Vectigalis TAX

Vectigalis TAX Specialist UK and international tax advisory for individuals, entrepreneurs and businesses.

Vectigalis Tax provides practical, technically robust and HMRC-defendable tax solutions, with a focus on cross-border matters and structuring

02/06/2026

Do you own more than one company, or have an old company that is no longer trading?

Many business owners do not realise that a dormant company, an investment company, a property company, or even a company owned by a family member can sometimes affect the corporation tax paid by their main business.

In our latest article, we explain in plain English how these rules work and why a company you have almost forgotten about could increase your tax bill.

Read the article here:

https://vectigalistax.co.uk/the-company-you-forgot-about-how-one-overlooked-shareholding-can-increase-your-corporation-tax-rate/

For a practical review of your company structure, contact Vectigalis TAX

Website: www.vectigalistax.co.uk
Email: [email protected]

Specialist UK and international tax advisory for individuals, entrepreneurs and businesses. Vectigalis Tax provides practical, technically robust and HMRC-defendable tax solutions, with a focus on cross-border matters and structuring

Many people who moved to the UK years ago still believe one thing:“I am not British, so my foreign assets should not be ...
29/05/2026

Many people who moved to the UK years ago still believe one thing:

“I am not British, so my foreign assets should not be caught by UK Inheritance Tax.”

That assumption may now be dangerously wrong.

From 6 April 2025, the UK Inheritance Tax rules changed significantly. The old domicile-based system has been replaced by a new residence-based approach.

In simple terms, if you have lived in the UK for long enough, your worldwide estate may fall within the UK Inheritance Tax net.

That may include:

your home abroad,
foreign bank accounts,
investment portfolios,
family assets,
shares in overseas companies,
trusts or succession structures,
and assets inherited outside the UK.

The part many people miss is this:

Leaving the UK does not necessarily end the UK Inheritance Tax exposure immediately.

Depending on your UK residence history, the exposure may continue for several years after you leave — in some cases up to 10 tax years.

This matters especially for internationally mobile families: Italians, Europeans and other foreign nationals who have lived in the UK for many years, built a life here, but still have assets and family wealth abroad.

The question is no longer simply:

“Where were you born?”

The better question is:

How many UK tax years have you accumulated — and what does that mean for your family estate?

I have written a plain-English article on this important change and why families with cross-border assets should review their position before the issue becomes a problem for the next generation.

You can read it here:

https://vectigalistax.co.uk/leaving-the-uk-your-worldwide-estate-may-still-be-within-uk-inheritance-tax

At Vectigalis Tax, we advise internationally mobile individuals, families and entrepreneurs on UK and international tax matters, including Inheritance Tax, residence, foreign assets, trusts and succession planning.

If this may affect you — or someone you know — please do not leave it too late.

For a confidential consultation:

[email protected]

UK tax residence mistakes can be expensive.For internationally mobile individuals, a few additional UK days can change t...
26/05/2026

UK tax residence mistakes can be expensive.

For internationally mobile individuals, a few additional UK days can change the tax outcome completely — especially where dividends, capital gains, offshore assets or family wealth are involved.

The Court of Appeal decision in *A Taxpayer v HMRC* shows that serious family circumstances may, in limited cases, be relevant when applying the “exceptional circumstances” rule under the Statutory Residence Test.

However, this is not an invitation to treat UK day limits casually. The real lesson is evidence: why the individual was in the UK, why they could not leave, when the circumstances changed, and whether the position can be defended years later.

I have written a short article on the case and its practical relevance for internationally mobile individuals.

Web: https://vectigalistax.co.uk/uk-tax-residence-and-exceptional-circumstances-what-a-taxpayer-v-hmrc-means-for-international-individuals/

Mail: [email protected]
Website: www.vectigalistax.co.uk

Most early-stage founders do not struggle because the idea is weak.They struggle because investors like the idea — but s...
18/05/2026

Most early-stage founders do not struggle because the idea is weak.

They struggle because investors like the idea — but still hesitate.

That is exactly where SEIS can change the conversation.

For qualifying investors, SEIS can offer 50% Income Tax relief, plus potential Capital Gains Tax advantages where the conditions are met. For founders, it can make an early funding round look more credible, more structured, and more investable.

But SEIS is not just a line to add to a pitch deck. If the company, investor, shares, timing or use of funds are wrong, the relief can be lost.

I have written a clear guide on why SEIS matters, where founders often make mistakes, and why it should be considered before shares are issued — not afterwards.

Link: https://vectigalistax.co.uk/seis-why-it-can-make-investors-say-yes-earlier/

For tailored SEIS and early-stage investment tax advice, contact ' TAX:

www.vectigalistax.co.uk
[email protected]

Partner-led UK and international tax advice on cross-border structuring, corporate tax, personal tax, transfer pricing, trusts, IHT, SDLT-related matters and HMRC disclosures.

A joint bank account in Italy.A family property with usufrutto.A share of nuda proprietà.Rental income paid abroad.An in...
14/05/2026

A joint bank account in Italy.
A family property with usufrutto.
A share of nuda proprietà.
Rental income paid abroad.
An inherited property sold overseas.

For many UK residents, offshore tax problems do not begin with tax avoidance. They begin with family arrangements that were never reviewed from a UK tax perspective.

HMRC now receives increasing amounts of international financial information. If foreign income, property, bank accounts or assets have not been correctly reported, the Worldwide Disclosure Facility may be the route to regularise the position.

Link to the article: https://vectigalistax.co.uk/hmrc-worldwide-disclosure-facility/

At Vectigalis TAXVectigalis TAX we advise on complex offshore disclosure cases involving foreign property, joint accounts, inherited assets, Italian usufrutto, nuda proprietà and cross-border tax issues.

For confidential advice, contact:

[email protected]

Partner-led UK and international tax advice on cross-border structuring, corporate tax, personal tax, transfer pricing, trusts, IHT, SDLT-related matters and HMRC disclosures.

Inheritance tax issues rarely become expensive overnight. More often, they develop quietly over years through delayed de...
11/05/2026

Inheritance tax issues rarely become expensive overnight. More often, they develop quietly over years through delayed decisions, outdated structures, and assumptions that are never revisited.

I have explored some of the most common areas where families encounter avoidable exposure, particularly around succession,

Business Relief, gifting, and international considerations.

Website: https://vectigalistax.co.uk/the-inheritance-tax-conversation-families-delay-too-long-until-it-is-expensive-to-fix/

If this is a conversation relevant to your family or clients, I would be very pleased to connect and exchange perspectives.

Mail: [email protected]

We are STEP members - https://www.step.org/

In cross-border groups, management charges often look like harmless year-end accounting entries.A UK company recharges s...
08/05/2026

In cross-border groups, management charges often look like harmless year-end accounting entries.

A UK company recharges strategic support to an Italian subsidiary.
A UAE entity invoices for business development.

Costs are allocated, invoices are raised, and everyone assumes the treatment is tax-neutral.

But that is not how tax authorities look at it.

For UK–Italy–UAE structures, intra-group cost recharges can quickly become a transfer pricing issue if they are not supported by substance, benefit, arm’s length pricing and proper documentation.

The real question is not whether the cost was incurred.

The real question is whether an independent business would have paid for the same service, on the same terms, in the same circumstances.

In my latest article for Vectigalis TAX, I look at when management charges stop being routine recharges and start becoming a tax risk — particularly for internationally mobile groups operating between the UK, Italy and the UAE.

Website: https://vectigalistax.co.uk/management-charges-between-uk-italy-and-uae-when-cost-recharges-become-a-transfer-pricing-problem/

Mail: [email protected]

A practical story about group recharges, tax risk and the importance of getting the sequencing right A UK company, an […]

A management buy-out often looks simple at the beginning.The founder wants to exit.The management team wants to buy.The ...
05/05/2026

A management buy-out often looks simple at the beginning.

The founder wants to exit.
The management team wants to buy.
The business already has continuity.
The lender likes the numbers.

Then the cross-border details appear.

One shareholder is overseas.
The seller wants loan notes.
A key director has moved abroad.
The management team wants equity.
The acquisition debt has to be serviced after tax.

At that point, an MBO is no longer just a commercial transaction. It becomes a tax structure.

In my latest article for Vectigalis Tax, I look at the main tax pressure points in cross-border management buy-outs, including seller taxation, management equity, acquisition debt, withholding tax, stamp duty, treaty issues and overseas shareholders or directors.

The central point is simple:

A successful MBO is not the one with the most complicated structure.

It is the one where the commercial deal, the legal documents and the tax analysis all tell the same story.

Read the article here:
https://vectigalistax.co.uk/cross-border-management-buy-outs-the-tax-pressure-points-founders-and-management-teams-must-understand/

A management buy-out can be an elegant succession strategy, but cross-border sellers, managers, lenders and loan notes create complex tax […]

Foreign assets are not always outside the UK Inheritance Tax net.For many internationally mobile families, wealth is rar...
29/04/2026

Foreign assets are not always outside the UK Inheritance Tax net.

For many internationally mobile families, wealth is rarely held in one jurisdiction.

It may include a family home in Italy, an overseas investment portfolio, a foreign bank account, shares in a family company, a trust structure, or pension wealth accumulated over decades.

The mistake is assuming that because an asset is abroad, it is automatically outside UK tax exposure.

The UK’s move towards a long-term residence basis for Inheritance Tax has materially changed the planning landscape.

For individuals who have lived in the UK for many years, overseas assets may now require a much closer review.

This is particularly relevant for UK-resident individuals with Italian, European or international assets, families with cross-border estates, and entrepreneurs whose wealth is held across companies, jurisdictions and generations.

In my latest article for Vectigalis Tax, I look at why cross-border IHT planning should not be left until succession becomes urgent, and why families need one coordinated estate plan rather than separate advice in each country.

Read the full article at: https://vectigalistax.co.uk/the-inheritance-tax-bill-hiding-in-your-foreign-assets/

For a confidential review: [email protected]

A demerger is a corporate divorce.And like any divorce, it can be orderly, strategic and well planned.Or it can become e...
27/04/2026

A demerger is a corporate divorce.

And like any divorce, it can be orderly, strategic and well planned.

Or it can become expensive, messy and tax inefficient.

In a cross-border context, separating a group does not simply mean moving shares from one company to another.

It means separating value, risk, IP, contracts, debt, people, decision-making functions and tax responsibilities across different jurisdictions.

This is where many businesses get it wrong.

They look at the legal structure.

But they do not see the tax history sitting behind it.

A cross-border demerger should never be improvised.

It should be designed.

In the article below, I explain why, in a cross-border context, that divorce must be carefully designed — not improvised

Link: https://vectigalistax.co.uk/the-cross-border-demerger-when-a-business-needs-a-divorce-before-it-can-grow/

Mail: [email protected]

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