can keep those advisers, your assets and your timetable on one plan, which matters most when several States have a claim on you. Begin your journey with us.
Generally, those with more than one State in the picture:
This guide is provided for general information purposes only and does not constitute tax, legal or financial advice. Tax treatment depends on individual circumstances and on rules that change. Figures are quoted from official sources at the dates shown.
