Brief Advice for Hong Kong Migrants Moving to the UK (New UK Tax Regime)

1. UK Inheritance Tax (IHT) Risk

• The UK levies 40% inheritance tax on worldwide assets once you are deemed domiciled (after 15 years, or sooner in some cases).
• Hong Kong has no estate duty — so this is the biggest new tax risk for migrants.
• Planning Tip: Settle an Excluded Property Trust (EPT) before becoming UK resident. This keeps HK/offshore assets outside the UK IHT net.

2. Income Tax & Capital Gains Tax (CGT)

• UK taxes residents on worldwide income and gains (unless protected by non-dom rules).
• From April 2025, the “non-dom regime” is being tightened — benefits will be limited.
• Planning Tip: Consider “pre-entry cleansing” — rebasing portfolios, realising gains, and restructuring holdings before moving.

3. Double Will Structure

• Keep a Hong Kong will for HK assets and a UK will for UK assets.
• This avoids conflicts and speeds up probate.

4. Banking & Compliance

• Any trust or offshore structure may trigger UK Trust Registration Service (TRS) if it holds UK assets or opens UK bank accounts.
• Banks must comply with CRS/FATCA reporting, so beneficial ownership cannot remain secret.

5. Roadmap for Migrants

1. Before Moving – Settle EPT, restructure investments, prepare dual wills.
2. At Arrival – Register with HMRC, consider remittance basis (if still applicable).
3. First 5 Years – Annual compliance reviews; trust/trustee reporting.
4. Year 6+ – Monitor domicile status; refresh estate plan.

✅ Key Takeaway:
Moving to the UK under BN(O) brings exposure to a completely different tax regime. Early trust and estate planning before migration is critical to preserve wealth and avoid the 40% IHT trap.