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In the news in April

The following recent news items cover the non-dom/Financial Institutions Group (FIG) reforms and early signals in prime London property, as well as forthcoming inheritance tax changes affecting Business Property Relief for family businesses.

Non‑Dom reform and London property: Early signals and considerations

With the non‑dom regime now replaced by a residence‑based system, internationally mobile individuals are reassessing the UK’s overall tax and lifestyle proposition. Early signals in prime London property point to shifting demand, making it a sensible time to review residency position and UK property exposure.

Property professionals have widely interpreted the recent closure of Harrods Estates’ final Knightsbridge office as a sign of a broader shift in London’s prime residential market, particularly following the abolition of the non‑dom tax regime.

At the 2024 Budget, the government replaced the longstanding non-dom system with a residence-based regime that taxes long-term UK residents on their worldwide income, subject to a four-year transition period. Since then, advisers report a noticeable fall in demand from internationally mobile buyers, especially in traditionally global neighbourhoods such as Knightsbridge.

Market data supports this shift, with prime London sales volumes significantly down year‑on‑year. Estate agents point to a combination of factors, including the non‑dom reforms, earlier stamp duty changes and evolving buyer profiles. Still, many agree that tax certainty and competitiveness play central roles in location decisions for the globally wealthy.

It must be noted that this research predates the very unfortunate events in the Middle East and the wider global uncertainty they have caused. With no apparent short-term resolution to that conflict, those international individuals and their families may well be reassessing their current requirements.  In such uncertain times, the UK still offers a peaceful, safe harbour for individuals and wealth, with a strong track record of the rule of law and a fiercely independent judiciary.

For internationally connected individuals and families, these developments underscore the importance of reviewing residency status, UK property exposure, and broader wealth structures, whilst balancing these against family interests and priorities. For property owners and investors, they highlight the need to reassess long‑term assumptions about demand, liquidity and exit planning.

If the non‑dom reforms affect you, or if you are considering relocation, investment, or restructuring, our specialist Greenwoods teams can provide personal advice and guidance to help you manage this evolving landscape.

Inheritance Tax reform: What family business owners should consider now

With the inheritance tax (IHT) relief, Business Property Relief having been tightened from 6 April 2026, family business owners may want to revisit succession plans they were unable to review before that deadline. In particular, it is worth examining ownership and governance arrangements, as well as how any future IHT liability would be funded.

Recent changes to the IHT regime are prompting renewed concern among UK family business owners, with several high‑profile entrepreneurs warning of unintended consequences.

From April 2026, Business Property Relief, which historically allowed family‑owned businesses to pass between generations free of IHT, is now significantly restricted. While the government conceded an increased threshold of £2.5m, business interests above this level may well face IHT at 20 per cent.

The core issue, repeatedly raised by business leaders, is liquidity. Many family firms are asset‑rich but cash‑poor, with values based on future earnings rather than readily realisable assets. In practice, this could mean estates/beneficiaries are left with substantial tax liabilities but limited means to fund them, potentially forcing asset sales, business restructuring or reduced reinvestment.

Beyond succession, the reforms are already influencing behaviour. Some owners report delaying or cancelling expansion plans to manage future tax exposure, a trend that may have wider implications for growth, employment, and long-term stability.  This is on top of recent increases to employer national insurance contributions.

For family business owners, these changes underline the importance of proactive succession and estate planning. Reviewing ownership structures, shareholder arrangements and funding options well in advance can help preserve both business continuity and family intentions.

If these reforms affect you now, it is a sensible time to seek advice and ensure your plans remain robust and tax-efficient under the new rules, as options remain available to you.

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This update is for general purposes and guidance only and does not constitute legal or professional advice. You should seek legal advice before relying on its content. Greenwoods Legal Services Limited is a Limited company, registered in England, registered number 16115882. Our registered office is Queens House, 55-56 Lincoln’s Inn Fields, London, WC2A 3LJ. Authorised and regulated by the Solicitors Regulation Authority, SRA number 8011813. Details of the Solicitors’ Codes of Conduct can be found at www.sra.org.uk. All instructions accepted by Greenwoods Legal Services Limited are subject to our current Terms of Business. VAT Reg No: 502 6933 06




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