Boru Consulting

Boru Consulting Trusted partners for cross-border founders. You build the vision. We handle the noise.

The Pre-Exit Year for UK-to-UAE HNWIThe pre-exit year is not a checklist — it's an architecture engineered backwards fro...
17/07/2026

The Pre-Exit Year for UK-to-UAE HNWI

The pre-exit year is not a checklist — it's an architecture engineered backwards from your SRT exit date.

TRF designation, CGT rebasing, the long-term resident IHT tail, UAE 90-day residence, Golden Visa, CMC reconstitution, QFZP substance, and DIFC will all need to be positioned around that single date.

The architecture takes 12 months, not 3-4. Split-year cases need a locked fact pattern. TRF needs a strategy across three years. UAE substance needs 90-180 days. Banking, family relocation, and UK property sales each add months.

Five traps cause most failed exits: vague timing without locked split-year case; delaying TRF to 2027/28 (300bps tax uplift); building UAE substance too late; selling UK property with UK residence still active at midnight; spouse/children staying UK-resident as "school anchors."

Post-exit year one tests the architecture. TRF is filed, rebasing elections made, LTR IHT tail begins, UAE residency is operational, substance file grows quarterly.

Full article on our website — link in profile.

DIFC and ADJD Wills for UK HNWIs After April 2025Since 2023, non-Muslim UAE residents have a federal civil framework for...
15/07/2026

DIFC and ADJD Wills for UK HNWIs After April 2025

Since 2023, non-Muslim UAE residents have a federal civil framework for wills (Federal Decree-Law No. 41 of 2022). There are two main registration routes: DIFC in Dubai and the Abu Dhabi Civil Family Court.

DIFC Wills are common-law style in English. A Full Will can cover worldwide assets. Guardianship is valid only for minors in Dubai or Ras Al Khaimah. Probate is handled by DIFC Courts, usually within weeks.

Abu Dhabi Wills operate under a civil-law system in Arabic and English. Typically lower-cost, they cover Abu Dhabi assets primarily, with federal reach. Over 21,000 civil wills were registered from 2022 to the end of 2025.

Important: A UAE will does not eliminate UK Long-Term Resident IHT on worldwide assets. It does not affect UK SRT exit, does not create UAE tax residency, and does not replace a UK will for UK-situs assets. Two coordinated wills are usually the best architecture.

Without a registered will, the default is 50% to the spouse and 50% equally among children, without gender distinction.

For UK HNWIs, the will is the succession instrument, not the full architecture. It must be coordinated with UK IHT planning, a UK will, and UAE tax residency.

Full article on our website — link in our profile.

The UK Statutory Residence Test: It's About More Than 183 DaysMany still believe that spending fewer than 183 days in th...
14/07/2026

The UK Statutory Residence Test: It's About More Than 183 Days

Many still believe that spending fewer than 183 days in the UK means you're not UK tax resident. That's not true.

The 183-day rule is only one part of the Statutory Residence Test. Your residence can also depend on previous UK residence, accommodation ties, family connections, work days, and how your days are counted.

Common mistakes:
A UK property kept for visits creates an accommodation tie. More than three hours of work in the UK counts as a work-day. Spending over 90 days in the UK in either of the previous two years creates a 90-day tie.

For HNWIs and mobile families, these details matter. Your residence affects income tax, capital gains tax, inheritance tax, and cross-border structures.

The key point: UK tax residence is determined by the Statutory Residence Test and documented facts, not by intention.

At Boru Consulting, we help internationally mobile founders and private clients understand how the SRT applies to their circumstances and plan cross-border movement with confidence.

If you'd like to review your residence position, contact us through our page or send a direct message.

You build the vision. We handle the noise.

Understanding the UAE Golden Visa: Benefits and LimitationsThe UAE Golden Visa grants the right to reside in the UAE, bu...
10/07/2026

Understanding the UAE Golden Visa: Benefits and Limitations

The UAE Golden Visa grants the right to reside in the UAE, but it is essential to note that it does not confer UAE tax residency.

Key benefits of the UAE Golden Visa include:
- A long-term permit (5 or 10 years, renewable),
- No requirement for a UAE national sponsor,
- Freedom to work, study, and sponsor family members,
- Exemption from the 6-month absence rule.

It is crucial to understand that the UAE Golden Visa does not imply UAE tax residence, which requires 90 days + residence permit + permanent place of residence/business, or 183 days of presence.

For those seeking the Golden Visa through property investment, a minimum of AED 2 million based on current DLD valuation is required, and mortgaged and off-plan properties are eligible.

The employment route, however, has been paused since October 2025, with zero approvals in Q2 2026, making the property route the most reliable option.

Read the full article in our Insights blog to learn more — link in our profile.

A UAE Free Zone licence does not automatically mean 0% Corporate Tax.Many businesses assume that setting up in a UAE Fre...
06/07/2026

A UAE Free Zone licence does not automatically mean 0% Corporate Tax.

Many businesses assume that setting up in a UAE Free Zone guarantees the 0% rate.

It doesn't.

To qualify, a company must meet five conditions every tax period to be recognised as a Qualifying Free Zone Person (QFZP).

Here's what every business owner should know:
✔ Meet all five QFZP conditions every year.
✔ Earn Qualifying Income only.
✔ Keep non-qualifying income below the lower of 5% of total revenue or AED 5 million.
✔ Maintain adequate economic substance in the UAE.
✔ Apply transfer pricing correctly and keep supporting documentation.

One mistake can be costly.

If a company fails just one of the QFZP conditions or exceeds the de minimis threshold:
• The 9% Corporate Tax rate applies to all Taxable Income, not just the non-qualifying income.
• The company loses QFZP status for the current tax period and the following four tax periods.

Understanding these rules before they become a problem is essential for protecting the 0% rate.

Read the full article in our Insights section via the link in our bio.

Family Investment Company vs Trust for the UK HNWI: architectures that survived 2025A Family Investment Company (FIC) is...
03/07/2026

Family Investment Company vs Trust for the UK HNWI: architectures that survived 2025

A Family Investment Company (FIC) is not a trust replacement. It is a different architecture for a different problem.

After Finance Act 2025 and 2026, both instruments are taxed at full UK rates. The question is now which functions each serves, not which one is "better".

Key difference
- A trust gives fiduciary control through independent trustees and discretionary distribution.
- A FIC gives corporate control through voting shares, bespoke Articles, and a board.

Tax reality
A FIC investing mainly in financial assets pays 25% Corporation Tax on profits.
Dividends extracted by shareholders face a second-layer dividend tax up to 39.35%.
Combined, extracted returns can exceed 50%.
Trusts face income and gain attribution to the settlor, plus IHT charges.

Read the full article in our Insights blog on our website — link in our profile.

UAE Individual Tax Residency: the 90-day rule, the 183-day rule, and the treaty gapUAE individual tax residency has thre...
01/07/2026

UAE Individual Tax Residency: the 90-day rule, the 183-day rule, and the treaty gap

UAE individual tax residency has three alternative tests:
- centre of financial and personal interests in the UAE,
- 183 days of physical presence in any rolling 12-month period,
- 90 days of presence with residence permit + employment/business + permanent place of residence.
The 90-day route is the most useful for internationally mobile HNWIs and the most misunderstood.

The treaty gap
Domestic UAE tax residency does not automatically deliver a Tax Residency Certificate (TRC) for treaty purposes.
For treaty-purpose TRCs, the FTA requires 183 days of physical presence, even if domestic residency is established at 90 days.

Golden Visa ≠ tax residency

Holding a UAE residence visa, including the Golden Visa, does not by itself establish UAE tax residency.
The visa is a precondition for the 90-day route only, not a full substitute for the other conditions.

Read the full article in our Insights blog on our website — link in our profile.

The UK Statutory Residence Test: the arithmetic most clients get wrongThe Statutory Residence Test (SRT) is mechanical, ...
29/06/2026

The UK Statutory Residence Test: the arithmetic most clients get wrong

The Statutory Residence Test (SRT) is mechanical, not interpretive.
For HNWIs, small mistakes in day-counts or work patterns can change your UK tax residence and every downstream tax position.

Three key traps
- Day count is by midnight only - a single overnight creates a UK day.
- The ties test recalibrates each year as residence history grows.
- Full-time work abroad fails on subtle work patterns you didn’t realise mattered.

Many clients focus on the headline 183-day rule, but residence can be triggered at far lower day counts under the ties test.

Read the full article in our Insights blog on our website — link in our profile.

Leaving the UK does not end Inheritance Tax exposureFrom 6 April 2025, UK inheritance tax no longer depends on domicile....
26/06/2026

Leaving the UK does not end Inheritance Tax exposure

From 6 April 2025, UK inheritance tax no longer depends on domicile.
An individual is a long-term UK resident, and taxable on worldwide estate, once resident in 10 of the preceding 20 tax years.

Crossing the threshold is the easier half.
Coming out of it is the harder half.

A minimum three-year tail follows every departure.
The tail extends by one year for each additional year of residence beyond 13, up to a ten-year ceiling.

What changed on 6 April 2025

Inheritance tax had been anchored on domicile since the 1984 Act.
The Finance Act 2025 replaced the entire connecting factor with the long-term UK resident concept.

Domicile retains some relevance for succession, wills, and asset location, but it has no further role in the UK IHT charge to tax.

The test is forward-looking at each chargeable event and is not a once-and-for-all determination.

Long-term resident status persists after departure as a graduated tail.
The tail is graduated by reference to the number of years of UK residence at the point of departure.

The floor is three tax years.
The ceiling is ten tax years.

Read the full article in our Insights on our website — link in our profile.

The 5 April 2017 rebasing election: most ex-non-doms will not use it correctlyThe Finance Act 2025 extended the 2017 reb...
25/06/2026

The 5 April 2017 rebasing election: most ex-non-doms will not use it correctly

The Finance Act 2025 extended the 2017 rebasing election to the broader group of former remittance-basis users.

Rebasing sets a 5 April 2017 market value as the base cost on disposal of eligible foreign assets.
The election is per-asset, made on disposal, and irrevocable.
It saves significant CGT in some cases and destroys value in others.

Who qualifies
To make a rebasing election under FA 2025, an individual must:
- be 'subject to' the remittance basis from 6 April 2017 to 5 April 2025,
- be UK-resident in the year of disposal,
- not be UK-domiciled at common law on 30 October 2024 or earlier,
- and hold an eligible foreign asset personally on 5 April 2017.

When not to elect
Rebasing is destructive in four scenarios:
- asset has fallen in value since 5 April 2017,
- asset acquired after that date,
- assets inherited from a non-resident spouse post-2017,
- disposals to a spouse on no-gain-no-loss basis.

Read the full article in our Insights blog on our website — link in our profile.

Address

London

Website

Alerts

Be the first to know and let us send you an email when Boru Consulting posts news and promotions. Your email address will not be used for any other purpose, and you can unsubscribe at any time.

Shortcuts

Share

Category