Ben Keith writes for Family Office Magazine: The Price of UK Uncertainty. The article was first published in Family Office Magazine Autumn 2026 Issue.
High net worth families are increasingly rejecting London as a worthy destination to relocate – largely for tax and immigration purposes – opting instead for Milan or Cyprus.
The trickiest part for family offices when it comes to helping families relocate is time. Families plan across generations; businesses are built over decades; and children go through schools and universities. Trusts and succession structures are rarely designed around a four-year political cycle. Yet the UK is increasingly asking internationally mobile families to make long term commitments against rules that offer much shorter periods of certainty.
There has been no investor visa since Tier 1 Investor closed in 2022, and money alone does not lead to a visa. An entrepreneur with an endorsed business can apply under Innovator Founder and may reach settlement in three years, while Global Talent covers leaders in academia, the arts and digital technology, with a three year route for some. Everyone else in the family needs a route of their own, usually through employment or family.
Settlement itself is also under review. The government’s proposed Earned Settlement model starts from a 10 year baseline for many migrants, with shorter periods proposed for those making greater economic or social contributions; the consultation closed in February, 200,000 responses later. The final model has yet to enter the Immigration Rules, though the Home Secretary confirmed changes will come this autumn and will apply to people already on routes to settlement. The rules may change by the time this is read, which is the problem in itself: a family can start on one set of terms and find them changed before it reaches the end.
For family offices, this makes long-term commitments harder to price and harder to reverse. A founder can make business decisions around a known tax rate, but it is harder to plan a family’s residence, children’s education and eventual settlement when the conditions attached to immigration status may change halfway through the process.
The tax reforms create a different mismatch. The foreign income and gains (FIG) regime introduced in April 2025 can be attractive: after 10 consecutive tax years of non-UK residence, a qualifying new resident can claim relief on eligible foreign income and gains arising during the first four years here, and FIG on which relief has been claimed can be brought into Britain without the remittance charge that applied under the previous regime.
For a family expecting to spend several years in London, that is a serious offer, but four years is a short period in family-office terms. A founder may still be building the company when the FIG window closes, children may be halfway through school, and the family may have bought property, recruited staff and established a life in Britain.
By the fifth year, someone who remains UK resident will generally be taxed on worldwide income and gains as they arise, and inheritance tax then creates another date. Broadly, someone resident in the UK for at least 10 of the previous 20 tax years becomes a long-term UK resident, bringing overseas assets potentially within the UK inheritance tax regime, and depending on the residence history, that exposure can remain between three and 10 tax years after departure.
For significant family wealth, year 10 can carry far more weight than year four, and trusts can be affected as well. The inheritance tax treatment of foreign property held in an offshore trust can now change with the living settlor’s long-term UK residence position, so a trust established years before the move, on the footing that its foreign assets would stay outside UK inheritance tax, may produce a different result because the settlor remained here longer than planned.
But London retains key advantages: deep capital markets, sophisticated advisers, private banking, international business networks, leading schools and universities, and a legal system trusted by families whose assets span several jurisdictions. For families coming from countries where political institutions or property rights are less predictable, the attraction is stronger still. Much of my work involves people whose home state has turned on them, through a fabricated prosecution, an asset seizure or an INTERPOL Red Notice, for whom settlement and eventually citizenship are a form of protection.
Many families will still choose London for its schools, cultural life and social and professional networks. But relocating a substantial family carries costs that never appear on a tax return: businesses move, children change schools, houses are bought, advisers and employees are appointed, social and commercial networks take years to build, and a family office may reorganise its structures around the family’s new residence. Families can accept a high price when they understand the terms; repeated changes make that calculation much harder.
These consequences become much harder to manage once the relevant date is close, so family offices should price the full UK commitment at the beginning, modelling the family’s position over four years, 10 years and 20 years across immigration status, worldwide taxation, inheritance tax, trusts, business ownership and succession. The review points are set by the rules themselves: what happens when FIG ends in year four; which assets come into scope if the principal is still here at year 10; which trusts are connected to that person as settlor; how long inheritance tax exposure would follow the family on departure; and whether the immigration route still produces the settlement outcome on which the family originally relied.
A second jurisdiction may form part of that planning, whether through residence rights or a genuine base elsewhere, or by keeping business or family interests outside Britain. The aim is to leave enough room to respond when tax, immigration or family circumstances change.
Britain still offers a powerful proposition for internationally mobile wealth; the difficulty is that families are being asked to make decisions measured in decades while policy changes over much shorter periods. A family office that prices that gap at the outset can still choose London, and does so on terms it understands.
To read the article on the Family Office Magazine website, please click here.
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Ben Keith is a leading barrister specialising in cross-border and international cases. He deals with all aspects of extradition, immigration, human rights, mutual legal assistance, Interpol, financial crime and international law, including sanctions. He represents governments, political and military leaders, high net worth individuals, human rights defenders and business leaders in the most sensitive cases. He is a leading authority on the removal of Interpol Red Notices for worldwide clients. He edits the Red Notice Monitor blog.
Ben has extensive experience of appellate proceedings before the Administrative and Divisional Courts, Civil and Criminal Divisions of the Court of Appeal and the Supreme Court as well as applications and appeals to the European Court of Human Rights and the United Nations.
Ben has significant expertise in post-soviet states, as well the Middle East and the Far East.
He is ranked in Chambers and Partners as a star leader in the field of extradition at the London Bar and in The Legal 500 as a Tier 1 leading individual in extradition. Ben is also ranked in Chambers and Partners in the field of immigration and in its Financial Crime: High Net Worth Individuals rankings. He is recognised in The Spears’ 500 2024 Guide as a ‘Recommended Immigration Law Barrister’.
