Pre-Arrival planning

From 6 April 2025, the UK is replacing the remittance basis with a new Foreign Income & Gains (FIG) regime. If you’re planning to become UK tax resident — even temporarily — it’s critical to act before arriving, while planning opportunities remain open.

Imperium ensures you land fully prepared to maximise eligibility for the 4-year FIG regime, establishing segregated accounts if necessary, rebase or realise assets tax-free prior to arrival in the UK, or prior to the start of your firth year of residence. If offshore structures are in place, individuals arriving in the UK should consider where restructuring of offshore trusts and companies should be undertaken.

What sets Imperium apart

At Imperium, we combine technical tax expertise with a strategic, forward-looking approach to international wealth structuring. We work closely with clients, advisers, and family offices to ensure offshore assets — including trusts, companies, and portfolios — are structured tax-efficiently ahead of UK residence. We help you assess eligibility for the 4-year FIG exemption and prepare funds for use in the UK without triggering tax. Our team has deep experience navigating s.86/s.87 TCGA, tainting rules, and anti-avoidance provisions. We can review and restructure offshore structure if necessary.

Typical client scenarios

1. International Executive – Long-Term Assignment
   Anna, a US national, is moving to London for 5 years. Imperium:
   • Confirms she qualifies for the FIG regime
   • Guides pre-arrival realisation of capital gains
   • Creates a clean capital structure for tax-free UK access
2. Entrepreneur – Offshore Trust & Company
   Carlos, a Latin American business owner, holds wealth in an offshore trust and BVI company. We:
   • Reorganise structures to protect trust status under UK attribution rules
   • Avoid relevant underlying company exposure
   • Implement clean distribution strategies