UK tax advice for ultra high net worth families

Wealthy families rarely have a simple tax position. The wealth is held in several forms: a family business, a property portfolio, investments, pensions, perhaps trusts that were set up a generation ago. The family may live in more than one country, and the next generation may have settled somewhere else again.

ASWATAX advises ultra high net worth families on the UK side of that picture. We work quietly, we explain the tax plainly, and we work alongside your family office, private bank and lawyers.

Who this is for

• Families with substantial wealth held across business, property, investments and trusts.
• Internationally mobile families: people moving to or from the UK, and families based overseas with UK assets or UK-resident members.
• Founders and owners of larger private groups thinking about the next generation.
• Trustees and family offices responsible for several generations and several entities.
• Advisers acting for a family of this kind, who want a specialist UK tax team alongside them.

The questions we are asked

• Who is in the UK inheritance tax net? Which family members are long-term UK residents, and for how long after leaving?
• What do the 2026 and 2027 reforms mean for us? The Business Relief cap, and pensions joining the estate.
• How should we hold our wealth? Personally, through a company, a Family Investment Company, a trust, or a combination.
• How do we pass on a family business? Without forcing a sale to pay the tax.
• Do our existing trusts and structures still work? Many were designed for rules that have changed.
• What happens when someone moves? The date can change the result materially.

What matters most now

Inheritance tax follows long-term residence

Inheritance tax has been residence-based since 6 April 2025. A person who has been UK resident in at least 10 of the previous 20 tax years is a long-term resident, and their worldwide estate is within UK inheritance tax at 40%. After leaving, a tail of between 3 and 10 years applies, depending on the length of residence. Domicile is no longer the test. For an internationally mobile family, that makes arrival and departure dates a planning question. See International Inheritance Tax and our UK Residency Checker.

Business Relief and large trading groups

From 6 April 2026, 100% Business Relief is limited to £2.5m of qualifying business and agricultural property per person, with 50% relief above that. Unused allowance can pass to a spouse or civil partner. A family with a trading group worth many times the cap needs to know how much of the value is now exposed, who holds it, and what can be done in time. See Business Relief changes 2026.

Pensions in the estate from April 2027

From 6 April 2027, most unused pension funds join the estate for inheritance tax. For many wealthy families, this is the biggest change to plan for. It affects which assets to draw on first, how pensions, wills and nominations fit together, and whether lifetime gifts or trusts should come into the plan. See pensions in your estate from April 2027.

Trusts and Family Investment Companies

Trusts can move value out of the estate quickly but carry entry, ten-yearly and exit charges. A Family Investment Company lets the founder keep control while future growth passes to the next generation, and it has its own tax features, including corporation tax at 25% on investment profit. Many families use both. See Trusts and Estates, Family Investment Company and our comparison of trusts and Family Investment Companies.

Property and business interests

Family wealth is often tied up in property and an operating business. We look at how each is held, whether trading status is protected, whether a reorganisation would help the next generation, and how to avoid a tax bill that forces a sale. For larger groups, see Complex Group Reorganisations.

How we work

1. A confidential first conversation. We learn about the family, the assets and the question. If you prefer, we start with a hypothetical.
2. Mapping. We build a clear picture of who is resident where, what is held where and in what form, and what the UK exposure is for each person.
3. The step plan. We compare the routes and we design the step plan, in writing, with the reasoning and the trade-offs, and we say plainly when a simpler step is better.
4. Coordination. We work with your family office, private bank, lawyers and overseas advisers so that the step plan we design works end to end.
5. Implementation. We prepare HMRC clearances and applications where they help, and support the legal documents.
6. Review. Rules change, and so do families. We stay available as things develop.

Every plan is reviewed by a Chartered Tax Adviser, and we reply the same working day.

Working alongside your other advisers

• Family offices. We act as a specialist adviser to the office and route our work through you. See Family Offices.
• Private banks and wealth managers. We provide the tax analysis behind an investment or structuring decision, in a form you can share with the client. We do not manage investments or offer regulated products.
• Law firms. We say what the documents must achieve for tax, and review drafts before they are signed. Charity law, trust law and overseas law advice stay with your lawyers.
• Overseas advisers. We coordinate, so that fixing the position in one country does not damage it in another.

Proof

We have advised 300+ clients, helped save an estimated £100m+ of inheritance tax for clients, set up 50+ Family Investment Companies and obtained 100% of the HMRC clearances we have applied for, across 100+ applications. We are Rated 5.0 on Google.

These case studies are anonymised. Each depends on its own facts, and past outcomes do not guarantee future ones.

• Cross-border inheritance tax planning: a forgotten treaty and a £1.6m tax bill. A couple with a combined estate of around £7.5m across the UK and India.
• A £4m, 18-property portfolio incorporated into a blended Family Investment Company. Addressing inheritance tax and succession.
• An inheritance tax review and trust wind-up. A £3m estate and two 1990s discretionary trusts that no longer served their purpose.
• The foreign income and gains regime. An entrepreneur moving from Dubai to London in 2025 with overseas property, shares and a consultancy business.

Confidentiality

We keep all family information confidential and restrict it to those who need it. We keep each family's matters separate, communicate through the channel the family or its office chooses, and process personal data under UK GDPR.

Why ASWATAX

We are a small, specialist firm of Chartered Tax Advisers. You are not passed between departments, and the people you meet at the start are the people doing the work. We start from what the family wants to achieve and work back to the structure.

Talk to us

Most of our work for wealthy families comes by introduction from a family office, bank or law firm, and you are equally welcome to contact us directly. Arrange a confidential first conversation, or write to taxadvisory@aswatax.co.uk.