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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Private Client—Bermuda—Q&A guide
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Economic

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Latest Private Client News

Double taxation tiebreakers—meaning of POEM (Haworth v HMRC)

Private Client analysis: The Court of Appeal has found that the test of ‘Place of Effective Management’ (POEM) in a double taxation treaty (DTT) is not the same as the central management and control (CMC) test for company residence. POEM is frequently used in DTTs as a tiebreaker to determine in which of two contracting states a person other than an individual (eg a company or trust) is resident for the purposes of the DTT. There is limited case law, either in the UK or internationally, on how the test should be applied. The court rejected the appellants’ submissions that a tribunal determining POEM should adopt a test derived from the CMC case of Wood v Holden, with the focus upon whether the decision-making functions of the constitutional organs have been usurped or dictated to. It found no support for this submission in authorities or materials admissible to interpret the DTT. Written by Christopher Stone KC, barrister at Devereux Chambers.

Government responds to 2024 MLR consultation

HM Treasury (HMT) has published the government’s response to the 2024 consultation on the Money Laundering Regulations (MLRs), detailing changes that will be made to the MLRs to close loopholes, clarify requirements and ensure customer due diligence is targeted at high-risk activity. A draft Statutory Instrument will be published for technical feedback in due course, and laid before Parliament later in 2025 if parliamentary time allows. The government says other issues will be addressed through guidance, in collaboration with supervisors, to ensure a consistent, risk-based approach.

Private Client weekly highlights—17 July 2025

This week’s edition of Private Client highlights includes: (1) Legislation Day is on 21 July 2025; (2) the ICAEW has launched a consultation on proposed probate registration fees for 2026; (3) analysis of Rogers v Wills, a rare example of the court finding a contract for care existed between family members; (4) the Investing and Saving Alliance proposes alternative approaches to the government’s pension IHT reforms; (5) Marcus v Marcus in which the appeal court upheld the decision that the word ‘children’ included a non-biological son; and (6) analysis of Mobile Telecommunications Company KSCP v HRH Prince Hussam Bin Saud Bin Abdulaziz Al Saud in which the court rules on the meaning of ‘place of residence’ in a bankruptcy jurisdiction appeal.

Question of the week: If an executed deed of appointment under a trust is missing the name of the appointee (due to a clerical error) would the courts generally admit evidence of the intention of the appointors as an aid to construction of the document? Or would rectification be required?

This Q&A considers whether, if an executed deed of appointment under a trust is missing the name of the appointee (due to a clerical error) would the courts generally admit evidence of the intention of the appointors as an aid to construction of the document, or would rectification be required.