Tax Requirements For Expats Doing Business In The United Kingdom

Exploring the Tax Requirements for Expats Doing Business in the United Kingdom unveils a landscape filled with intricate details and obligations. This topic not only concerns the basic compliance with taxation laws but also touches on the nuances of international treaties and personal financial planning.

As expats navigate the complexities of conducting business in the UK, understanding the local tax system becomes crucial for ensuring both legal compliance and financial efficiency.

In the UK, expats face a diverse array of tax considerations, from income tax and value-added tax (VAT) to national insurance contributions and corporate tax obligations. Recognizing the importance of these elements is essential for any expat entrepreneur aiming to thrive in the UK market.

Furthermore, the intricacies of double taxation agreements and capital gains tax add additional layers to the financial landscape, making it imperative for expats to stay informed and seek professional advice when necessary.

Overview of Tax Requirements for Expats in the UK

Navigating the tax landscape as an expatriate doing business in the United Kingdom can be complex, yet it’s crucial for ensuring compliance and avoiding potential penalties. Understanding the tax obligations, distinctions between resident and non-resident statuses, and the significance of the UK tax year are essential components for any expat engaged in business activities in the UK.The UK offers a structured tax system, which includes multiple obligations that expats must fulfill.

These obligations are primarily influenced by your residency status, which determines your tax liabilities, including income tax, national insurance contributions, and potentially Capital Gains Tax. One must be well-versed in these regulations to ensure proper financial management and compliance.

Tax Obligations for Expats Doing Business in the UK

Expats doing business in the UK are subject to a range of tax obligations that must be diligently managed throughout the tax year. These obligations include registering with HM Revenue and Customs (HMRC), submitting accurate tax returns, and paying any taxes due.

• Income Tax: Expats must pay income tax on earnings, and the rates can vary depending on the income bracket and residency status.
• National Insurance Contributions: These are mandatory for individuals earning above a certain threshold and depend on the employment status and earnings.
• Value Added Tax (VAT): Businesses may need to register for VAT if their taxable turnover exceeds the threshold set by HMRC.

Resident and Non-Resident Tax Statuses

Understanding whether you are considered a resident or non-resident for tax purposes is critical in determining your tax liabilities in the UK. The Statutory Residence Test helps in determining this status and involves several factors, such as the number of days spent in the UK and connections to the country.

Expats deemed residents are taxed on their worldwide income, while non-residents are typically taxed only on their UK-sourced income.

• Resident: Generally, spending 183 days or more in the UK within a tax year would categorize you as a resident.
• Non-Resident: Staying fewer than 183 days in the UK while maintaining strong ties abroad may qualify you as a non-resident.

Importance of Understanding the UK Tax Year

The UK tax year runs from April 6th to April 5th the following year. Awareness of this timeframe is vital for effective tax planning and compliance.

• Tax Planning: Aligning financial activities with the tax year can optimize tax obligations and benefits.
• Filing Deadlines: Ensure timely submission of tax returns and payments to avoid penalties and interest.

Understanding these aspects helps expats manage their tax responsibilities effectively while conducting business in the UK, ensuring adherence to local laws and regulations.

Income Tax for Expats

Expats living and working in the United Kingdom are subject to the country’s tax regulations, which can initially seem complicated due to the unique aspects of British taxation. Understanding income tax rates, personal allowances, and filing requirements is crucial for expats to manage their financial obligations effectively.

Income Tax Rates Applicable to Expats

The United Kingdom employs a progressive tax system where income is taxed at increasing rates based on earnings. It’s important for expats to be aware of these rates as they directly impact their net income. As of the current tax year, the income tax bands in the UK are as follows:

• Personal Allowance: Up to £12,570 – 0% tax rate.
• Basic Rate: £12,571 to £50,270 – 20% tax rate.
• Higher Rate: £50,271 to £150,000 – 40% tax rate.
• Additional Rate: Over £150,000 – 45% tax rate.

Understanding these brackets helps expats anticipate their tax liabilities accurately. Note that these rates do not include National Insurance contributions, which also apply to earnings.

Implications of Personal Allowances on Taxable Income

Personal allowances significantly influence the amount of income tax an expat needs to pay. This allowance acts as a threshold of tax-free income. For most individuals, the personal allowance is £12,570, but this can be adjusted depending on specific circumstances such as age, income, and residency status.

For every £2 earned over £100,000, £1 of the personal allowance is lost, leading to a marginal tax rate increase.

This mechanism means that expats earning substantial incomes may find their personal allowance reduced or eliminated, resulting in higher taxable income. Planning income distribution or timing can help optimize tax efficiency.

Filing Income Tax Returns as an Expat

Expats are generally required to file a Self Assessment tax return if they have other untaxed income, such as rental income, tips, or substantial interest and dividends. The process ensures that any tax due is accurately calculated and paid.The deadline for filing paper tax returns is October 31, while online submissions are due by January 31 following the end of the tax year.

Expats should ensure they have all necessary documentation, such as P60s or P45s, and any foreign income details to facilitate this process.Many expats find it beneficial to consult with a tax advisor familiar with both the UK system and international tax treaties to avoid double taxation and to claim any possible reliefs or exemptions.

This can be particularly valuable in understanding cross-border tax implications and ensuring compliance with both UK and home country tax obligations.

Value Added Tax (VAT)

Navigating the landscape of taxation as an expat doing business in the UK requires a solid understanding of the Value Added Tax (VAT) system. VAT is a consumption tax levied on the sale of goods and services in the UK, and understanding its nuances is crucial for compliance and effective financial planning.

This section will illuminate the process of VAT registration, thresholds, implications for small businesses, and a comparison of VAT rates across different sectors.

VAT Registration Process for Expat-Owned Businesses

Registering for VAT is a mandatory step for businesses reaching certain revenue thresholds or if they choose to do so voluntarily. For expat-owned businesses, this process ensures compliance with UK tax laws and can enhance credibility with clients and suppliers.

• To register for VAT, expat-owned businesses must submit an application to HM Revenue & Customs (HMRC) using the online VAT registration service.
• After registration, businesses receive a VAT registration certificate, which includes the VAT number and confirms when to submit the first VAT Return and payment.
• Businesses must regularly submit VAT returns, detailing income and expenses, and pay any VAT due to HMRC.

Thresholds for VAT Registration and Implications for Small Businesses

Understanding the VAT registration threshold is crucial for expat entrepreneurs, particularly those running small businesses. If the company’s taxable turnover exceeds the threshold, VAT registration becomes compulsory, affecting pricing and accounting practices.

• The current VAT registration threshold is £85,000. Businesses exceeding this amount of taxable turnover in a rolling 12-month period must register for VAT.
• Small businesses below this threshold can choose to register voluntarily, which might be beneficial if they purchase a lot of goods where VAT can be reclaimed.
• Registering for VAT affects cash flow, as the business must charge VAT on sales and pay it to HMRC, but it also allows the reclaiming of VAT on purchases and expenses.

Comparison of VAT Rates for Different Sectors

VAT rates in the UK vary across different sectors, impacting the pricing strategies and market competitiveness of expat-owned businesses. Understanding these rates helps in accurate pricing and financial forecasting.

Sector	Standard VAT Rate
General Goods and Services	20%
Reduced-rate Items (e.g., domestic fuel)	5%
Zero-rated Items (e.g., books, children’s clothing)	0%

“Understanding the diverse VAT rates and their application can significantly influence a business’s pricing model and profitability.”

By comprehending the intricacies of VAT, expat entrepreneurs in the UK can not only ensure compliance but also optimize their financial strategies for sustained success.

National Insurance Contributions

Understanding National Insurance Contributions (NICs) is crucial for expats doing business in the UK, as it affects their tax liabilities and eligibility for social security benefits. NICs are payments made to the UK government to qualify for certain state benefits.

For expats, the intricacies of NICs can vary based on their employment status and residence status in the UK.The different types of contributions need to be assessed, especially for self-employed individuals, as they have distinct calculation methods. Moreover, NICs also determine the entitlement to social security benefits, making them an essential aspect of an expat’s financial obligations in the UK.

Types of National Insurance Contributions for Expats

Expats must identify which class of NICs they fall under to ensure compliance and adequate contributions. The different types include:

• Class 1 NICs:These are paid by employees and their employers. Expats working in the UK might fall into this category if they are employed by a UK-based company.
• Class 2 NICs:Designed for self-employed individuals, these are paid at a flat rate. Expats who are self-employed will typically need to contribute under this class.
• Class 3 NICs:These are voluntary contributions, allowing individuals to fill gaps in their NIC record and qualify for state benefits.
• Class 4 NICs:Additional contributions for self-employed individuals based on their profits.

Calculating NICs for Self-Employed Expats

Self-employed expats must navigate a slightly different NICs calculation method compared to employees. Their contributions depend on their profits and are categorized into Class 2 and Class 4 NICs.Firstly, Class 2 NICsare a fixed weekly rate. For example, the rate for the 2023/24 tax year is £3.15 per week.

These contributions are essential for accessing basic state benefits, such as the State Pension.Next, Class 4 NICsare calculated as a percentage of profits. For the 2023/24 tax year, the rate is 9% on profits between £12,570 and £50,270, and 2% on profits over £50,270.

Formula for Class 4 NICs: \[ \textClass 4 NICs = 0.09 \times (\textProfits

• £12,570) + 0.02 \times (\textProfits
• £50,270, \textif any) \]

Understanding this calculation is essential for self-employed expats to ensure compliance and accurate financial planning.

Impact of NICs on Social Security Benefits

NICs are not just a tax obligation; they play a pivotal role in determining eligibility for various social security benefits in the UK. The number of qualifying years of NICs can affect an expat’s entitlement to benefits such as:

• State Pension:Typically requires a minimum of 10 qualifying years of NICs to receive any State Pension, with 35 years needed for the full State Pension.
• Maternity Allowance:Available to those who meet the criteria of sufficient NICs in the qualifying period.
• Employment and Support Allowance (ESA):Eligibility and amount can depend on the NICs record.

The impact of NICs on these benefits highlights their importance beyond mere tax compliance, affecting long-term financial security for expats living and working in the UK.

Corporate Tax Considerations

As expat entrepreneurs consider establishing or managing businesses in the United Kingdom, understanding corporate tax obligations becomes pivotal. Corporate taxes are a crucial part of the financial landscape, impacting the net profitability of enterprises. This section delves into the obligations, processes, and comparative metrics associated with corporate taxes in the UK.The corporate tax obligations for expat entrepreneurs in the UK require meticulous attention to detail.

Entrepreneurs must navigate through a structured system that ensures compliance with statutory regulations while optimizing their tax liabilities.

Corporate Tax Obligations for Expat Entrepreneurs

Corporate tax obligations in the UK demand that companies comply with the prevailing tax regulations. This involves registering for corporation tax and maintaining accurate financial records. The obligations primarily include:

• Registering for corporation tax with HM Revenue and Customs (HMRC) within three months of starting business activities.
• Preparing and submitting annual financial statements that reflect the company’s financial performance and position.
• Calculating the taxable profits and paying the correct amount of corporation tax by the due date.
• Keeping records and evidence of income, expenses, and other business activities for at least six years.

Process for Submitting Corporate Tax Returns

Navigating the process for submitting corporate tax returns can initially seem daunting, but structured steps simplify this endeavor. It is crucial for companies to be precise and timely in this regard.

1. Ensure the company is registered for corporation tax using the company’s unique taxpayer reference (UTR).
2. Compile a comprehensive set of financial statements, ensuring all revenue and expenses are accurately recorded.
3. Calculate the corporation tax due using the current year’s tax rate, which as of 2023, is 25% for profits over £250,000 and 19% for profits under this threshold.
4. Submit the corporation tax return (CT600) online via the HMRC portal before the filing deadline, typically 12 months after the end of the accounting period.
5. Pay the corporation tax owed by the deadline, usually 9 months and 1 day after the end of the accounting period.

Comparison of UK Corporate Tax Rates to Other Countries

Understanding the relative scale of the UK’s corporate tax rates compared to global counterparts is essential for strategic business planning. It provides insights into the competitive positioning of the UK as a business hub.By examining corporate tax rates, expat entrepreneurs can evaluate the financial implications of operating in different jurisdictions:

Country	Corporate Tax Rate
United Kingdom	19% 25%
United States	21%
Germany	29.9%
Ireland	12.5%
France	25%

The UK’s corporate tax rates are competitive within the European context, offering a flexible framework for businesses to flourish.

This comparative analysis aids expat entrepreneurs in making informed decisions about where to establish or expand their operations, ensuring alignment with their financial and strategic goals.

Double Taxation Agreements

Double taxation agreements (DTAs) play a vital role in international business, particularly for expatriates working in the United Kingdom. These agreements are designed to protect individuals and businesses from being taxed twice on the same income by both the UK and their home country.

By understanding how these treaties function, expats can maximize their tax efficiencies and avoid unnecessary financial burdens.A double taxation agreement is a treaty between two countries that ensures tax paid in one of the countries is accounted for in the other.

This mitigates the risk of being taxed by two jurisdictions on the same income. DTAs are crucial for expats as they provide a framework to alleviate the complexities of international taxation.

Countries with Double Taxation Agreements with the UK

The UK has established double taxation agreements with numerous countries to facilitate international trade and investment. These agreements help define the tax obligations of individuals and businesses operating between the UK and the partner country, often covering income tax, corporation tax, and capital gains tax.

• United States:The US-UK tax treaty aims to prevent double taxation and fiscal evasion, providing guidelines on where income from different sources should be taxed.
• Germany:The agreement between the UK and Germany addresses the allocation of taxing rights and promotes economic cooperation by eliminating tax barriers.
• Australia:This DTA covers taxes on income, assisting in the smooth operation of businesses and the mobility of skilled professionals between the two nations.
• India:A comprehensive agreement that addresses issues related to residency, tax credits, and the exchange of information to prevent tax evasion.

Claiming Relief Under a Double Taxation Agreement

To benefit from a DTA, expatriates must actively claim relief, which typically involves a specific application process. This ensures that they are not unduly taxed and can take advantage of the respective treaty’s provisions.Relief can generally be claimed in the following ways:

1. Residence Status:Determine your tax residency status in both countries. This is crucial as it affects eligibility for treaty benefits.
2. Filling Out Forms:Most treaties require individuals to fill out specific forms to apply for relief. In the UK, this often involves the HMRC forms such as the DT Individualform.
3. Providing Proof:Documentation such as tax residency certificates or proof of income may be needed to substantiate claims under the treaty.
4. Seeking Professional Advice:Consulting with a tax professional can ensure the correct application of treaty provisions, which can vary significantly between agreements.

“Understanding and utilizing double taxation agreements is key to financial planning and tax efficiency for expatriates navigating the complexities of cross-border taxation.”

Capital Gains Tax

Capital Gains Tax (CGT) is a tax on the profit when you sell (or ‘dispose of’) something (an ‘asset’) that’s increased in value. It’s the gain you make that’s taxed, not the amount of money you receive. For expats doing business in the UK, understanding the intricacies of CGT is crucial, especially considering the cross-border nature of their assets and financial dealings.

Expats may have unique liabilities owing to differing tax treaties and residency rules that can affect how CGT is applied. Understanding these can help in strategic planning and minimizing tax burdens.

Capital Gains Tax Liabilities for Expats

Expats residing in the UK need to be aware of their tax liabilities concerning capital gains. The UK’s treatment of CGT for expats depends significantly on their tax residence status. Expats may be liable if they are considered UK residents for tax purposes, regardless of whether the asset in question is in the UK or abroad.

• UK Residents: Typically, UK residents are liable to pay CGT on worldwide gains. It’s crucial for expats to determine their residency status to understand their liabilities accurately.
• Non-Residents: Generally, non-residents are not liable for CGT on assets outside the UK. However, they may be subject to CGT on UK property and land.
• Temporary Non-Residency: There are specific rules for those who have been non-resident for less than five tax years before returning, where gains may be taxable upon return.

Methods for Calculating Capital Gains Tax

Calculating CGT involves determining the gain made from the sale or disposal of an asset. The calculation requires accurate records of the purchase and sale transactions.

Capital Gain = Proceeds from Sale

• Cost of Acquisition
• Allowable Expenses

• Proceeds from Sale: The total amount received from selling the asset.
• Cost of Acquisition: The original purchase price, including any associated purchase costs.
• Allowable Expenses: These might include improvements made to the asset and the costs involved in selling it.

Once the gain is calculated, it must be reported in the tax return. The UK has a tax-free CGT allowance each year, and only gains above this threshold are taxed.

Exemptions and Reliefs Available for Expats

There are various exemptions and reliefs that expats might leverage to reduce CGT liabilities. These can vary based on individual circumstances and residency status.

• Annual Exempt Amount: Each taxpayer has an annual exempt amount, which is not subject to CGT. This can significantly reduce the tax burden if gains are within this threshold.
• Private Residence Relief: If the asset is a primary residence, expats may be eligible for relief, reducing the CGT owed.
• Double Taxation Relief: Through Double Taxation Agreements, expats may avoid being taxed twice on the same gain. It’s essential to check specific agreements between the UK and the expat’s home country.

Understanding and applying these exemptions and reliefs can significantly impact the net amount of tax expats owe, making it vital for them to consult with tax professionals or advisors familiar with international tax law.

Inheritance Tax Considerations

In the United Kingdom, inheritance tax (IHT) is a crucial consideration for expatriates who have assets within the country. This tax is levied on the estate of a deceased person, encompassing property, money, and possessions. Understanding how inheritance tax affects expats is essential for effective financial planning and asset protection.Inheritance tax rules in the UK apply based on domicile status, which determines the tax implications for expats.

The current standard rate of inheritance tax is 40%, applied to estates exceeding the threshold, commonly known as the ‘nil-rate band’, which is £325,000 for the 2023/2024 tax year.

Strategies for Mitigating Inheritance Tax Liabilities

There are several strategies that expats can employ to minimize inheritance tax liabilities. Utilizing these approaches can help protect and preserve wealth for future generations.

• Gift Assets: Transferring assets as gifts during the lifetime can significantly reduce the value of an estate subject to IHT. Gifts made more than seven years before death are typically exempt from IHT.
• Use of Trusts: Setting up trusts can help control how assets are distributed and may provide tax benefits. Trusts can prevent the entire estate from being subject to inheritance tax at once.
• Life Insurance: Taking out a life insurance policy that covers potential inheritance tax liabilities ensures that heirs are not burdened with tax payments.
• Spousal Transfers: Transfers of assets to a spouse or civil partner are generally exempt from inheritance tax, making this a strategic option to consider.

Implications of Domicile Status on Inheritance Tax

Domicile status is a critical factor in determining how inheritance tax applies to expats. It dictates the extent of tax responsibilities and affects planning decisions.

• UK Domicile: Individuals domiciled in the UK are subject to inheritance tax on their worldwide assets. This full scope of taxation makes domicile status a significant consideration for expats.
• Non-Domicile Status: Expats considered non-domiciled in the UK are liable for inheritance tax only on their UK assets. However, long-standing residents may be deemed domiciled for tax purposes after a 15-year presence in the UK.
• Domicile of Origin and Choice: The domicile of origin is typically the country of birth, while domicile of choice is established by residing in another country with the intention to remain permanently. Changes in domicile can have profound tax implications.

Domicile status profoundly influences how inheritance tax applies to expats, highlighting the need for strategic planning to manage tax liabilities effectively.

Implementing informed financial strategies and understanding domicile implications can effectively mitigate the impact of inheritance tax for expats in the UK.

Compliance and Reporting Obligations

Navigating tax compliance and reporting obligations can be a daunting task for expats doing business in the UK. Ensuring that all tax-related obligations are met is crucial to avoid penalties and maintain good standing with HM Revenue and Customs (HMRC).

This section will guide you through the key compliance and reporting deadlines, potential penalties for non-compliance, and summarize the various reports along with their due dates.

Key Compliance and Reporting Deadlines for Expats

Understanding and adhering to the UK’s tax deadlines is vital for expats to ensure compliance. Missing these deadlines can result in significant financial penalties, so it is important to be aware of the following key dates:

• Self-Assessment Tax Return: Due by January 31st each year for the prior tax year.
• VAT Return: Typically due one month and seven days after the end of your VAT accounting period.
• Corporation Tax Return: Due within 12 months of the end of the accounting period.
• National Insurance Contributions: Class 1 NICs are due monthly or quarterly, while Class 2 and Class 4 NICs are typically paid via self-assessment.

Penalties for Non-Compliance with UK Tax Laws

Failure to comply with UK tax laws can result in severe financial penalties. These sanctions are designed to encourage compliance and ensure the timely and accurate reporting of tax obligations. Key penalties include:

• Late Filing Penalty: A fixed penalty of £100 for missing the self-assessment tax return deadline, with additional penalties if more time elapses.
• Late Payment Penalty: Interest charged on overdue tax payments, along with additional penalties if the payment is more than 30 days late.
• VAT and Corporation Tax Penalties: Penalties vary based on the severity and frequency of non-compliance, and can include surcharges and interest on late payments.

Summary of Various Reports and Their Due Dates

For ease of reference, the following table summarizes the key reports that expats need to file, along with their respective due dates:

Report Type	Due Date	Notes
Self-Assessment Tax Return	January 31st	For the previous tax year
VAT Return	1 month and 7 days post-accounting period	Ensure registration if taxable turnover exceeds £85,000
Corporation Tax Return	12 months after accounting period	Typically April or December for most companies
National Insurance Contributions	Varies	Depends on class of NICs

“It’s better to prevent tax penalties by staying informed of your reporting obligations and adhering to all deadlines set by HMRC.”

By understanding these compliance and reporting obligations, expats can ensure that they remain in good standing with UK tax authorities, avoiding unnecessary penalties and fostering a smooth business operation in the UK.

Professional Advice and Resources

Navigating the intricacies of the UK tax system as an expat can be a challenging endeavor. Understanding where to seek professional guidance is pivotal to ensuring compliance and optimizing your financial obligations. Despite the complexity, there are ample resources and professionals who can provide invaluable assistance.Hiring a tax advisor who is well-versed in expat taxation can offer several advantages.

They help demystify tax laws, optimize tax positions, and mitigate the risk of non-compliance. In addition, numerous government resources are available to assist expats in understanding their tax responsibilities.

Hiring a Tax Advisor for Expat Taxation

Engaging a tax advisor familiar with expat taxation can provide substantial benefits. A specialized advisor offers insights tailored to your unique situation, ensuring both compliance and efficiency.

• Expertise in International Tax Law: Tax advisors with knowledge of expat tax regulations can navigate complex international tax laws, ensuring you make informed financial decisions.
• Maximizing Tax Efficiency: Advisors can identify deductions, credits, and strategic planning opportunities to minimize your tax liabilities.
• Compliance Assurance: Professionals ensure timely and accurate tax filings, reducing the risk of penalties and audits.
• Personalized Advice: Individual circumstances vary, and a tailored approach ensures that your specific needs and obligations are effectively met.

Government Resources for Expats

The UK government provides several resources to assist expats in understanding and meeting their tax obligations. Utilizing these resources can enhance your understanding and compliance.

• HM Revenue & Customs (HMRC) Website: Offers comprehensive information on tax requirements, forms, and guidance notes specifically for expats.
• HMRC Expat Helpline: A dedicated helpline providing direct support for expatriates with queries about their tax obligations.
• Online Tax Calculation Tools: HMRC provides tools to estimate tax liabilities, helping you plan and manage your finances effectively.
• Publications and Guides: Various government-issued guides and publications detail UK tax obligations, including specific guidance for expats.

“Taxation is the price which civilized communities pay for the opportunity of remaining civilized.” – Albert Bushnell Hart

Engaging with these resources and professionals ensures that expats can confidently manage their tax responsibilities while focusing on their business ventures in the UK.

Last Point

In conclusion, the tax landscape for expats doing business in the United Kingdom is a multifaceted domain that demands attention and understanding. From income tax specifics and VAT requirements to the strategic use of double taxation treaties, every aspect contributes to a comprehensive financial strategy.

By staying informed and seeking expert guidance, expat entrepreneurs can navigate the UK’s tax system with confidence, ensuring compliance and optimizing their business potential in this vibrant economic environment.

Clarifying Questions

What is the tax year in the UK?

The UK tax year runs from April 6th to April 5th the following year. Understanding this is crucial for filing and compliance purposes.

Are there personal allowances available for expats in the UK?

Yes, expats may be eligible for personal allowances, which reduce the amount of taxable income. However, eligibility can depend on residency status and other criteria.

How are double taxation agreements beneficial to expats?

Double taxation agreements prevent individuals from being taxed twice on the same income in two different countries. They provide relief through tax credits or exemptions, ensuring expats are not unfairly penalized.

What are the VAT registration thresholds for expat-owned businesses?

The VAT registration threshold in the UK is currently £85,000 in taxable turnover per year. Businesses exceeding this amount must register for VAT.

How does domicile status affect inheritance tax for expats?

Domicile status can significantly impact inheritance tax obligations. Individuals domiciled in the UK may have different tax liabilities compared to non-domiciled individuals, affecting their estate planning strategies.