UK Family Office Events Ltd
TAX-AWARE INVESTING · UK FAMILY OFFICES · UPDATED JUNE 2026

Tax-Aware Investing
for UK Family Offices
— The 2026 Guide

The complete guide to the UK tax changes every family office principal, CIO and private wealth owner must understand in 2026 and 2027 — and how to structure investments accordingly.

Published for informational purposes only. Does not constitute tax, legal, financial or investment advice. All data sourced from HMRC and primary government sources as cited. Always seek independent qualified professional advice before making any decision.

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The UK tax landscape for family offices and private wealth holders has changed more fundamentally between 2024 and 2026 than in the previous two decades combined. Five structural changes — each significant individually, collectively transformative — have reshaped the environment within which UK family office investment decisions must now be made.

Tax-aware investing for UK family offices in 2027 is not about avoidance. It is about understanding which reliefs still apply, which have been restricted or removed, what transitional facilities remain open and for how long — and how to structure investment decisions to remain tax-efficient within the new landscape.

This guide covers each of the five major changes in detail, with verified primary source data, investment implications and the questions every principal should be discussing with their advisers now.

01

Agricultural & Business Property Relief — Capped from 6 April 2026

What changed

From 6 April 2026, the 100% IHT relief on combined APR and BPR is capped at £2.5 million per individual — increased from the original £1 million cap announced at the 2024 Autumn Budget, following lobbying, confirmed 23 December 2025. Assets above £2.5 million receive 50% relief only, creating an effective 20% IHT rate. AIM and EIS shares now attract 50% BPR only. Couples can combine to shelter up to £5 million. Relevant property trusts have their own £2.5 million allowance refreshing every 10 years. Payment of IHT extended to 10 annual interest-free instalments for all qualifying APR and BPR assets.

Investment implications

Family offices holding business assets, agricultural land or AIM-listed shares above £2.5 million need to review succession structures, trust arrangements and gifting strategies urgently. The window for transferring unlimited qualifying assets into trust under the previous rules has closed. Planning now requires careful assessment of the new £2.5 million allowance against wider estate planning structures.

Source: HMRC; House of Commons Library CBP-10181 (June 2026); Royal London for Advisers; Womble Bond Dickinson; Saffery.

02

Non-Dom Abolished: FIG Regime

What changed

The UK non-dom regime — in place for over 200 years — was abolished on 6 April 2025. Replaced by the four-year Foreign Income and Gains (FIG) regime, available only to individuals non-resident in the UK for at least 10 consecutive years before UK residency. Within the FIG period, qualifying individuals pay no UK tax on foreign income and gains. After year four, worldwide taxation applies. The Temporary Repatriation Facility allows those who previously used the remittance basis to bring pre-2025 foreign income and gains to the UK at 12% in 2025/26 and 2026/27, rising to 15% in 2027/28. After the 2027/28 tax year the TRF closes permanently.

Investment implications

The TRF window at 12% is open now — in 2026/27. It rises to 15% in 2027/28 and then closes permanently. For any principal who has accumulated significant pre-2025 foreign income and gains under the remittance basis, the decision of whether to designate under the TRF and at what level is one of the most time-sensitive tax decisions available in the current landscape.

Source: HMRC; Saffery; KPMG; Tax Adviser Magazine; BDO.

03

Offshore Trust Protections

What changed

From 6 April 2025, previously protected offshore trusts no longer shield foreign income and gains from UK tax for UK resident settlors and beneficiaries. Foreign income and gains arising in protected trusts before that date are taxable to the extent matched against worldwide trust distributions or benefits. The concept of tainting has been eliminated. The onward gift and close family member rules have been amended.

Investment implications

Any family office with historic offshore trust structures — particularly those established specifically to benefit from the non-dom trust protections — must urgently review those structures with qualified legal and tax advisers. The interaction between trust distributions and the new matching rules creates complex exposures that vary significantly by structure, timing and the residence status of settlors and beneficiaries.

Source: Tax Adviser Magazine; Saffery; BDO; HMRC.

04

Residence-Based IHT

What changed

The domicile-based IHT system has been replaced with a long-term residence test. Individuals UK resident for more than 10 of the previous 20 tax years are long-term residents for IHT and potentially subject to UK IHT on worldwide assets. Non-UK assets held by long-term UK residents — previously protected from UK IHT under the non-dom domicile-based system — now fall within the UK IHT net.

Investment implications

For principals who are long-term UK residents with significant non-UK asset holdings, this creates potential IHT exposure that did not previously exist. Cross-border estate planning — reviewing asset location, trust structures, insurance arrangements and succession plans — is now urgent. The UK experienced a net loss of 10,800 millionaires in 2024 in part as a direct response to these changes.

Source: HMRC; KPMG; BDO; Hubbis.

05

What Still Works: Tax-Efficient Structures

Despite significant restrictions, a number of tax-efficient structures remain available and valuable. This section covers those that remain intact and relevant for UK family offices in 2027.

EIS

Enterprise Investment Scheme — 30% income tax relief on qualifying investments. Lifetime cap £24 million from 6 April 2026 (£40 million for Knowledge Intensive Companies). IHT relief through BPR at 50% for qualifying EIS shares.

SEIS

Seed Enterprise Investment Scheme — 50% income tax relief on investments up to £200,000 per tax year. CGT reinvestment relief. Loss relief available. Suits early-stage direct investment by family office principals.

Pensions

The removal of the Lifetime Allowance has made UK pensions significantly more attractive for high-net-worth individuals as a tax-efficient accumulation and succession vehicle. Contributions attract income tax relief at the marginal rate.

ISAs

£20,000 annual individual allowance — tax-free income and capital gains wrapper. Transferable on death to a surviving spouse without losing the tax-free status. Useful component of broader family tax planning.

VCTs

Venture Capital Trusts — 30% income tax relief on investments up to £200,000 per tax year. Dividends paid free of income tax. CGT-free on disposal. Suits principals with appetite for qualifying smaller company exposure.

This section is for general informational purposes only and does not constitute tax advice. EIS, SEIS, ISA, VCT and pension eligibility and suitability depend on individual circumstances. Always seek independent qualified tax advice from an FCA-regulated professional before making any investment decision. UK Family Office Events Ltd is not a regulated financial adviser.

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FREQUENTLY ASKED QUESTIONS

Questions & Answers

What is tax-aware investing for UK family offices?
Tax-aware investing for UK family offices is the practice of structuring investment decisions with full consideration of the tax consequences for the principal, the family and the office — including income tax, capital gains tax, inheritance tax, stamp duty and applicable international tax obligations. In 2026 and 2027, tax-aware investing is particularly urgent because of five structural changes to UK tax law introduced between April 2025 and April 2026 — the abolition of the non-dom regime, the removal of offshore trust protections, the shift to residence-based IHT, the capping of APR and BPR relief at £2.5 million, and the reduction of BPR on AIM shares to 50%. This information is for general purposes only and does not constitute tax advice.
What is the IHT APR and BPR cap introduced in 2026?
From 6 April 2026, the 100% IHT relief on combined Agricultural Property Relief and Business Property Relief is capped at £2.5 million per individual. Assets above this threshold receive only 50% relief — an effective 20% IHT rate on the excess. AIM-listed and EIS shares are now capped at 50% BPR in all circumstances. Couples can combine allowances to shelter up to £5 million of qualifying assets. The original cap of £1 million was increased to £2.5 million on 23 December 2025 following industry lobbying. Source: HMRC; House of Commons Library CBP-10181 June 2026. This is general information only — seek independent qualified tax advice.
What is the FIG regime and the Temporary Repatriation Facility?
The Foreign Income and Gains (FIG) regime replaced the UK non-domicile remittance basis on 6 April 2025. It is available to individuals who have been non-resident in the UK for at least 10 consecutive years. Qualifying individuals pay no UK tax on foreign income and gains in their first four years of UK residency. The Temporary Repatriation Facility (TRF) allows those who have previously used the remittance basis to bring pre-2025 foreign income and gains into the UK at 12% in 2025/26 and 2026/27, rising to 15% in 2027/28. The TRF closes permanently after the 2027/28 tax year. Source: HMRC; Saffery; KPMG. This is general information only — seek independent qualified tax advice.
What tax-efficient investment structures remain available for UK family offices in 2026?
Despite the reforms, several structures remain available and valuable: the Enterprise Investment Scheme (30% income tax relief, £24 million lifetime cap from April 2026); the Seed Enterprise Investment Scheme (50% income tax relief up to £200,000 per year); UK pensions (income tax relief at the marginal rate, with the Lifetime Allowance removed); ISAs (£20,000 annual tax-free wrapper per individual); and Venture Capital Trusts (30% income tax relief up to £200,000 per year, tax-free dividends). Eligibility and suitability for all structures depend on individual circumstances. This is general information only — always seek independent qualified tax advice from an FCA-regulated professional.
How do I attend a Tax-Aware Investing Briefing?
UK Family Office Events Ltd hosts closed, invite-only Tax-Aware Investing Briefings for UK family office principals and private wealth owners across London and key UK cities. All briefings are free to qualifying principals and are led by senior private client tax advisers and lawyers. All sessions operate under Chatham House Rule. Register your interest using the form on this page or contact info@uksfoevents.com. The tax-aware investing theme is also a core pillar of the UK Family Office Risk & Technology Conference 2027 — apply to attend at uksfoevents.com/attend.