Quarterly Technical Briefing

#6 Winter 2026

Editorial comment

Aidan Golden
Head of Group Technical Services

Welcome to the Winter 2026 edition of NAVIGATOR.

This edition arrives as cross border tax rules continue to shift, with advisers facing greater scrutiny, tighter regimes and increasingly mobile clients. As ever, NAVIGATOR provides the insight and practical guidance needed to stay ahead.

Our Technical Spotlight examines HNW Expat Tax Regimes. It opens with Brendan Harper’s overview, outlining both the opportunities and the pitfalls advisers must understand as they plan within these regimes. This is followed by five market specific articles covering the expat tax regimes of the UK, France, Portugal, Spain and Italy, and concludes with the key insight that portability, through an insurance-based wealth solution, can outperform individual expat regimes over the long term.

This edition highlights key developments across Regulation, Tax and Compliance, including Colombia’s revised Wealth Tax for 2026, Belgium’s Budget measures and France’s changing social contribution landscape.

Elsewhere, Navigator Voices features my exclusive interview with Paul Thompson, CEO of Utmost. Marking ten years since the Utmost brand launch, Paul shares what defines a resilient life company and highlights three trends set to shape the industry in 2026 and beyond.

In Country Focus, we look at the growing impact of fiscal drag on UK clients. We also include a case study that shows how an insurance-based solution can mitigate fiscal drag for UK clients.

As always, our aim is to equip advisers with clear, practical analysis that supports thoughtful, compliant and forward looking planning for clients.

Thank you for reading, and for your continued engagement with NAVIGATOR.

Aidan Golden
Head of Group Technical Services

Commentaire éditorial

Aidan Golden
Head of Group Technical Services

Bienvenue dans l’édition Hiver 2026 de NAVIGATOR.

Cette édition paraît dans un contexte où les règles fiscales transfrontalières continuent d’évoluer, les conseillers étant soumis à une surveillance accrue, à des régimes plus stricts et à une clientèle de plus en plus mobile. Comme toujours, NAVIGATOR fournit l’analyse et les orientations pratiques nécessaires pour garder une longueur d’avance.

Notre Technical Spotlight est consacré aux régimes fiscaux applicables aux expatriés à haut niveau de patrimoine (HNW). Il s’ouvre par une analyse de Brendan Harper, qui présente à la fois les opportunités et les risques que les conseillers doivent comprendre lorsqu’ils planifient dans le cadre de ces régimes. Cette section est suivie de cinq articles spécifiques par marché, couvrant les régimes fiscaux des expatriés au Royaume-Uni, en France, au Portugal, en Espagne et en Italie, et se conclut par un constat clé : la portabilité, via une solution patrimoniale adossée à l’assurance-vie, peut s’avérer plus performante à long terme que les régimes d’expatriation pris individuellement.

Cette édition met également en lumière les principales évolutions en matière de Réglementation, Fiscalité et Conformité, notamment la révision de l’impôt sur la fortune en Colombie pour 2026, les mesures budgétaires en Belgique et l’évolution du cadre des contributions sociales en France.

Dans Navigator Voices, vous retrouverez mon entretien exclusif avec Paul Thompson, CEO d’Utmost. Marquant les dix ans du lancement de la marque Utmost, Paul explique ce qui définit une compagnie d’assurance-vie résiliente et met en avant trois tendances appelées à façonner le secteur en 2026 et au-delà.

Dans Country Focus, nous analysons l’impact croissant du fiscal drag (érosion fiscale progressive) sur les clients britanniques. Nous présentons également une étude de cas illustrant comment une solution patrimoniale adossée à l’assurance-vie peut contribuer à en atténuer les effets pour ces clients.

Comme toujours, notre objectif est de fournir aux conseillers une analyse claire et opérationnelle, afin de soutenir une planification réfléchie, conforme et tournée vers l’avenir.

Merci de votre lecture et de votre engagement continu envers NAVIGATOR.

Aidan Golden
Head of Group Technical Services

PulseRegulation, Tax and ComplianceTechnical SpotlightNavigator VoicesCountry FocusCase Study InsightsUpcoming Events Download PDF

In this issue

Pulse

The key developments in regulation, tax and compliance by market.

Regulation, Tax and Compliance
Technical Spotlight
Navigator Voices
Country Focus
Case Study Insights

Managing Fiscal Drag and Inheritance Tax in the UK

Upcoming Events

Upcoming webinars and other industry events

Ask Our Team

Get in touch with the Technical Services team

Pulse

Keep your finger on the industry pulse with our quarterly round-up of the most important regulatory and compliance developments in the wealth management sector.

Updated quarterly, this overview reflects the position at the time of publication.
For the latest developments, please refer to the most recent edition.

France
2025 Budget Act No. 2025-127

Life insurance is safe and sound
Several fiscal adjustments, while life insurance maintains its favourable tax treatment.

14 February 2025

  • Introduction of a minimum 20% tax on high incomes.
  • Tightening of capital gains taxation for non-professional furnished rental properties (LMNP).
  • New tax framework for management packages.
  • Indexation of the income tax scale.

Italy
IVASS Regulations on permissible assets and investment restrictions for unit-linked insurance products

Second Consultation on revised set of rules on permissible assets and investment restrictions for index and unit-linked products.
Final Regulation still not issued.

30 June 2025

  • IVASS is still to issue the final regulation on permissible assets and investment restrictions for unit and index linked products, as well as its views on biometric risk requirements —despite two consultation rounds (carried out in 2022 and 2024) and feedback received from the industry, including Utmost – with no official timeline nor any expectations now on the possible issuance date.

EU
Omnibus Simplification Package approved

Proposed Omnibus regulation to cut ‘red tape’.

16 December 2025

  • ‘Omnibus Simplification Package’ published.
  • Contains proposals to reduce CSRD and CSDDD burdens on firms and simplify obligations under the Taxonomy Regulation.
  • Proposals de-scope a number of firms from the CSRD reporting requirements altogether.
  • Package also contains proposals to postpone the reporting obligations for firms reporting for financial years 2025 and 2026 to prevent possible costs of reporting before being de-scoped.
  • On 16 December 2025 the final text for the Omnibus was adopted by the European Parliament.
  • Council of the European Union expected to approve the text in early 2026.

Portugal
ASF parafiscal charge increase

ASF parafiscal charge will increase on 1 January 2026.

1 January 2026

  • The ASF parafiscal charge due on all premiums and top-ups will increase from 0.048 to 0.078%. This will be in force on 1 January 2026.

Portugal
PIT breaks and tax rates changes

The 2026 Portuguese State Budget amended the PIT breaks and some tax rates. This does not affect directly our product taxation. It only affects if the Policyholders decide to aggregate the income from surrenders with other income and be consequently liable to taxation at the final PIT rates.

1 January 2026

  • The 2026 Portuguese State Budget amended the Personal Income Tax (PIT) brackets by 3.51%, through the automatic mechanism provided by law, and reduced the rates for the 2nd to 5th brackets by 0.3 percentage points.

Italy
2026 Budget Law

Dividend and capital gains taxation for companies

1 January 2026

  • The favourable tax rate of 1.2% in case of dividends issued by and capital gains derived from underlying Italian companies (i.e., PEX regime) will continue to apply exclusively in case of the underlying investment in the Italian company is > 5% or with a taxable value > €500,000.
  • The new provisions apply to distributions of operating profits, reserves, and other funds approved starting 1 January 2026.

Belgium
New Law on capital gains tax on ‘financial assets’ held by Belgian residents

Branch 23 (unit-linked) insurance contracts will fall into the scope of the new Law, but only on withdrawals and surrenders.

1 January 2026

  • On 23 November 2025, the Belgian government reached agreement on the 2026 Budget including application of a new capital gains tax.
  • Draft Law to be discussed and voted on by Parliament and provides that the new tax will be introduced with a retroactive effect as from 1 January 2026.
  • Upon realization of the gain, i.e., sale of the financial asset, the tax rate of the capital gains tax will be 10%, with an exemption of a capital gain of €10,000 per year per investor.
  • Historical gains realized up to 31 December 2025 out of scope of capital gains tax.

Belgium
Increase of the rate of the Tax on the Annual Securities Accounts (ATSA)

Increase of the Annual Tax on Securities Accounts (ATSA) from 0.15% to 0.30%.

1 January 2026

  • ATSA is a wealth tax applicable on all securities accounts above €1,000,000 held by Belgian residents.
  • Increasing on 1 January 2026 from 0.15% to 0.30%.
  • Not applicable on insurance contracts with an underlying securities account of more than €1,000,000 subscribed by a
  • Belgian-resident policyholder at a Luxembourg insurance company (or eventually its Belgian Branch) where the custodian bank of the insurance contract is situated outside Belgium.

France
Green Industry Law no. 2023-973 of 23 October 2023

Transaction fees banned for arbitrage mandates.
Introducing a DDA interpretation within French law on life insurance dealing charges (in arbitration mandates).

1 January 2026

  • Commissions or remuneration received in connection with investment or disinvestment transactions between the investment links available under an arbitration mandate within a life insurance policy have been prohibited since 1 January 2026.
  • In the context of discretionary portfolio management for third parties, asset managers will be prohibited from charging fees in connection with buy or sell transactions, first for new mandates from 1 January 2028.

Sweden
Yield tax applicable for income year 2026 set at 1.065%. Amount exempted also increased to SEK 300,000.

Will impact all Swedish tax resident holders of a life insurance policy and/or an ISK account.

1 January 2026

  • The Government borrowing interest rate as of 30 November 2025 set at 2.55%, which brings an effective yield tax at the level of 1.065% ((2.55% + 1%) x 30%).
  • The yield tax is applied on life insurance policies on the value as of 1 January 2026. The yield tax is also applied in full on additional premiums paid the first 6 months of the year and at half rate on premiums paid the last 6 months of the year.
  • Please note, non-Swedish withholding tax paid within a life insurance portfolio may be set off against the yield tax and Swedish withholding tax may be fully recovered.
  • Amount in a life insurance policy or on an ISK account exempted from yield tax increased to SEK 300,000 for 2026 (previous exempted amount of SEK 150,000).
  • Exemption is a tax incentive by the Government to increase savings in Sweden. Primarily to benefit retail clients but will apply to all life insurance policies and ISK accounts.

Italy
Insurance Arbitrator (AAS)

New alternative dispute resolution system for insurance-related matters.

15 January 2026

  • The new Insurance Arbitrator (AAS) is now live, effective 15 January 2025. It is a simple, fast, and non-expensive alternative dispute resolution system for insurance-related matters, available to policyholders, life assureds and beneficiaries of an insurance contract.
  • Appeals to the AAS shall be filed online against an insurance company and/or an insurance intermediary, via the AAS portal, available on the website .
  • Further information on the requirements for submitting a complaint to the AAS is available on the AAS website.

Italy
IVASS Order no. 169/2026

IVASS regulation on the “right to be forgotten” implementing LAW no. 193/2023.

15 January 2026

  • Law no. 193/2023 introduced a ban on insurance companies and intermediaries to request information on the health status to clients who had suffered from oncological pathologies when taking out or renewing insurance contracts, when a certain amount of time has passed in the absence of relapses of the disease.
  • The Regulation requires the oncological right to be forgotten to be expressly mentioned in the contractual documentation used for the conclusion or renewal of insurance contracts.
  • In addition to amending IVASS Regulations 40/2018 and 41/2018, IVASS requires insurance undertakings to include the new provision in the Additional PID (precontractual information document).

EU
Artificial Intelligence (AI) Act

Majority of provisions in the Act to take effect by 2 August 2026.

2 August 2026

  • Published in the EU Official Journal on 12 July 2024, the AI Act classifies AI systems based on their potential risk, banning those with unacceptable risk and regulating high-risk systems.
  • Applies to all organisations that develop, use, distribute, or import AI systems in the EU, even if they are not EU-based.
  • Legal application to be phased in over the next three years, with most provisions taking effect on 2 August 2026.
  • Digital Omnibus published 19 November 2025 contains proposal for Regulation amending the AI Act but these do not materially affect the overall effect of AI Act.

EU
Retail Investment Strategy (RIS)

Retail Investment Strategy PRIIPs and IDD changes.

2027/2028

  • RIS aims to boost consumer protection and confidence in the financial sector through enhanced disclosure requirements and financial promotion rules, for example, to encourage customers to invest in financial products across the Union. It has two main components:
    • The Omnibus Directive, which significantly amends IDD, MiFID II, UCITS, AIFMD, and Solvency II.
    • Amendments to the PRIIPs Level One Regulation, paving the way for new technical standards
  • Negotiations on aspects such as inducement rules and value-for-money benchmarks have been intense. The EU ‘trilogue’ negotiations are expected to begin in November 2024, following the new Commission’s term commencement.
  • Given the complexity of these legal updates, the strategy is not expected to be in effect until 2027.

EU
EU Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT)

6th AML Directive (AML D6) and new AML Regulatory Package.

10 July 2027

  • This package includes a directive outlining the mechanisms member states must implement, a regulation establishing the Authority for AML and CTF, and a significant regulation to replace the current Fifth AML Directive.
  • The new regulation aims to address inconsistencies in the local application of the directive by introducing directly applicable rules across the EU.
  • Four sets of draft Regulatory Technical Standards published by EBA on 6 March 2025 including draft RTS on Customer Due Diligence. These were subsequently revised following feedback. AMLA will take over the production of these RTS and supplement with additional RTS.

EU
Sustainable Finance Disclosure Regime (SFDR) Changes

Proposed SFDR changes aim to simplify rules and align disclosures with other EU sustainability frameworks.

2028 (H1 at the earliest)

  • On 20 November 2025 the European Commission adopted its final proposal for amendments to SFDR.
  • Aim to simplify rules and align disclosures with other EU sustainability frameworks.
  • Key changes include:

    • New product categorization regime.
    • Remove portfolio management and investment advice from scope of SFDR.
    • Remove entity level requirements for PAI reporting and disclosures on how sustainability risks are considered in remuneration policies.
  • Changes are expected to come in effect early to mid-2028.

UK
Targeted Support Regime

FCA publishes final rules for Targeted Support Regime in PS 25/22 setting out new regulatory proposition for targeted support in pensions and retail investments. Key part of FCA’s work to close the ‘advice gap’.

6 April 2026

  • FCA have identified a gap in provision of financial advice.
  • Targeted support introduced as a new type of help for consumers not currently accessing financial advice but have uninvested cash savings or pension requirements for example.
  • Under targeted support firms can deliver product suggestions suitable for groups of customers who share common characteristics.
  • Regime comes into force 6 April 2026. Only FCA authorised firms with over £500,000 in capital being able to provide Targeted Support.
  • Rules are a starting point with changes to ‘simplified advice’ also on horizon.

UK
UK PRIIPs Revocation and Replacement Consumer Composite Investment Disclosure Regime

Final rules on Consumer Composite Investments Regime released in PS 25/20. Replaces UK PRIIPS regime.

April 2026

  • FCA have released final rules for new consumer disclosure regime.
  • Term ‘PRIIP’ being replaced with ‘consumer composite investments’.
  • PRIIPS KID and UCITS KIID replaced with a product summary.
  • Manufacturers will need to make underlying information available to distributors in a machine-readable format.
  • Flexible format allowing for more information to be provided on top of that mandated
  • Rules on complaints handing for unauthorised manufacturers and distributors of CCI’s.

UK
IHT on unused pensions savings and changes to Property and Savings rates of tax

UK Government remain committed to including unused pensions savings in estates for IHT purposes.

April 2027

  • Autumn Budget announced unused pension savings may be included in people’s estates for IHT.
  • Despite industry pushback, the pensions minister has stated that there will be no change of approach from the government in this matter.
  • Property and Savings rates of tax changed with 2% increase on property and savings rates of income tax –basic rate increased to 22%, higher rate increased to 42% and additional rate increased to 47%. Changes to order of taxation with property income sitting after non-savings income but before savings income. The personal allowance will be deducted against non-savings income prior to property, savings or dividend income
  • Temporary Repatriation Facility rate (for those previously claiming remittance basis) increases from 12% to 15% for final year

UK
Financial Conduct Authority Crypto roadmap

FCA expects all Policy Statements that form the new Crypto regime to be published in 2026. FCA consulting on proposal to lifted ban on retail clients accessing crypto Exchange Traded Notes on 8 October 2025.

25 October 2027 (expected date)

  • Roadmap sets out key dates for expected discussion papers. and consultation papers in development of new UK crypto regime.
  • Designed to increase consumer trust and ensure market integrity.
  • DP24/4: Regulating cryptoassets – Admissions & Disclosures and Market Abuse Regime for Cryptoassets published 16 December 2024.
  • Discussion paper DP25/1 Regulating cryptoasset activities published 2 May 2025. It seeks views on FCA’s approach to regulating cryptoasset trading platforms, intermediaries, cryptoasset lending and borrowing, staking and decentralised finance and use of credit to purchase cryptoassets.
  • Consultations CP25/14 and CP25/15 published setting out proposed rules for issuing stablecoin and the proposed prudential requirements for issuers.
  • Consultation CP25/40 published containing proposed rules for firms conducting regulated cryptoasset activities such as trading platforms, intermediaries (including cryptoasset lending and borrowing), staking and decentralised finance.

UK
Regulatory regime for ESG ratings providers

Proposed ‘Go live’ date for ESG ratings regime. .

2028

  • Draft legislation bringing ratings providers under remit of FCA. From 29 June 2028 firms will need FCA authorisation to provide certain types of ESG ratings in the UK.
  • FCA have published consultation CP25/34 setting out proposed approach to regulation.
  • Regime expected to improve transparency and quality of ESG ratings for investments and other types of financial products.
  • Goal of supporting better decision making and confidence in the market and support growth in sustainable finance.

UK
Temporary Repatriation Facility ends and High Value Council Tax Surcharge introduced

Ending of the Temporary Repatriation Facility and lower tax rates for those previously able to use remittance basis who remit their pre-6 April 2025 income or gains.

April 2028

  • End of the Temporary Repatriation Facility for those previously claiming remittance basis.
  • Introduction of The High Value Council Tax Surcharge (HVCTS) – an annual levy on residential properties valued above £2m starting at £2,500 and increasing to a maximum of £7,500 on houses worth £5m and above.

UK
Salary Sacrifice Changes

Impact to UK employees previously utilising salary sacrifice.

April 2029

  • Changes to pension salary sacrifice rules come into effect. NI payable on contributions above £2,000.

Norway
Change of tax rules applicable to corporate policyholders

The change will impact Norwegian corporate policyholders by limiting eligibility for the participation exemption.

1 January 2026

  • As part of the 2026 State Budget, the Norwegian Parliament (Stortinget) approved changes to the taxation of unit-linked insurance for corporate policyholders in December 2025.
  • The original January 2025 proposal to fully remove the participation exemption (fritaksmetoden) for companies investing via a unit-linked life policy was not adopted in its original form.
  • Instead, the participation exemption now applies only to assets that would qualify for the exemption if held directly, tightening the scope of tax-exempt treatment within unit-linked policy structures.
  • The changes are intended to prevent unintended tax planning, while preserving legitimate use of insurance arrangements.
  • The revised rules preserve unit-linked life insurance as a flexible investment structure for corporate investors, rather than eliminating participation exemption treatment altogether.
  • The amended rules will apply from 1 January 2026.
  • Corporate policyholders may wish to review the underlying portfolio composition to assess how the revised rules may apply to their individual circumstances.

Malaysia
Extended exemption for foreign-sourced income

Exemption period extended to 2036.

January 2025

  • Malaysia clarified taxation of foreign income in 2022–2024 guidelines.
  • Exemption extended to 31 December 2036 (effective 1 January 2027).
  • Applies to resident individuals on all classes of foreign-sourced income (excluding partnership income), provided such income is taxed abroad.

Singapore
Family Office Tax Incentives Economic Criteria for Qualifying Funds

Extension and revision of tax schemes.

January 2025

  • Incentives first introduced in 2019 – 2021, expanded in 2022 – 2024 to attract family offices.
  • Changes to economic criteria for sections 13D, 13O, and 13U to take effect from January 2025.
  • Extension of tax incentives for qualifying funds until end of 2029.
  • Inclusion of Limited Partnerships under section 13O scheme.
  • Revised economic criteria for qualifying funds, including potential introduction of a minimum fund size and increased business spending commitments.

MOF Update to Individual CFC Regime Q&A
MOF Update to Individual CFC Regime Q&A

Clarified CFC treatment of PPLI.

April 2025

  • Taiwan introduced CFC rules in 2023, expanded in 2024 to cover offshore trusts.
  • MOF added Q&A Q66 clarifying PPLI treatment under CFC rules.
  • Where individuals transfer CFC shares to an insurer and retain economic control, the CFC is treated as directly held.
  • Reinforces substance-over-form to prevent CFC tax avoidance.

Hong Kong
Companies (Amendment) (No. 2) Ordinance 2025 – Inward Re-domiciliation

Enables re-domiciliation of foreign companies.

May 2025

  • Builds on Hong Kong’s 2021 fund re-domiciliation regime and 2024 proposals for corporate re-domiciliation.
  • Amendment Ordinance gazetted 23 May 2025.
  • Eligible companies must meet jurisdictional recognition, minimum incorporation period, and creditor protection requirements.
  • Retention of original company name and BR number; profits tax transitional relief available.

Hong Kong
Family Office Policy Further Review and Tax Concessions

Enhanced measures and tax regime for family offices.

May 2025

  • Hong Kong launched family office concessions in 2023–2024 to attract UHNWIs.
  • Ongoing measurement of the Capital Investment Entrant Scheme (CIES) and Family-owned Investment Holding.

Thailand
Remittance-Based Taxation of Foreign Income Tax on foreign income brought into Thailand

Comprehensive taxation on foreign income.

2025>2026

  • Thailand shifted from deferral-based taxation to remittance-based taxation in 2024.
  • Foreign income taxation effective from 1 January 2024. Foreign income brought into Thailand will be taxed in the year it is brought in, regardless of when earned. This eliminates the previous tax deferral strategy.

Thailand
Proposed draft May 2025 Royal Decree on Foreign Income Remittance Reform

New 1–2-year tax-exempt window under draft decree.

2025>2026

  • Reform proposal follows strict 2024 remittance taxation rules.
  • Draft royal decree (May 2025) proposes that foreign income remitted within the same or next calendar year after it’s earned (1–2 year “safe window”), will be exempt.
  • Encourages timely capital return; draft still pending enactment, likely in 2026.

Regulation, Tax and Compliance

Belgium Budget 2026: Key Tax Changes Impacting Life Insurance Planning

Nicolaas Vancrombrugge
Senior Wealth Planner – Belgium and Luxembourg

Belgium’s 2026 Budget introduces two significant tax changes that will influence how advisers support their clients regarding the planning of their wealth. The confirmation of a new capital gains tax, combined with an increase in the Tax on Annual Securities Accounts, marks a notable shift in the country’s fiscal landscape.

Nicolaas Vancrombrugge outlines what these measures mean in practice and highlights the opportunities that insurance-based wealth solutions can offer in a changing regulatory environment.

Read the article

France: 2026 Social Contributions – Implications for Portfolios, Insurance and Expatriates

Nicolas Morhun
Senior Wealth Planning, Associate Director – France

Alix Devalmont
Senior Wealth Planner – France

France has introduced targeted changes to its social contribution regime as part of year-end legislative measures. In this article, Nicolas Morhun and Alix Devalmont explain how the 2026 law increases the contribution sociale généralisée (CSG) or generalised social contribution, on pure financial income while preserving preferential treatment for “popular savings”.

For advisers, the message is clear: portfolios face higher levies, while insurance and capitalisation contracts maintain their relative efficiency. Expatriates with S1 coverage are largely shielded from the change.

Read the article

Colombia: Emergency Decree Reshapes Wealth Tax for 2026

Nerea Llona
Tax and Legal Counsel – Spain and LatAm

Colombia’s tax landscape shifted at the end of 2025, as Congress rejected the proposed Financing Law and the Government enacted Emergency Decree No. 1474‑2025 to, amongst other things, reshape the Wealth Tax for 2026.

In this article, Nerea Llona outlines what the Decree changes for Colombian Wealth Tax purposes, who is now within scope, and how life insurance policies should be valued.

Read the article

Sweden: Effective Yield Tax For 2026

Roberth Josefsson
Senior Wealth Planner – Sweden

The Swedish National Debt Office has confirmed the Government borrowing rate at 2.55% as of 30 November 2025. This sets the effective yield-tax rate for income year 2026 at 1.065%. The increase from the 0.888% rate applied in 2025 reflects interest rates stabilising at a higher level during 2025 compared with 2024.

Roberth Josefsson outlines what this means for Swedish investors.

Read the article

UK Autumn Budget 2025: Key Points for Advisers

Simon Martin
Head of UK Technical Services

Simon Martin provides a concise overview of the key measures announced in the UK Autumn Budget and links to Utmost’s full analysis and updated planning tools.

Read the article

Technical Spotlight

High-Net-Worth Expat Tax Regimes in Focus

This Spotlight explores major High-Net-Worth tax regimes across core Utmost markets and builds toward the central insight: portability, when structured through an insurance-based solution, can outperform individual expat regimes over the long term. Reviewing all articles provides essential context.

Brendan Harper
Head of Asia and HNW Technical Services

Special Tax Regimes: Pitfalls and How Advisers Can Navigate Them

Expat tax regimes are becoming more common as high-tax jurisdictions compete to attract internationally mobile talent. These regimes offer temporary benefits, yet many clients do not appreciate their limits, complexity or the long-term consequences of relying on them. Advisers must understand both the opportunities and the pitfalls.

Brendan Harper examines the key risks associated with expat tax regimes and explains how advisers can support clients navigating these rules.

Read the article

UK: The Foreign Income and Gains (FIG) Regime

Lana Jarvis
Senior Wealth Planner – UK and International

Lana Jarvis outlines the conditions, the clients who benefit from FIG and where the regime presents challenges.

Read the article

France: The Inpatriate Tax Regime

Nicolas Morhun
Senior Wealth Planning, Associate Director – France

Alix Devalmont
Senior Wealth Planner – France

Alix Devalmont and Nicolas Morhun explain the key features of the French inpatriate regime and outline the practical considerations for advisers supporting internationally mobile clients.

Read the article

Portugal: The New Inpatriate Regime (NIR)

Mafalda Moura Cesário
Head of Tax and Legal – Portugal and Brazil

Mafalda Moura Cesário explains the conditions of the NIR and outlines when the regime works well for clients, and when it does not.

Read the article

Italy: The Flat Tax Regime

Filippo Mancini
Senior Wealth Planner Italy

Filippo Mancini explains how the regime works, outlines who benefits from it, and sets out the key considerations for advisers supporting internationally mobile clients.

Read the article

Spain: The Special Expatriate Tax Regime (“Beckham Law”)

Nerea Llona
Tax and Legal Counsel – Spain and LatAm

Ester Carbonell van Reck
Senior Wealth Planner – 
Spain and LatAm

Nerea Llona and Ester Carbonell van Reck explain how the Beckham regime works, who it is designed for and what advisers must consider.

Read the article

Brendan Harper
Head of Asia and HNW Technical Services

Why Portability Outperforms Expat Tax Regimes in Long Term Wealth Planning

For globally mobile clients, wealth planning becomes more complicated each time they move. Structures that worked well in one country may not fit local definitions in another. Even simple products, such as pensions or mutual funds, may fail to qualify for favourable treatment. More complex arrangements can trigger anti-roll up rules, leading to punitive tax charges, denial of reliefs and higher reporting obligations.

Brendan Harper explains why portability is essential for clients who move across borders and why advisers need solutions that remain compliant and effective in every jurisdiction.

Read the article

Country Focus

Asia: Managing Tax Compliance and Transparency for Asian HNW Families

Peter Tung
Tax and Legal Counsel – Asia

In this article, Peter Tung examines how Asian high net worth families can stay ahead of tightening global tax rules while preserving wealth across borders. As automatic information exchange and anti-avoidance measures intensify, compliance is no longer optional.

International insurance-based solutions offer flexibility and continuity, but success depends on accurate residency checks, timely disclosures, and meticulous documentation.

Read the article

France: Trust-Owned Life Policies Face New Tax Risks After Court Ruling

Benjamin Fiorino
Wealth Planner / Tax and Legal Counsel, France and Monaco

A recent Paris Court of Appeal ruling confirms that life insurance policies held through irrevocable or discretionary trusts may fall outside the French life insurance tax regime. Distributions can instead be treated as indirect gifts, creating unexpected exposure for HNW expatriates.

Benjamin Fiorino explains the decision and outlines planning options for clients relocating to France.

Read the article

UK: Fiscal Drag and Its Growing Impact on Clients

Simon Martin
Head of UK Technical Services

Fiscal drag is drawing more UK taxpayers into higher tax bands, despite no formal increases in tax rates. Tax thresholds have remained frozen while salaries and living costs have increased. Clients now face rising liabilities across income tax, inheritance tax (IHT) and capital gains tax (CGT). Understanding this trend is essential for advisers supporting long‑term planning.

Simon Martin explains how fiscal drag is affecting clients and considers how insurance‑based wealth solutions can support planning when thresholds remain static.

Read the article

Case Study Insights

Simon Martin
Head of UK Technical Services

Managing Fiscal Drag and Inheritance Tax in the UK

Clients returning to the UK often face frozen tax bands, rising earnings and growing concerns about inheritance tax (IHT). In this case study, Simon Martin explores how an overseas insurance bond can help mitigate fiscal drag, reduce IHT exposure, and provide flexibility for wealth transfer – all while ensuring professional investment management and long‑term tax efficiency.

Read the Case Study

Events and Webinars

Stay updated on our webinars and other industry events where Utmost will have a presence.

Market
Event
Date

International

Utmost Insights Webinar: Private Assets in Focus: What Advisers need to know for 2026.

Private markets are evolving fast, with growing interest from clients and advisers. Join Utmost’s Marc Achesonand Domenico Iacono, with guest speaker Michael Elio, Partner at StepStone, for a practical update on the alternatives landscape and what truly matters for advisers in 2026.

18 February 2026

Find out more

International

The International Bar Association (IBA) – 31st Annual International Private Client Tax Conference | London

1-3 March 2026

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UK

Utmost Insights Webinar: Fiscal Drag and Its Growing Impact on Clients – How Investment Bonds can help

The freezing of Income, Capital Gains and Inheritance tax allowances until April 2031 will lead to tax increases in real terms.

Join Steve Sayer as he examines what this means for clients and how careful planning can help to defer or reduce tax liabilities in the future.

4 March 2026

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Spain

8th Annual Unit-Linked Conference | Madrid

23 April 2026

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