£10m Property Portfolio Cross Border Planning

The Situation

An international investor owned a UK property portfolio worth around £10 million but lived overseas. He believed that because he was no longer living in the UK, his assets were no longer subject to UK inheritance tax.

No succession or protection planning had been put in place.

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The Risk

In reality:

• UK property remains subject to UK inheritance tax regardless of residency
• Domicile rules can extend UK tax exposure even further
• Up to 40 percent tax could apply to the full portfolio
• The family could be forced to sell assets to pay the tax

This created a potential seven figure tax bill.

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Our Review

We reviewed:

• UK and overseas residency
• Domicile status
• Property ownership and structures
• Inheritance tax exposure
• Liquidity and protection options

This gave a clear view of the real tax risk.

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The Strategy

1. Domicile and tax position clarified
   We explained how UK domicile and asset location drive inheritance tax, not just where someone lives.
2. Inheritance tax modelling
   We calculated the likely tax bill under different scenarios so the client could see the scale of the exposure.
3. Structural planning reviewed
   We assessed whether corporate or trust based ownership would reduce risk or improve control.
4. Insurance planning introduced
   We arranged inheritance tax protection through life insurance written into trust to ensure any future tax bill could be funded without selling property.