FOSSUK Retirement and Estate Planning Swiss-UK Cross Border Estate Planning – UK Perspective Andrew Goodman.

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Presentation transcript:

FOSSUK Retirement and Estate Planning Swiss-UK Cross Border Estate Planning – UK Perspective Andrew Goodman

osborneclarke.com 1 Introduction 1.English Cross-Border Estate Principles 2.Application of English Law 3.UK Inheritance tax 4.Planning Strategies under the new regime 5.Lasting Powers of Attorney

osborneclarke.com 2 English Cross-Border Estate Principles England & Wales BasisTestamentary freedom Connecting factorsDomicile in the common law sense and Situs Law governing the estate UK domiciliary all assets ˃ English law UK real estate > English law Foreign domiciliary All others > Law of domicile Form of willEnglish > Signature of testator & two witnesses Foreign > Recognised in most cases Estate administrationExecutors and Grant of Probate / Administration Intestacy rules (family)£250,000 + possessions + ½ residue to spouse Balance split between children outright

osborneclarke.com 3 Application of English Law Example: UK resident Swiss citizen with UK and Swiss property and bank accounts 1.Probate / administration obtained in England 2.Joint property passes automatically to the survivor 3.Apply the relevant marital regime (if any) to divide the assets 4.Deceased has a (common law) domicile in Switzerland but (civil) domicile in England. 5.The conflict is resolved in favour of Swiss law applying UK Property – always English law (complete testamentary freedom) All other property – Swiss law (forced heirship regime)

osborneclarke.com 4 UK Inheritance Tax United Kingdom ApplicationUK domicile > worldwide / Non-UK domicile > UK only GiftsGifts made during the last seven years of life RatesNil rate band of £325,000 then 40% on estate Effective £650,000 for married couple Extension of nil-rate band to £500,000 (£1m) for home from 2020 ExemptionsTransfers to spouse or charity All non-UK assets/gifts for foreign domiciliary Regular gifts of excess income Reliefs100% relief for business assets held for 2 years 50/100% relief for agricultural land held 2/7 years Foreign creditsEstate tax treaty with Switzerland + Unilateral relief

osborneclarke.com 5 Planning strategies Planning opportunities are diminishing 1.Lifetime gifts (beware anti-avoidance) 2.Move assets / cash outside of the UK 3.Excluded property settlements prior to 15 th year of residence 4.Buy with debt – bank or family finance 5.Life insurance written in trust 6.Hold UK assets (other than residential property) via a foreign company 7.Use business / agricultural reliefs

FOSSUK Retirement and Estate Planning Swiss-UK Cross Border Estate Planning – UK Perspective Andrew Goodman