Foreign jurisdictions

This subtopic contains information on a range of foreign jurisdictions which the private client practitioner is likely to encounter when advising internationally mobile clients on their tax and estate planning. Topics covered include personal taxation, trusts, companies, foundations, succession laws and regulatory regimes. We shall continue to add content on these and other jurisdictions, depending on the needs of our clients.

The following subtopics may also be useful:

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International private client—general principles—overview
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Cross-border planning (and private client)—overview
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Foundations—overview
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Offshore companies (and private client)—overview
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Offshore trusts—general principles—overview
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Private client and private international law—overview

For information on the execution of contracts and deeds in various jurisdictions, see Practice Notes: Execution of deeds—jurisdictional guide, Execution of contracts—jurisdictional guide and E-signatures—jurisdictional guide.

Information on Scotland can be found in several subtopics in the Private Client in Scotland topic.

Bermuda

Practice Notes

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Bermuda trusts
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Economic substance legislation in the Crown Dependencies and Overseas Territories—summary

News Analysis

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Brexit and the Overseas Territories—Bermuda
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Privy

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Latest Private Client News

High Court decides that Danish Tax Authority failed to prove inducement by misrepresentation (SKAT v Solo Capital Partner)

Tax analysis: The High Court dismissed the fraud claims brought by the Danish Tax Authority, Skatteforvaltningen (SKAT) arising out of the cum-ex trading scandal. SKAT alleged that it had been wrongfully induced to pay claims for repayment of Danish withholding tax by misrepresentations made in documents submitted to it. However, the court held that while the refund claims were invalid, SKAT had failed to show that it had been induced to make the payments in reliance on false representations. The documents submitted to SKAT did not contain the majority of the representations alleged by SKAT and the process by which the claims were approved was so mechanistic and unthinking that no regard was had to the alleged misrepresentations. While the court found that many of the defendants were dishonest at the time and were untrustworthy witnesses at trial, this was not sufficient to prove the particular case as pleaded by SKAT. The judgment confirms the importance of factual evidence when establishing claims for misrepresentation Written by Edward Reed (senior advisor), Alice Mason (senior associate) and Victoria Braid (associate) at Macfarlanes LLP.

Private Client weekly highlights—16 October 2025

This week’s edition of Private Client highlights includes: (1) Re AB, a decision concerning the obligation to provide position statements to the public in the COP; (2) HMRC issues policy paper on the Tax Treatment of Cryptoasset Exchange Traded Notes; (3) Ellis v Ellis, a contentious probate case in which the court rejected an argument that it depart from the general rule that costs follow the event; (4) Maile v Maile, in which a claim for proprietary estoppel claim failed because the statements relied on were too vague; (5) EDPS v SRB, which concerned whether pseudonymised data must always be treated as personal data under the GDPR; and (6) the Ministry of Justice announces its intention to reform weddings law following recommendations of the Law Commission.

OSCR launches interactive report on new Scottish charity registrations

The Scottish Charity Regulator (OSCR) has launched a new interactive report showcasing information about new charities recently added to the Scottish Charity Register. The weekly-updated report provides information on each newly registered charity, including its charitable purpose, location, and legal form. It also enables users to view registration trends, figures, and other key information. Through an interactive map linking directly to each charity’s register entry, the tool promotes greater transparency and public confidence in Scotland’s charity sector.

Question of the week: A client has received a gift of funds from his aunt. His brother has received the same amount. The brothers have agreed between themselves to use the funds for her care if she requires it and they have drawn up a Deed to document this. Will the terms of the Deed override their Wills (their Wills leave their respective estates to their wives)?

This Q&A considers whether, if a client has received a gift of funds from his aunt. His brother has received the same amount. The brothers have agreed between themselves to use the funds for her care if she requires it and they have drawn up a Deed to document this. Will the terms of the Deed override their Wills (their Wills leave their respective estates to their wives).