If you’ve missed your Corporate Tax registration deadline or already paid the AED 10,000 fine, there’s now a golden opportunity to waive or reclaim that penalty — but only if you act quickly. In a recent move to support businesses during the first year of the UAE’s Corporate Tax rollout, the Federal Tax Authority (FTA) has announced a limited-time grace period. The initiative allows eligible businesses to apply for a full penalty waiver if they file their Corporate Tax return early. This is a major relief for thousands of companies who have either: Missed their Corporate Tax registration deadline, or Registered late and were hit with the AED 10,000 fine Why is this happening? According to Gulf News, this initiative is part of a broader effort by the Ministry of Finance and the FTA to ease the transition into the new Corporate Tax system and promote long-term compliance. What You Need to Know: Deadline for the waiver: July 31, 2025 BUT: You must file your return well ahead of your official tax deadline to qualify. Don’t wait – gathering your financial records and preparing your tax return can take time. For most businesses operating on a calendar year basis (Jan–Dec), that means filing within the next couple of months. Who qualifies for the penalty waiver? If you’re asking: “Can I get a refund on my Corporate Tax late registration fine in the UAE?” “Is it possible to waive the AED 10,000 Corporate Tax penalty?” “How do I apply for the UAE Corporate Tax penalty relief?” Then the answer is – yes, you may be eligible. But there’s a catch: you must file your tax return early, ahead of your normal deadline. This is not automatic, and if you miss the window, the fine will not be waived or refunded. Why early filing matters: The FTA has made it clear: early compliance is the only route to relief. This means: Completing your Corporate Tax registration (if not already done) Preparing your financials for your first tax year Submitting your Corporate Tax return well before the deadline This one-time waiver won’t be repeated – so don’t leave it until the last minute. How Mosaic Chambers Group can help: At Mosaic Chambers Group, our FTA-certified tax advisors and legal consultants are ready to guide you through the entire process. Whether you need help: Understanding your eligibility Filing your Corporate Tax return early Claiming your AED 10,000 fine refund Or ensuring future tax compliance We’re here to take the stress out of Corporate Tax. Book a free consultation today and get expert support from our team. Click here to get in touch or below to book your call.

April 6th, 2025 marks the beginning of a major shift in UK taxation. Labour’s new tax reforms have officially scrapped the long-standing non-domiciled (non-dom) tax status — a move that targets wealthy individuals who live in the UK but, under the new non dom regime, have been able to mitigate UK tax on their overseas income and gains. This change spells the end of a tax break that attracted many high-net-worth individuals (HNWIs) to the UK and is already causing ripples across the country’s elite financial circles. The message is clear: if you live here, you pay here. Let's break down what has changed. What Was the Non-Dom Tax Regime? The non-dom tax regime allowed individuals residing in the UK, who claimed their primary home (domicile) to be outside the UK, to avoid UK income and capital gains taxes by not bringing any foreign earnings or gains back into the UK. This system made the UK an attractive location for individuals with international earnings. We covered this in more detail here. What Has Changed? Since 2025-26 tax year, the government has implemented several significant reforms. These reforms include: 1. End of Non-Dom Status All UK tax residents will now owe UK income tax on all global income and gains, regardless of whether these were brought into the country or not. 2. Inheritance Tax (IHT) on Foreign Assets Non-doms could previously avoid UK Inheritance Tax on assets they held outside the UK; now individuals who have lived here for more than four years will be liable for IHT on all their global estate assets. 3. Temporary Reliefs To assist the transition, temporary measures include the following: Tax Year 2025-26 will see a 50% reduction on foreign income tax. Capital Gains Tax (CGT) laws allow us to rebase overseas assets based on their value as of April 2019 for CGT purposes. Temporarily, bringing money from abroad may not incur full tax charges upon entering the UK. Why Has the Government Made These Changes? According to Labour, eliminating non-dom status will provide many advantages: Enhance tax fairness Raise extra funds to support public services Close longstanding loopholes used by the wealthy Rising Tax Bills HNWIs with overseas assets and income will now face significantly increased tax obligations that may have an effect on personal finances, family planning and wealth transference. Making Decisions About Moving Abroad Some individuals are already leaving the UK in order to settle in countries with more advantageous tax regimes. Some common destinations for relocation include: United Arab Emirates (UAE) does not levy income or capital gains tax Switzerland provides fixed annual tax arrangements for its most wealthy citizens Italy - flat tax of EUR100,000.000 on foreign income for new residents Monaco does not levy personal income tax for residents Concerns Raised About Impact Within Industry Concerns are being expressed that this could lead to a decrease in: Investment into UK businesses Jobs funded by private wealth Donations to UK Charities What About Entrepreneurs? Many entrepreneurs utilise non-dom status to reduce tax on international business earnings, however, these changes could require: Establishing headquarters or structures outside the UK Reconsider ownership of intellectual property or company shares An investigation of how profits and dividends are managed is important to ensure long-term growth. What Should Be Done Now? If you or those you work with have been affected, taking immediate steps is key to their safety. Here are a few things you can do. 1. Consult With A Specialist Tax Advisor Every situation varies. Seek tailored guidance from someone familiar with both UK and international tax regulations. 2. Evaluate Your Financial Structures Evaluate how you hold assets - for instance through offshore companies or trusts. Any necessary changes must be implemented for optimal efficiency and compliance purposes. 3. Consider Relocating If the UK's new tax rules no longer suit, you might wish to explore living elsewhere where tax liabilities would be lower. Be sure to carefully consider all legal, financial, and family aspects prior to making any decisions. Summary The changes to the non-dom tax regime mark a profound transformation for those who rely on global income and wealth for tax payments, especially those living abroad. Although intended to increase fairness, these reforms also pose challenges to those accustomed to using it. Now is the time to review your plans, secure your assets, and seek professional guidance. How Can We Assist? At our offices in both the UK and UAE, we assist individuals, entrepreneurs and professional advisors in making well-informed decisions. If you have any queries about this article or need advice then get in touch.

As soon as billionaires start moving out, something strange is afoot. Lakshmi Mittal, the super-rich steel magnate behind ArcelorMittal--the world's largest steel company--is reported to be considering leaving Britain due to a potential end of non-domiciled (non-dom) tax status benefits in Britain. Who Is Lakshmi Mittal Anyway? Mittal stands out as being something special among his fellow billionaires; for years, he's lived comfortably in Britain while taking advantage of non-dom tax arrangements that enable individuals (like himself) to avoid UK taxes on foreign income as long as it was spent within British borders. But these cosy days are over! What Has Changed? Starting April 2025, the UK will transition away from its non-dom system and toward something much less generous. Key changes will include: End of Non-Dom Era: The remittance basis of taxation will be replaced by a new four-year exemption applicable to foreign income and gains from 6 April 2025. Global Assets Affected by UK Inheritance Tax: Transition to residence-based system for inheritance tax means that after being resident 10 out of 20 years, worldwide assets will be liable for IHT. Remittance Basis—Gone: Previously, non doms only paid tax on foreign earnings if remitted to the UK. Though there are transitionary rules to ease the impact, basically now, wherever you earn income, the UK taxman wants a share. Simply put, the party is officially over now folk like Mittal are wondering whether staying put makes any sense. Where Might the Wealthy Go? When your fortune is at stake, you don't make decisions at random; that is why HNWIs such as Mittal are keenly scrutinising places that might allow them to keep more of their cash safely: UAE: No income tax, inheritance tax or wealth tax applies in this region. Portugal: Thanks to its Non-Habitual Residency scheme, sunny Portugal has become an appealing location for individuals who seek tax benefits without compromising on lifestyle. Switzerland and Monaco: Monaco has long been considered a tax haven because of its favorable personal and corporate tax rules. The country does not tax individuals on their income, and corporations within the country have favourable tax treatment. Italy: allows for long-term residence and access to Schengen countries. Under certain circumstances, a flat rate of tax of 7% on all foreign-sourced income is available to new residents of Italy. Why Should the UK Worry? Britain's Reputation at Risk Packing their bags publicly doesn't exactly send out the message that Britain is ready for business; Mittal leaving could prompt other wealthy individuals to consider whether this country remains attractive. Money Matters Every time a billionaire leaves the UK economy, their absence leads to reduced investments, lower donations to charity and less lavish spending - not just with regards to taxes but also economically. Politics The government could run into trouble if new policies are seen to push away wealthy donors with money - not exactly an ideal recipe for voter appeal! What should HNW people be Doing Now? Verify Your Status: Evaluate whether your current tax status remains advantageous under these new circumstances. Clarifying Your Tax Exposure Globally: Fully understand the tax repercussions associated with maintaining or cutting ties to the UK. Consider Alternatives: Assess potential jurisdictions such as the UAE or certain European nations that offer clearer tax regimes without inheritance or wealth taxes. Final Thoughts Mittal's potential exit encapsulates more than simply his tax bill; it spotlights a wider anxiety amongst wealthy individuals Decisions like these require careful thought, proactive planning, and expert advice. Are You Worried About Tax Reform in the UK? Mosaic Chambers Group can provide independent, practical advice tailored to your circumstances.

For over two centuries, the UK’s non-domiciled tax regime and its remittance basis has been a cornerstone of tax planning for wealthy expats and international families. It was introduced, along with income tax, by Willian Pitt the Younger at the very end of the 18th century. It was part of the fiscal firepower necessary to battle Napoleon Bonaparte. And, like income tax, it had pretty much been a constant feature of the UK’s system ever since. But in March 2024, the then Chancellor, Jeremy Hunt, rang the death knell for the remittance basis, with Labour’s Rachel Reeves – who would succeed Hunt a few months later - declaring she would have abolished it anyway. The end is therefore very much nigh for the UK’s non-dom tax regime. More specifically, the end is 6 April 2025. However, out with the old and in with the new’ goes the saying. As such, the ‘what comes next’ will reshape the tax landscape for non-doms, expats, and international investors with a UK footprint (or those considering creating one). What is Domicile (and Non-Domicile)? Domicile is not a straightforward concept like tax residence. The latter is largely about physical presence (or otherwise) in a particular. Instead, as well as physical presence, it also requires an understanding of your future intentions. Is a place somewhere that you intend to live permanently or indefinitely. There are two main types of domicile that I will discuss here: • Domicile of origin: This is inherited at birth, usually from your father (if you think that is misogynistic then I don’t make the rules, OK?). You do not lose your domicile of origin. However, think of it as the foundations of a building. You can a domicile of choice on top it. • Domicile of choice: You build a new domicile of choice by achieving two things. Firstly, by physically residing in place and, secondly, by forming the intention to stay in that same place permanently or indefinitely. Both must be present.

So you’ve left the UK for pastures new. The sun is shining. You're making more money. You’re enjoying a great quality of life in a new country. In fact, you’re totally de-mob happy. Even better, as a non-UK resident, UK taxes are a dim and distant unpleasant memory, right. Right? Wrong. I don’t necessarily see my role in life as chief balloon popper. However, there are some Uk tax things you should bear in mind before declaring yourself a tax exile. Am I really non-UK Resident (“NR”)? Up until 2013, the UK didn’t really have a statutory definition of residence for tax purposes. Yes, that’s as crazy as it sounds. Fortunately, the Statutory Residence Test (“SRT”) was introduced from 2013. The idea is that it provides a degree of objectivity through a series of tests. Although a statutory test, other than in straightforward cases, it can still remain complex.

The UAE has become an attractive financial hub, drawing in high-net-worth individuals and businesses looking for wealth management strategies. Offering tax-efficient structures, world-class financial institutions and access to various markets, the UAE presents opportunities for those wishing to protect or grow their wealth. Your Risk Across Borders One of the key principles of wealth management is diversification. By spreading assets across various jurisdictions, both individuals and businesses can reduce exposure to regional economic downturns, currency volatility, or regulatory shifts that might threaten their assets. International wealth management ensures financial stability and flexibility to protect from unforeseen challenges in your future financial endeavours. Access Global Investment Opportunities. Broadening one's investment options beyond local choices can drastically expand wealth potential. The UAE serves as a gateway to exclusive global markets, offering access to various asset classes such as stocks, real estate, private equity and alternative investments. By employing strategic plans investors can take full advantage of these opportunities to diversify portfolios and maximise returns. Currency Diversification for Financial Stability Holding assets in multiple currencies is an effective strategy for protecting wealth. Currency fluctuations can have serious ramifications on purchasing power and investment value; by diversifying into multiple currency portfolios, individuals can protect themselves against depreciation and inflationary pressures. The UAE financial ecosystem offers access to numerous multi-currency investments to boost financial resilience. Geopolitical Hedging and Regulatory Stability Global economic conditions are constantly shifting, and regulatory changes in any country can have significant ramifications on financial security. Diversifying holdings among multiple jurisdictions provides a safeguard against geopolitical uncertainty while keeping assets secure regardless of market fluctuations locally. UAE regulatory framework facilitates this strategy with investor-friendly policies and financial instruments designed to safeguard wealth. Summary Wealth and financial planning in the UAE provide unique opportunities for growth, security and long-term prosperity. By taking advantage of global investment access, currency diversification and geopolitical hedging tools available today - individuals and businesses alike can safeguard and expand their assets with confidence. With expert assistance from Mosaic Chambers Group's Wealth Planning services you can create a tailored wealth plan tailored towards achieving your goals while protecting the future.

THE NEW RULES IT & CGT - The new 4 year Foreign Income and Gains (“FIG”) regime With the remittance basis of tax soon to be sent packing, we might wonder what, if anything, stands in its place? Indeed, Jeremy Hunt suggested a replacement regime which has been largely adopted as was by the new Labour Government. So, is this new regime akin to the dog’s naughty bits?.... or simply a dog’s breakfast? Well, in truth, we are probably somewhere in the middle. Sadly, we didn’t get anything quite as attractive as the regime on offer in Italy. But we did get something. What is this fiscal Newfoundland? Firstly, in line with the decision to largely banish domicile as a connecting factor from the tax code, a residence-based regime will take effect from 6 April 2025. Individuals who elect for this regime will not pay UK tax on foreign income and gains (FIG) for the first 4 years of tax residence. It should be noted that this will only apply to those who are coming to the UK for the first time or, at least, have not been resident in the UK in any of the previous 10 tax years. For those who became resident for tax purposes in 2022/23, 2023/24 and 2024/25 tax years (ie less than 4 years) they will be allowed to benefit from the regime until they have been resident for the balance of their first four years. Illustration – current remittance basis user interrupted by new FIG regime

THE PRE 6 APRIL 2025 RULES Individuals So, what are these favourable rules that are being scrapped? Firstly, various changes have taken place to the non-dom / remittance basis rules over the years. Each sortie by the legislator taking its toll on the attractiveness of these rules. As such, I will look at some of the history which, I aver, it might be useful to know. So, let’s see what we can Golden Retrieve from the memory banks. Income tax and Capital Gains Tax (”CGT”) The remittance basis simply provides the non-dom taxpayer with the privilege of leaving his or her foreign income and gains (“FIG”) overseas without any tax being paid. If he or she leaves it overseas then there is no tax to pay. However, if he or she brings, enjoys or uses the funds in the UK then they will suffer tax to the extent that they do so. If it is foreign income that is ‘remitted’ then it will suffer UK income tax. If it is a foreign gain that is remitted then it will suffer CGT. When the funds remitted were ‘mixed’ then special rules would apply. In order to use the remittance basis, one must make an election and potentially pay a fee to use it1. The amount payable depends on how many years one has been resident in the UK: less than 7/9 tax years: the remittance basis is ‘free of charge’; between 7/9 tax years and 12/14 tax years: the remittance basis charge is £30k if one has been resident in the UK for 12/14 or more tax years and 17/20 tax years then one must pay 60k. Prior to 2017, there was another tier of 17/20 tax years at which point the Remittance Basis Charge was £90k. However, this was scrapped when that years Finance Act created a long-stop date of being able to use the remittance basis of 15/20 tax years after which the ability to use the remittance basis was pulled (this was known as being deemed domiciled for income tax and CGT purposes). A taxpayer had flexibility to choose whether to pay the Remittance Basis Charge in one year and not another. It would simply be a ‘cost v benefit’ calculation for a particular tax year. Inheritance Tax (“IHT”) Under pre 6 April 2025 rules, IHT primarily looked one’s domicile position rather than residence. The position is that if one is domiciled in the UK then you pay UK IHT on worldwide assets. Whether that person is non-resident at the point of death is largely unimportant (unless also franked by valid claims to be non-UK domiciled). A non-domiciled (and non-deemed) individual is subject to IHT on UK assets only. Prior to 2017, a non-dom who had been resident in the UK for 17 out of 20 tax years would become ‘deemed domiciled’ for IHT purposes only. However, with the concept of ‘deemed domiciled’ being introduced for income tax and CGT as well, the threshold became 15/20 tax years across the board. The rules for trusts The concept of protected trusts was introduced in 2017. Let us first remind ourselves of the framework that preceded that one. The Pre-2017 position The basic position before 2017 was that a non-UK trust (other than in respect of UK residential property from April 2015) did not pay UK CGT regardless of where the asset was located. This is based on the fundamental jurisdictional basis of UK CGT. However, such a simple rule – which would be open to significant abuse if existed in isolation – was bolstered by a plethora of anti-avoidance rules2. Prior to 2017, those anti-avoidance rules: looked to attach the gains of the trust to a UK settlor under certain circumstances; or alternatively, looked to attach the gains of the trust to a UK beneficiary. Under those rules, where a settlor retained an interest (for ease, let’s say they may still benefit from the trust property) under a non-UK trust then the tax position depended on the settlor’s domicile position: a UK domiciled settlor: taxed on the trust gains as they arise (under TCGA1992, s86; a non-dom settlor was not Where the trust was not settlor interested then the anti-avoidance code switched its beady eyes to the beneficiaries of the trust. Specifically, it looked to see whether there was a link between the beneficiary and the UK: If the beneficiary was UK resident and domiciled then capital payments (or benefits) he or she received were matched with any trust gains and the beneficiary pays tax; If the beneficiary was non-dom then, he or she was only taxable (in respect of any capital payments or benefits matched with trust gains) on the remittance basis; If the beneficiary was non-dom and non-resident then the provisions (TCGA 1992, s87) were unlikely to impose a charge (subject to other anti-avoidance rules). IHT for trusts Under the pre-April 2025 rules, trusts established by non-domiciled individuals would benefit from the attractive excluded property regime to the extent that property in the trust was of a non-UK situs. Broadly, such property is outside of the scope of UK IHT status to the extent that the trustees hold non-UK assets. In addition, this includes trust property being outside of the Relevant Property Trust regime (eg 10 year / exit charge) for trusts. As to whether trust property was excluded property the domicile status of the settlor was tested only at the time the trust was established. So, if the settlor subsequently became deemed domiciled for IHT purposes, this did not matter. The trust property remained excluded property and outside of any person’s estate and was no relevant property. Finally, the Gift with Reservation of Benefit Rules (“GWROB”) were trumped by the excluded property rules. This meant that the settlor could retain an interest but the value of the assets would remain outside his or her estate. B.I.N.G.O. The position between April 2017 – 5 April 2025 & Protected trusts The basic position for trusts – whether considering income or capital gains - was no different to that which existed prior to 2017. However, again, the complications came when it comes to the anti-avoidance provisions at work. As we have seen above, under the previous rules, relief was given where non-doms were the settlors of such trusts and / or where such people received benefits from said trust. The rules between 2017-2025 had some additional problems to grapple. This was because it was in 2017 that the concept of ‘deemed domicile’ was introduced for income tax and CGT purposes. In other words, a long stop date to the benefits a non-dom can obtain. Of course, for those non-domiciled individuals who had set up trusts before they became deemed domiciled under the new rules , removing the reliefs described above from the trust anti-avoidance provisions would be a massive rug-pull. This ‘protected trust’ relief applied to those who set up trusts whilst non-dom but who became ‘deemed-dom’ in years from 2017/18 onwards. Under the CGT trust protections , s86 generally did not apply where a settlor became deemed domiciled under the new rules. This meant that whilst value is left within the trust there will be a gross roll up of gains. Instead, the tax position focused on capital payments or benefits actually paid out to beneficiaries. The tax treatment depended on which category of person the payment or benefit is made to: Close family members (spouses, co-habitees, minor children, not grandchildren): Other persons Where receipt is by a close family member then, if they were subject to tax on the receipt, then that was that. If not, for instance they were non-resident, then the Settlor was liable for tax. If the receipt was by an ‘other person’ then the tax position was dependent on the recipient’s status. Of course, if it is the settlor then he will pay tax based on his own position. Illustration – Protected trusts and CGT summary

Background – The British Bulldog v French Bulldog At the dying end of the 18th century, a little man with a big ego was throwing his weight around in Europe. His name was Napoleon. You might have heard of him. At the same time, William Pitt the Younger, at an impossibly young age of 24, was the UK’s prime minister. He wasn’t given a particularly easy ride as, at the same time, King George III was losing his marbles. In 1799, young Pitt introduced for the first time an income tax in order to pay for his fight with the angry little Frenchman. It was at this same time that he also introduced a remittance basis of taxation for overseas civil servants who, in today’s terminology, might be referred to as non-doms. The idea was to provide them with relief from these new taxes in relation to their overseas property. Little did young Pitt know that he was creating a political football and a fiscal tightrope for centuries to come. Something that would only be cast aside some 226 years later. So, it was a surprise when Jeremy Hunt the Beiger announced in Spring Budget 2024 the abolition of the remittance basis of taxation and, more generally, the removal of domicile as a main determining factor for UK taxation. It was perhaps less of a surprise when Chancellor Rachel Reeves, with a slightly less impressive CV (even the made up one) when compared to Pitt, flourished the pen to sign the non-dom demise. So, has the UK’s big tax dog finally had its day? A woof guide to domicile. So what is domicile and, by negative extension, non-domicile? Although, unusually, domicile has had an important impact on a person’s tax position in the UK it is not a pure tax construct. It is a concept of general law. It is therefore important to note that the proposed abolition of the non-dom tax changes are merely changes to the tax consequences of such a status. It does not change the position from a general law perspective. For example, they will apply to things like the law of succession and will even continue to be relevant for some double tax treaties. Dicey, in his tome Conflicts of Laws, provides the authoritative definition of domicile of origin: 'every person receives at birth a domicile of origin…A legitimate child born during the lifetime of his father has a domicile of origin in the country in which his father was domiciled at the time of his birth' In sum, one inherits a domicile of origin (“DO”) at birth. To use archaic terminology, where one is ‘legitimate’, then you inherit your DO from your father. Where your mother and father are not married, then a DO is inherited from one’s mother. A DO is rather sticky and tenacious. There must be strong evidence that a domicile of choice (“DC”) has been acquired elsewhere for it to be overtaken. Indeed, one does not completely shed a DO. Instead, think of the DO as the foundation of a building. It will remain as it is until someone takes the trouble to build something on top of it. A DC might be built on this foundation. Again, Dicey provides us with the commentary: ‘every independent person can acquire a domicile of choice by the combination of residence and intention of permanent and indefinite residence, but not otherwise’ As such, in order to build a DC, it is necessary to have: intention to reside permanently / indefinitely in a place; and physical residence in that place. Where this is the case, and can be backed up by evidence, the edifice will remain strong. However, where an element is missing then the walls will come tumbling down and you will be left with the foundations. In other words, your domicile of origin. But this is a double edged sword. What if little ‘ol me tried to assert I was domiciled in Spain? I have a domicile of origin in the UK (or should that be the People’s Republic of Yorkshire?) In order to develop a domicile of choice in Spain I would need to both be resident in Spain, but also show, and evidence, my intention to reside there indefinitely. Of course, if I came back, or even just hopped across the border to France, then I no longer reside there and would no longer have a DC in Spain. My DO in the UK would revert. And that simply wouldn’t Labra-doo. In part 2 of our series, we look at the pre-6 April 2025 rules, covering income tax, CGT, IHT, and trust regulations. Find out what’s changing, why it matters, and how it could impact your financial planning.

In 2025, the UAE is set to solidify its reputation as the ultimate destination for wealth, attracting an estimated 6,700 millionaires to its shores. This surge in high-net-worth individuals (HNWIs) is positioning the UAE as the premier global hub for the affluent, surpassing long-established wealth centres like the UK and the US. If you’re looking to relocate to Dubai or invest in the region, now is the perfect time to look at the opportunities it has to offer. What are the benefits of moving to the UAE? The UAE has become the go-to location for millionaires, and it’s not hard to see why: Tax Benefits: With no income tax and no inheritance tax, the UAE has a compelling financial advantage. If you are looking to maximise your wealth, these tax policies provide a rare opportunity to preserve and grow your assets. Lifestyle Excellence: Cities like Dubai and Abu Dhabi offer an exceptional lifestyle, from world-class healthcare and top-tier international schools to luxury living and fine dining. Whether you're interested in high-end real estate or enjoying a cosmopolitan lifestyle, the UAE delivers in every aspect. Stability and Security: In a world where economic and political volatility are increasingly common, the UAE’s robust political stability and thriving economy offer peace of mind. For those seeking a secure environment for both their wealth and family, the UAE stands as a beacon of certainty. The Impact on the Economy As more millionaires relocate to Dubai and other cities, the economic impact is clear: Real Estate Demand: Luxury property prices in Dubai have already seen a 10% rise in 2024, and with more HNWIs moving to the UAE, demand for high-end real estate will continue to grow. This makes the UAE an attractive location for both investment and personal residence. Sector Growth: Industries such as financial services, hospitality, and luxury retail are all expanding rapidly. With more wealth coming into the region, these sectors are being reinforced to meet the needs of the growing affluent population. Wealth Management Expansion: As millionaires settle in the UAE, the demand for sophisticated wealth management solutions is increasing. This provides unique opportunities for financial planners and wealth managers to help you optimise your portfolio in a tax-advantaged environment. The Challenges Ahead The rapid influx of wealth does come with its challenges: Infrastructure Strain: As more millionaires relocate, the pressure on the UAE’s infrastructure intensifies. From transportation to housing, ensuring that the region can accommodate this growing population is a key focus for local authorities. Environmental Impact: As urbanisation accelerates, sustainable growth practices will be critical to minimising the environmental footprint. The UAE is already taking steps to address this, but managing growth responsibly remains an ongoing challenge. Social Equity: With wealth flowing into the region, the potential for inequality exists. It’s essential for policies to address this disparity, ensuring that the economic benefits are shared broadly while maintaining the UAE’s global competitiveness. Conclusion The UAE is well on its way to becoming the world’s foremost destination for wealth in 2025. Whether you’re considering relocating to Dubai, diversifying your investments, or looking for tax-efficient wealth planning solutions, the UAE’s combination of stability, tax advantages, and high-quality lifestyle options makes it an unparalleled choice. For those serious about securing their financial future and enjoying a prosperous life in one of the world’s most dynamic economies, now is the time to act. The UAE’s rise as a wealth magnet underscores its strategic appeal. If you’re considering relocating or investing in the UAE, reach out for expert financial advice.

Why settle for drizzle when Dubai offers tax-free zones, luxury living, and booming business opportunities? Learn why expats are making a comeback.

New Year, New Rues: Learn about UAE corporate tax penalties for late registration in 2025. Avoid fines of up to AED 50,000 with expert advice on compliance and timely registration.

Plan for 2025 with our top 10 financial tips. From the Autumn Budget tax changes to financial planning, ISA contributions & estate planning, optimising your savings & securing your wealth.

The 2024 UK Budget delivered a series of tax increases that could weigh heavily on business owners. With higher corporate tax rates, reduced allowances, and more stringent compliance measures, running a business in the UK is becoming increasingly expensive. For those seeking growth-friendly environments, the UAE offers a compelling alternative, boasting a 9% corporate tax rate, zero personal income tax, and a growing global reputation as a business hub. This shift highlights the need for business owners to assess how tax policies align with their ambitions. In the UAE, businesses benefit from economic incentives, robust infrastructure, and a strategic global position, making it an attractive destination for international entrepreneurs. Key Budget Changes and Their Impact National Insurance Contributions Employers face rising NIC rates (from 13.8% to 15%) and lower thresholds for payments. Despite an increase in the Employment Allowance, the added costs will strain resources for small and medium enterprises (SMEs). The UAE has no income tax or NICs: The absence of income tax or NICs allows companies to reinvest in growth without the burden of rising employment costs. Capital Gains Tax Reform CGT rates have risen to 18% for the basic rate and 24% for the higher rate, impacting disposals after October 2024. Additionally, Business Asset Disposal Relief (BADR) will climb to 14% by 2025. For entrepreneurs selling assets, these changes substantially reduce net returns, limiting funds for reinvestment. The UAE has no CGT: With no CGT, business owners retain more of their profits, fuelling growth and wealth preservation. Changes to Non-Domicile Taxation and Inheritance Rules From April 2025, the non-domicile regime will shift to a residence-based system, narrowing exemptions for offshore income. Additionally, inheritance tax (IHT) reliefs for agricultural and business assets will be capped at £1 million. The UAE does not impose an inheritance tax: Free from inheritance taxes, the UAE offers business owners the freedom to secure their wealth for future generations without complex compliance hurdles. A Strategic Relocation? For UK business owners, the Autumn Budget underscores the urgency of reassessing long-term plans. The UAE, with its favourable tax environment and vibrant business ecosystem, offers a unique opportunity to secure growth and preserve wealth in an increasingly complex fiscal climate. Whether you’re planning to expand or relocate, expert advice is crucial. Our team is here to help you every step of the way. Book a call with one of our advisors below.

The UAE Golden Visa is a long-term residency programme offering 5 or 10-year renewable permits depending on eligibility criteria. Unlike standard residency visas, however, this one allows foreign nationals to live, work, and study without needing an UAE national sponsor. For innovators, investors and skilled professionals looking to take advantage of the UAE's dynamic economy, tax-free income stream and luxurious lifestyle - this visa provides individuals the chance to move in permanently while taking full advantage of all its advantages. Key Features of the Golden Visa Experience Long-Term Residency Take advantage of long-term residency to make life simpler, without the hassle of frequent renewals and build the foundation to advance your career, business or personal life. A five or 10-year renewable visa provides the security needed for growth in all aspects of your life: career advancement, business expansion or personal relationships. Sponsor Freedom Unlike many UAE visas, the Golden Visa gives you more control and independence in managing your residency status in this country. Multiple Entry Privileges Enjoy travel into and out of the UAE freely without incurring entry permits or visa restrictions - making this privilege ideal for business travellers as well as global citizens. Family Sponsorship Make the most of your Golden Visa by including spouse, children and any dependents as beneficiaries so they can live, work and study alongside you in the UAE. Eligibility Criteria of UAE Golden Visa • Individuals across all categories are eligible for these loans, with each grouping having its own eligibility requirements. • Investors investing at least AED 2 Million in an approved UAE business or fund. • Real Estate Investors who own properties worth AED 2 Million can secure a five year renewable visa. • Entrepreneurs: Start-up owners who possess at least AED 500,000 of capital with the approval from an UAE government entity can apply. • Talented Professionals: Individuals skilled in fields like science, medicine, engineering arts & culture who meet specific educational/professional benchmarks. • Outstanding Students: Emirati universities enrolling top performing students Who Should Consider an UAE Golden Visa? • Investors: Individuals seeking a secure and profitable environment to launch or expand business ventures. • Entrepreneurs: Creative thinkers with innovative ideas seeking success in an ever-evolving market. • Talented Professionals: Highly skilled professionals seeking to make an impactful contribution in UAE industries. • Outstanding Students: Top students aspiring towards global educational systems. How Can Mosaic Chambers Help? Navigating the UAE Golden Visa application process may seem complicated and overwhelming, but with Mosaic Chambers will make the process straightforward and worry-free! From eligibility evaluation and paper processing through to helping secure a Golden Visa! For more information, contact one of our advisors.

Our Director, Andy Wood, has written an article for Taxation, offering guidance on handling some of the tougher financial challenges associated with cryptocurrency from a tax perspective. The piece includes analysis of the position for investors affected by the seismic Celsius and FTX bankruptcies. It also explores the risks of owning cryptoassets, such as lost keys, scams, and hacking. To learn more, enter your details below and we will send the article to your inbox. If you have any questions, get in touch here.

The UK’s March 2024 Budget introduced sweeping reforms to the taxation of “non-doms,” with confirmation from the new Labour Government in the Autumn Budget that these changes would proceed in largely the same form.

Are You Thinking of Establishing Residency in the UAE? Mosaic Chambers provides expert guidance across all residency visa options to individuals and families, helping individuals identify the most suitable visa type to meet their goals and qualifications. Whether it is investors, entrepreneurs, employees, retirees, students or freelancers looking for residency visas our comprehensive blog outlines every UAE residency pathway including eligibility criteria and application steps for each.

Mosaic Chambers provides comprehensive guidance on residency routes, helping you make well-informed decisions about relocating to Dubai and the various residency and Visa options.

Firstly, let’s be honest, its great to see HMRC referring to Business Property Relief again. None of that Business Relief nonsense that has crept in over recent years. I would say that is probably the most significant part of the Budget. Of course, you might also be interested in the pretty seismic cuts to: Business Property Relief; and Agricultural Property Relief You are? That’s disappointing. I was hoping to save my poor fingers. Here we go then. Business Property Relief (“BPR”) The Budget announced that both BPR and APR will become subject to a £1m cap from April 2026. Presently, there is no cap on either meaning, that assuming assets qualify for the relief, both lifetime gifts and assets in the death estate can benefit from relief at a rate which is often 100%. In respect of BPR, for example, the shares in an unquoted, family trading business will qualify for BPR at 100% as long as the shares have been held for two years. This means that they can be: transferred into trust without an immediate IHT charge (and often no 10 year charge and no exit charge if the assets are still held at the relevant time); the subject matter of an outright gift and, even it that PET fails, there will be no IHT; and form part of the death estate without there being an IHT charge As I say, the value of relief could be unlimited. However, there is now a cap of £1m. Beyond that, relief is capped at 50%. It should be noted that these changes only apply to the 100% rate. The following business property will qualify for 100% relief: property consisting of a business or interest in a business; unquoted securities of a company which give the transferor control of the company immediately before the transfer; any unquoted shares in a company (see below re changes to AIM shares) If the assets only qualified for the existing 50% rate, for example, a controlling interest in a quoted company, then the new rules do not effect the position – 50% relief applies to the entire value (and does not use up any of the cap). Agricultural Property Relief (“APR”) The same cap will also apply to agricultural land. The following agricultural assets qualify for 100% relief: where there is a right to vacant possession, or vacant possession is obtainable within 12 months (extended, by concession, to 24 months and to circumstances where the tenanted value and vacant possession values are broadly similar). where the property is let on a tenancy beginning after 31 August 1995 (or, in Scotland, a tenancy acquired after that date by right of succession). where the transferor was beneficially entitled to the interest transferred before 10 March 1981 and relief would have been available under the rules then in force. Again, the first £1m of value related to these assets will qualify for the 100% relief with the balance being subject to relief at just 50%. For assets which already only qualify for 50% relief, these are unaffected by the changes. Interaction of BPR and APR under the new £1m Cap The £1m cap applies across both. In other words, you don’t get £1m for BPR and £1m for APR… the spoilsports. Instead, the cap is allocated proportionality over agricultural and business assets. So, in a scenario where Jimmy has the following assets qualifying for BPR / APR reliefs at 100%: £3m of BPR assets; and £2m of APR assets The cap is allocated as £3m/£5m x £1 = £600k to BPR and £2m/£5m x £1m = £400k to APR assets. The balances receive relief at 50%. The £1m Allowance and Trusts A trust will also get a £1m allowance to cover the 10 year charge and also exit charges. It will be applied in the same way, with any assets that qualify for the 100% relief being exempt up to the first £1m with the balance being subject to tax at 50%. Where a person sets up multiple trusts on or after 30 October 2024, we are told that there will be anti-avoidance rules that split the allowance between those trusts. AIM Shares In addition, AIM shares will no longer benefit from 100% relief where held for two years. This is because relief of 50% will now apply to any shares that are listed on non-recognised stock exchanges. The AIM market will be such an exchange (ie not a recognised exchange). This removes an odd feature of the legislation that I have commented on quite a few times in the past. Click here to read. Conclusion These are really big changes which will fetter the ability of business owners and / or farmers to pass on their businesses to the next generation of the family. As such, consideration will need to be given on alternative plans such as outright gifts and life insurance.

It seems odd to group these things together. Employee Ownership Trusts are warm and fluffy. Encouraged by government to increase employee ownership. A cynic might say loved by business owners looking for a tax efficient exit. Whereas Employee Benefit Trusts are the thing of nightmares. They carry more baggage than an average Swissport employee. But they are very much cut from the same cloth. Budget 2024 announced restrictions in the application of both. Let’s take a butchers. Employee Ownership Trusts (“EOTs”) What is an EOT? Employee Ownership Trusts (EOTs) were introduced under the Finance Act 2014 to promote indirect employee ownership by allowing employees to collectively own shares through a trust. In theory, this model incentivises employees by enabling them to benefit from the company’s success, which can enhance employee motivation, retention, and overall company growth. In addition, and of interest to the business owner, EOTs come with specific tax reliefs: capital gains tax (CGT) relief on share disposals, inheritance tax (IHT) relief, and income tax relief on employee bonuses. The CGT relief allows owners to transfer a controlling share (over 50%) of their business into an EOT without triggering CGT, provided the company meets certain conditions, such as being actively trading and equally benefiting all employees. It is not an exemption, but a form of holdover relief. Meaning the trustees essentially pick up the tab for the historic gain when they come to sell. IHT relief is also available for shares transferred into an EOT, making it exempt from charges typically associated with trusts. With the restrictions to BPR announced in the Budget, this might become more attractive for new EOTs going forward. Additionally, employees of EOT-owned companies can receive annual bonuses up to £3,600 tax-free. regulations, professional advice is recommended for companies considering this structure. The changes to EOTs in summary The Chartered Institute of Taxation, for some reason, has had a bee in its bonnet about EOTs for the last few years and it might be said these changes are, at least in part, down to their lobbying. Control: There will be a restriction on former owners (and those connected with them) from retaining control of companies' post-sale to the EOT by virtue of control (direct or indirect) of the Trust. This will be a problem for vendors who want to control from beyond the sale. Trustees must be UK resident: This means that the trustees cannot benefit from a tax-free eventual sale by being non-resident. As such, this ensures that the CGT relief is merely a deferral and not avoidance. The trustees will pick up the tab which will, ultimately, be borne by the employee beneficiaries. Fair market value consideration: the trustees must take reasonable steps to ensure that the consideration paid to acquire the company shares does not exceed market value. I am amazed that trustees are not already doing this. Clawback period extended: the ‘vendor clawback period’ if the Employee Ownership Trust conditions are breached post-sale, will now not end until the fourth tax year following the end of the tax year of disposal Reporting: the claim for CGT relief must include details of the sale proceeds and the number of employees of the company at the time of disposal Income tax distributions: Legislation will clarify that certain payments, including where the company makes payments to the trustees to repay consideration left outstanding to the vendors, is not taxed as a distribution. The changes had immediate effect (e.g. for disposals to the EOT from 30 October 2024 onwards). Employee Benefit Trusts (“EBTs”) Introduction Darkness descends. A wolf howls in the distance. A shiver runs down your spine. Yes, its EBTs folks. However, despite their use for PAYE and corporation tax, EBTs have remained interesting for capital tax planning reasons – whether for IHT purposes of CGT purposes. The shares in a genuine business (note, not necessarily trading) could be transferred to an EBT (without the bells and whistles of the EOT) without it being a transfer of value and without an immediate CGT charge where certain conditions were satisfied. These conditions being less onerous than the EOT. Again, with the curtailing of BPR and BADR, they will remain so in the future. However, one will need to be more and more careful, and the scenarios they will be appropriate have probably reduced somewhat as a result of the Budget. Let’s take a peep… from behind the sofa. The Budget 2024 changes The changes can be summarised as follows: ensure that the restrictions on connected persons benefiting from an Employee Benefit Trust must apply for the lifetime of the trust restrict the Inheritance Tax exemption to where the shares have been held for two years prior to settlement into an Employee Benefit Trust — where there has been a share reorganisation, the shares previously held will be taken into account in considering the two-year holding period ensure that no more than 25% of employees who can receive income payments should be connected to the participator in order for the Employee Benefit Trust to benefit from favourable tax treatment The first of these is unlikely to be a problem – other than for pretty egregious planning which has already been fingered by the GAAR Advisory Panel. You could probably say the same about the second one. The third may have more practical reasons and is likely to mean that EBTs, for these purposes, will have to be used for businesses which have, and are prepared to benefit, a more diverse cohort of employee beneficiaries.

Could we get any sleepier than IHT and pensions. You're forgetting, this is the Rachel Reeves rock and roll budget. Brace yourselves. Current Tax Position on Death Other than in the case of non-discretionary pension schemes, the benefits in a pension scheme escape IHT on death. However, that is not the full picture. Generally speaking, the surplus value in a pension scheme may be subject to income tax in the hands of the recipient, depending on whether the member has reached the age of 75 or not. If the member dies before the age of 75, then the death benefits are usually paid free of tax (though this is a simplified answer). Death benefits paid when the individual dies age 75 or over are taxed at the recipient’s marginal rate of income tax. New Proposals In the Budget, we were told that unused pension funds and death benefits payable from a pension will be added to a person’s estate for Inheritance Tax purposes. This will take effect from 6 April 2027. It will be down to pension scheme administrators to report and pay any IHT due. As such, it seems to be the intention that, where the pensioner is over the age of 75, that the surplus pension fund could be subject to 40% IHT on death. If, say, a child or grandchild receives benefits then the beneficiary will also be subject to tax at a rate of up to 45% on those receipts. This means that the funds could be subject to an overall rate of 67%! Of course, the pension is likely to have benefited from tax relief on contributions going in and tax-free investment growth (generally). But, all the same, seems a bit stingy, Rachel. What about QNUPS? I’ve not seen much about QNUPS in the comments I’ve seen elsewhere. However, it is abundantly clear that the IHT changes will also apply to QNUPS. The Consultation Doc on this aspect states the following: “1.13. While the relevant changes will apply equally to UK registered schemes and QNUPS, any references to pension schemes in this consultation document should be taken as referring to UK registered pension schemes administered by PSAs. We recognise that QNUPS have a different administrative structure to UK registered schemes, and stakeholders are welcome provide any views on how these changes should be implemented for QNUPS (see Question 8 below). “ This is perhaps not a surprise bearing in mind the number of people marketing QNUPS as IHT saving vehicles. But those days appear to be over. That’s a shame. Conclusion Where pensions and QNUPs might have been sold on the basis of their IHT efficiency in the past, this will not be the case from the new rules taking effect in April 2027.

Back in the election manifestoes, Labour had promised to raise more stamp duty by adding another 1% on the rate for non-residents buying UK residential property. The surcharge for foreigners being 2%. This seemed perfect. A tax not only paid by ‘others’ (the best kind of tax). But it would be payable by ‘others’ located overseas. However, it seems that Labour has eschewed such an obvious move and decided to add this to the surcharge applied to anyone purchasing an ‘additional’ property. It is assumed this is a much more lucrative move.

The Labour Budget brought substantial updates to Capital Gains Tax, focusing on rate adjustments and relief reductions. Business Asset Disposal Relief (BADR) will see phased rate hikes, reaching 18% by April 2026, significantly reducing its benefit. Investors' Relief also faces cuts, with rates increased to 14% and 18% in stages and a reduced lifetime limit of £1 million. Click to read more...

The 2024 Labour Budget brings major changes to the QROPS (Qualifying Recognised Overseas Pension Scheme) landscape, affecting UK pension transfers overseas. The Overseas Transfer Charge (OTC) will now apply to all transfers outside the UK, including those to the EEA. EEA pension schemes must align with global regulatory standards, and UK-registered pension scheme administrators will need UK residency by 2026. These adjustments reflect post-Brexit shifts in tax relief and regulation, impacting QROPS providers and UK residents with overseas pensions.

Labour's latest budget introduces substantial reforms targeting UK non-domiciled (non-dom) residents, reshaping the tax landscape starting in April 2025. For expats, non-doms, and high-net-worth individuals with global assets, these changes will bring both new tax obligations and potential opportunities.