Relocation, Relocation, Relocation: When, How To Prepare For Any Move

Ben Lister and John Sweeney 3 November 2023

Relocation, Relocation, Relocation: When, How To Prepare For Any Move

With higher taxes possibly on the way in the UK and likely to affect HNW individuals and families, the law firm examines the most salient challenges and options.

This news service is running a series of four articles from Taylor Wessing, the law firm, on issues relevant to private clients and their advisors. The editors are pleased to share this content. The editors don’t necessarily endorse all views of guest writers. The usual disclaimers apply. Email

In this second article, the authors are Ben Lister, partner, and John Sweeney, senior associate. 

It is no news to anyone that we are living in times of enormous economic and geopolitical uncertainty. In the space of just a few years we have experienced (among other things) a global pandemic, cost of living crisis, war in Europe and an erupting conflict in the Middle East. Public finances, including those of the UK, are increasingly strained and governments are under pressure to find new revenue sources to replenish their budget deficits. 

In the run up to a new general election here in the UK, which might bring Labour into power for the first time in 13 years, more UK-based individuals are starting to consider moving to more "tax-friendly" jurisdictions. 

We are increasingly receiving enquiries from clients regarding their relocation options. These conversations appear to be driven, at least in part, by a combination of uncertainty in the UK and the fact that other jurisdictions now have very attractive inpatriate tax regimes, such as Italy, Spain, and Greece. But as clients' plans transition from idea to reality what is it that they should be considering?

The process of relocation can be broken down into four main phases: an exploratory phase, in which clients need to consider practicalities and the implications of the move (to ensure that they really do want to proceed); planning (to ensure that the main elements have been properly considered, including taking tax and legal advice in the country they are leaving and the new country they are moving to); the actual move, and the period following the move.    

The exploratory and planning stages are crucial for putting an individual (and their family) in a position to proceed with a relocation knowing that the move will achieve their intended objectives (whether tax or otherwise).  Critical to this planning phase is considering what we see as the three pillars of any proposed relocation project – practicalities, immigration, and tax.

Before uprooting themselves (and their family) and moving to a new jurisdiction, it makes sense to consider some basic questions. Has the individual spent much time there previously? Can they really see themselves living there? Do they like the climate? Can they speak the language? How will any children get on at the schools? Many relocation discussions do not make it past these very initial practicalities. These questions might seem obvious, but we have worked on cases where a family has made a move overseas only to return to the home country on the grounds that the climate was not as expected! 

The fact that the intended new country of residence has an incredibly attractive inpatriate regime will be irrelevant if the client cannot obtain the right to live and work there. Within the European Union, moves between countries are simple for those with an EU passport; but for British clients without an EU passport (following Brexit) or other non-EU passport holders, due consideration will need to be given to the chosen jurisdiction's immigration rules. 

In many jurisdictions, clients can typically obtain some form of investment visa (unlike in the UK which has scrapped its visa-by-investment route, even though other means remain available); but it is important for clients to bear in mind that their chosen jurisdiction's tax and immigration regimes are likely to be separate processes (albeit two that can be managed concurrently).  

Finally, whilst tax is not always the main basis of these discussions, it is fair to say that the vast majority of the enquiries we receive have some form of tax slant. If tax is a driver, clients may need to match their chosen jurisdiction with their specific tax objectives. By way of example, if a client is looking to unwind an international pension plan, Greece may not be a suitable jurisdiction since the UK/Greece Double Tax Treaty does not relieve lump sum payments. 

Likewise, clients should be aware that Italy's lump sum tax regime (in which an individual's tax liability is limited, broadly, to €100,000 ($105,930) per annum) does not necessarily cover gains arising on disposals of “qualified participations” (effectively interests in close companies); albeit there are steps which can be taken to bring these within the scope of the regime. 

What should hopefully be apparent is the fact that any proposed relocation project requires a great deal of forethought. In this respect, clients would be well advised to obtain advice at the earliest opportunity; ideally, at least a year to six months prior to departure.  

Clients should bear in mind that, for UK tax purposes, it may be preferable for their departure to occur just prior to the tax year commencement (i.e., shortly before 5 April).  However, it may also be the case that the tax year in the client's chosen jurisdiction will mirror the calendar year.  This can present planning opportunities, but it often has an impact on the timing of the steps required to become resident in the chosen jurisdiction (and which often include obtaining a tax ruling from the local tax authorities).   

Finally, it should be noted that changes are and have been made to some of the favourable inpatriate tax regimes across Europe.  For example, Portugal has just scrapped its Non-Habitual Resident regime with effect from 2024 and Italy has also made some tweaks to its inpatriate regime targeted at workers – although the separate Italian €100,000 lump sum tax regime referred to earlier remains unchanged. 

Given these changes, the seeming direction of legislative travel (at least on the European continent) and the proximity of the UK general election, clients may wish to consider their options sooner rather than later.    

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