Broadly, if the individual remains UK resident, HMRC will tax foreign source income and gains on an arising basis unless the individual is non-domiciled, claims the remittance basis and the funds are not remitted to the UK.
A new job may well go hand in hand with accommodation.
If the leaver decides to buy a property in their new chosen location, care will need to be given to the relevant implications in that jurisdiction.
If the individual remains domiciled in the UK, any property purchased abroad will still fall within the UK IHT net and any future liability should be factored into lifetime planning.
Although it seems Harry and Meghan will retain Frogmore Cottage as their UK residence for the time being, the purchase of a property abroad may well necessitate or trigger the sale of UK property.
Non-residents are still liable to pay CGT on the sale of UK residential property (subject to the availability of main residence relief) and any tax due must be paid within 30 days of the sale.
The acquisition of assets in a country other than the UK is a sensible opportunity to review any existing Will and Power of Attorney and consider what changes may need to be made.
For example, it is possible to have one Will which covers assets in all jurisdictions but there can be advantages to having separate Wills in each relevant jurisdiction.
Domicile is again relevant from a UK succession perspective as the UK looks to the law of the individual’s domicile to determine how moveable assets should pass.
Joined up advice should be taken to ensure that the desired result is achieved in the most tax efficient manner, bearing in mind not only UK IHT but any death taxes in the new jurisdiction.
At the same time, thought should be given to any trusts established while in the UK as relocation of trustees or beneficiaries can have serious tax and administration implications.
With regard to Powers of Attorney, an LPA made in the UK may not be recognised abroad and so it might be necessary to put further protections in place.
Marriage or civil partnerships
Another major life event which may be on the cards following a move abroad is marriage or civil partnerships.
For those seeking to ring-fence certain assets, prenuptial agreements can be useful but it would first be important to understand whether such an agreement would in fact be valid in each relevant jurisdiction.
Also, certain typical provisions in say a US-style prenuptial agreement may be against public policy in another jurisdiction and so care would need to be taken in the drafting to ensure claims in each jurisdiction are properly considered and addressed.
