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Private client review for July 2025

This month’s update, by Sophie Dworetzsky (Charles Russell Speechlys).

Here we go again

In a slightly unsettling game of ‘will they won’t they?’ there was much rumour of a change to the long-term resident (LTR) concept.

Under the LTR regime after nine years of UK tax residence worldwide assets are subject to IHT (with transitional provisions applying to excluded property trusts in existence at the date of the 2024 Autumn Budget).

A number of commentaries reported that the new LTR rules would be changed if they were found to have a negative impact on the UK’s competitiveness. The concerns were apparently prompted by the ‘exodus’ of what were resident non-domiciled (RND) individuals.

One’s first response might fairly be that this issue was raised many times and many alternative suggestions were presented to HM Treasury and it is unfortunate to say the least that...

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