Quarterly Technical Briefing

#5 Autumn 2025

Editorial comment

Aidan Golden
Head of Group Technical Services

Welcome to the Autumn 2025 edition of NAVIGATOR.

This edition marks one year since we launched NAVIGATOR. Over the past 12 months, it has evolved into a practical tool for advisers, offering technical insight, planning ideas and jurisdictional updates that support client conversations. The feedback has been strong, and it’s clear that NAVIGATOR is now part of the advisory toolkit.

Our Technical Spotlight this quarter focuses on controlled distribution – a growing priority for high-net-worth families seeking to manage succession with clarity and control. In this context, we explore how insurance-based solutions are being used to structure wealth transfer in Spain, Belgium and Luxembourg.
Case Study Insights further illustrate how clients are applying these techniques in practice.

We also introduce NAVIGATOR Voices, a new section dedicated to interviews with subject matter experts. I sat down with Stephen Atkinson to discuss how tax authorities are intensifying surveillance of high-net-worth individuals using AI, automation and international data sharing – a timely topic for advisers navigating today’s compliance landscape.

Elsewhere, we cover crypto reporting, U.S. estate tax and the UK’s upcoming pension changes – all part of a fast-evolving environment where transparency, accuracy and ethical planning are more important than ever.

Thanks for reading, and for being part of NAVIGATOR’s first year.

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
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
Green Industry Law No. 2023-973 of 23 October 2023

Greater transparency within policies and funds.
Changes to the information provided to customers prior to the purchase and sale of a fund within a life insurance policy.

24 October 2024

  • Greater transparency and clear communication on surrender penalties on life insurance policies or funds.
  • New rules on the pre-contractual information that must be provided to customers.

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

Reinforcement of “the duty to advise”.
Creation of a financial profile for the customer, to be updated proactively.

24 October 2024

  • Introduction into French law of a range of measures requiring regular updating of the information collected from policyholders throughout their investment life.

Italy
Institute for the Supervision of Insurance (IVASS)

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

  • More than three years since the first consultation in March 2022, and more than two years since the second public consultation in March 2024 (closed May 2024), IVASS is still to issue the final regulation on revised rules for permissible assets and investment restrictions for index and unit-linked products, as well as its views on biometric risk requirements. Once issued, these regulations will apply to both domestic and EU insurers operating in Italy on a FoS basis.
  • Utmost provided feedback to the Regulator on the revised rules during both consultation processes, aiming to minimise the impact the proposed changes might have on the Italian product and market.
  • There is currently no official update on the expected issue date of the final regulations. IVASS was expected to issue them by the end of 2024, but this did not happen. Latest expectations are that IVASS may issue the final regulation by the end of 2025

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.

31 December 2025 (at latest)

  • On 30 June 2025, the Belgian government officially reached an agreement concerning the modalities of a new capital gains tax that will be applicable on all financial assets held by Belgian residents.
  • 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.
  • The tax will be effective as of 1 January 2026. Historical gains realized up to 31 December 2025 will be out of scope of the capital gains tax.

EU
Omnibus Simplification Package on sustainability

Proposed Omnibus regulation to cut ‘red tape’.

2025/2026

  • ‘Omnibus Simplification Package’ published with proposed amends to CSRD and CSDDD.
  • ‘Stop the clock’ directive postpones application of certain reporting requirements.
  • Commission and various EU committees are producing opinions and reports on the Omnibus proposal.

Sweden
Exemption from yield tax (Avkastningsskatt)

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

1 January 2026

  • Tax incentive by the Government to increase savings on ISK accounts or in life insurance policies in Sweden.
  • Primarily to benefit retail clients but will apply to all life insurance policies and ISK accounts.
  • Decided in 2024 with implementation in two steps; first an amount of SEK 150,000 in a life insurance policy or on an
  • ISK account exempted from yield tax in 2025, increased to an amount of SEK 300,000 exempted from yield tax in 2026.

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

  • Transaction costs on traditional private bank accounts managed on a discretionary basis are still permitted in France.
  • Transaction costs will be prohibited on discretionary managed life insurance policies from 01 January 2026.

Portugal
ASF parafiscal charge increase

ASF parafiscal charge will increase on 1 January 2026.

1January 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

Announcement that the Portuguese State Budget will amend the PIT breaks.

1 January 2026

  • Draft of the Portuguese State Budget submitted for discussion 10 October. Some changes in the PIT annual breaks and potentially also on the annual tax rates are expected. The Budget will be discussed in the “generality” on the 27 and 28 October. The final version of the discussion in “speciality” needs to be closed by 27 November. The final version of the Budget in force on 1 January 2026.

Italy
Insurance Arbitrator (AAS)

New alternative dispute resolution scheme implemented in Italy by IVASS for the insurance sector.
FOS providers in Italy are free to decide whether to join or not.

15 January 2026

  • AAS website has been launched and is active, and the AAS members have been appointed.
  • Utmost entities have joined the scheme.
  • On 8 October IVASS has officially communicated to the industry that the AAS will be operational from 15 Jan 2026, meaning that clients will be able to file complaints with the AAS from that date onwards.
  • Decision to join duly notified to IVASS in July 2025.
  • Utmost is currently in the process of updating all its product literature to reflect the new AAS provisions.

EU
Artificial Intelligence (AI) Act

Majority of provisions in the Act to take effect.

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 simplification Omnibus expected to be published by end 2025 but no overall moratorium on the AI act expected. Public call for evidence on Digital simplification ends 14 October 2025.

EU
Sustainable Finance Disclosure Regime (SFDR) Changes

ESAs propose SFDR changes.

End 2026

  • The European Supervisory Authorities (ESAs) have proposed several changes to the existing SFDR, including a simplified categorisation system.
  • In May, the EC launched a call for evidence on the review of the SFDR. The feedback period closed on 30 May. The
  • European Commission are expected to issue their review of SFDR level 1 in H2 2025.
  • Negotiations on revising the SFDR given as a priority in the programme of the Danish Council Presidency.

EU
Retail Investment Strategy (RIS)

Retail Investment Strategy PRIIPs and IDD changes.

2027

  • 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.

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.

UK
UK PRIIPs Revocation and Replacement Disclosure Regime

Consultation Paper on new disclosure regime to replace UK PRIIPs published 19 December 2024. Second Consultation Paper CP25/9 released covering cost information and complaints handling.

2025

  • FCA consultation document on a new consumer disclosure regime released with draft rules.
  • Term ‘PRIIP’ being replaced with ‘consumer composite investments’.
  • Proposal to replace PRIIPS KID and UCITS KIID with a product summary.
  • FCA also consumer testing their proposals.
  • The existing exemption for UK UCITS Funds in providing a UK PRIIPs document expires in 2027.
  • Proposed rules on complaints handing for unauthorised manufacturers and distributors of CCI’s.
  • Policy statement with final rules expected late 2025.

UK
Regulatory regime for ESG ratings providers

HM Treasury currently finalising the scope of the regime.

2025

  • Regime expected to improve transparency and quality of ESG ratings for investments and other types of financial products.
  • Treasury published consultation response November 2024.
  • FCA voluntary survey of ESG ratings providers closed on 16 May 2025. Results will shape future regulatory regime.

UK
Targeted Support regime

New regime to enable authorised firms to provide more support to customers and help fill advice gap

2025

  • Part of the wider advice guidance boundary review by FCA.
  • Not individualised advice but a ready-made suggestion for a consumer segment.
  • Consultation paper CP25/17 closed 29 August 2025. Policy Statement with final rules expected end 2025.
  • Gateway for firms to apply for targeted support permissions to open in March 2026. Pre Application Support Services already opened.

UK
Treasury has announced that the UK Autumn Budget will be on Wednesday 26 November 2025

Changes to UK taxation.

26 November 2025

  • The Government need to make changes to plug the fiscal gap with estimations ranging between £17bn and £50bn

UK
Possible simplification of SDR requirements

FCA considering simplification of Sustainability Disclosure Requirements.

2025/26

  • FCA published findings of multi-firm review of climate reporting in line with TCFD recommendations on 6 August
  • In light of their findings, FCA are considering simplifying disclosure rules.
  • Will focus on aspects including decision-usefulness, improving good outcomes for consumers, reducing greenwashing, easing unnecessary burdens on firms and reducing greenwashing.

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 lift ban on retail clients accessing crypto Exchange Traded Notes.

2026

  • 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 CP25/25 on Application of FCA Handbook for Regulated Cryptoasset Activities published with deadline for response 12 November 2025 (15 October for chapters 6 & 7).
  • From 8 October 2025 Crypto ETNs now available to retail clients where they are admitted to trading on a UK
  • Recognised Investment Exchange. Financial promotion rules will apply and there is no access to the FSCS for these products.

UK
IHT on unused pensions savings

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.

Norway
Proposal for a revision of tax rules applicable to corporate policyholders

If passed, will impact corporate clients holding policies as gains from shares within the policy will no longer be tax exempt at withdrawal.

1 January 2026

  • The proposal from the Ministry of Finance is looking at abolishing the tax exemption method currently applicable to the share portion of the policy. This only impacts corporate clients.
  • The changes are suggested to apply retroactively, as per 30 January 2025.
  • The consultation for the proposal closed on 30 April 2025.
  • The Ministry of Finance is now reviewing and revising its proposal; no timeline has been provided.

Malaysia
Guideline related to Income Tax
(Exemption) (No. 6) Order 2022 (Amendment) Order 2024

Clarified tax treatment for foreign income.

June 2024

  • Foreign income received in Malaysia by residents will be taxable, with certain exemptions for foreign dividend income and other specified conditions.
  • Detailed guidelines issued for the tax treatment of foreign income received in Malaysia, including exemptions and record-keeping requirements.

Taiwan
CFC Reporting for Offshore Trusts

Tightened tax rules for offshore trusts held by Taiwanese residents.

July 2024

  • New ruling issued by the Ministry of Finance supplementing the CFC ruling in January 2024 that imposes Alternative Minimum Tax (AMT) on the settlor/beneficiaries of offshore trusts when CFC is involved.
  • Offshore trustees must register with Taiwan tax authorities, prepare accounts and detailed income and distribution statements for all trust assets. Trustees without a presence in Taiwan must appoint a local agent.

Hong Kong
Proposed Company Re-domiciliation Regime

New regime to allow foreign companies to change their place of incorporation to Hong Kong.

July 2024

  • Streamlined process for businesses to re-domicile to Hong Kong.
  • Applies to foreign companies of different types and scales.
  • A comprehensive regime follows the fund re-domiciliation regime implemented in November 2021 which established a simplified fund re-domiciliation regime for Open-Ended Fund Companies and Limited Partnership Funds.

China
Enforcement of Six-Year Rule

Taxation on global income for long-term foreign residents.

December 2024

  • Six-Year Rule introduced from January 2019. 2024 marks the first year that this rule is applicable.
  • Foreigners residing in China for more than 183 days per year for six consecutive years will be taxed on their global income. The six-year period can be reset by leaving China for more than 30 consecutive days.

Malaysia
Extended exemption for foreign-sourced income

Exemption period extended to 2036.

January 2025

  • 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 Fund

Extension and revision of tax schemes.

January 2025

  • 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.

Taiwan
MOF Update to Individual CFC Regime Q&A

Clarified CFC treatment of PPLI.

April 2025

  • 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

  • Amendment Ordinance gazetted 23 May 2025.
  • Prospective application. 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

  • Ongoing measurement of the Capital Investment Entrant Scheme (CIES) and Family-owned Investment Holding Vehicles (FIHVs) introduced in March 2024.

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

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

2025>2026

  • 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.

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

Comprehensive taxation on foreign income.

2025>2026

  • Further revision of 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.

Regulation, Tax and Compliance

Crypto Transparency Is Coming:CRS 2.0, CARF and Your Clients

Marie Hainge
Technical Services Legal and Regulatory Adviser

The crypto-asset landscape has evolved from a niche asset class to a relatively mainstream investment, but regulatory and reporting frameworks have struggled to keep pace. Facing a potential loss of tax revenues, as well as market and customer risks, regulators and organisations are introducing new frameworks to counter these risks and modernise tax compliance.

In this article, Marie Hainge, Technical Services Legal and Regulatory Adviser, considers the rise in crypto-assets for investors, outlines the key reporting changes, and discusses the possible implications for clients who hold an interest in these assets.

Read the article

UK First Tier Tribunal Confirms Expatriate Pension Not Taxable in UK

Brendan Harper
Head of Asia and HNW Technical Services

A recent decision by the UK First Tier Tribunal has confirmed that an expatriate pension is not taxable in the UK. This is welcome news to many UK pension holders who have retired abroad to favourable tax jurisdictions.

In this article, Brendan Harper, Head of Asia and HNW Technical Services, explains the implications of the decision and how it also revealed a potential trap for the unwary.

Read the article

U.S. Estate Tax for Non-Resident Aliens: Key Facts and Planning Opportunities

Peter Tung
Tax and Legal Counsel – Asia

With U.S. Estate Tax rules offering vastly different exemptions for citizens and non-resident aliens, Asian families with even modest U.S. investments may face unexpected tax exposure.

Peter Tung, Tax and Legal Counsel – Asia, highlights how Asian families can be caught by the US$60,000 U.S. Estate Tax allowance and sets out practical steps advisers can take to plan ahead.

Read the article

Technical Spotlight

Controlled Distribution

Brendan Harper
Head of Asia and HNW Technical Services

Using Insurance for Controlled Distribution

Controlled distribution is an important objective in estate planning, particularly for high-net-worth individuals seeking to ensure that wealth is passed on in a structured, secure and tax-efficient manner. Insurance-based wealth solutions offer a powerful and flexible way to achieve this.

In this article, Brendan Harper, Head of Asia and HNW Technical Services, explains how insurance contracts, used alone or in combination with trust structures, can support advisers in delivering controlled distribution strategies tailored to complex family needs.

Read the article

Ester Carbonell van Reck
Senior Wealth Planner – 
Spain and LatAm

Controlled Wealth Succession in Spain with Unit-Linked Life Insurance

Unit‑linked life insurance contracts can be a powerful instrument for estate planning in Spain. When a policy includes special conditions, for example, staggered access to the insurance benefits or deferred termination, families can time and control the transfer of wealth to future generations in a controlled manner.

In this article Ester Carbonell van Reck, Senior Wealth Planner – Spain and LatAmexplains how with thoughtful structuring, they provide a clear, legally sound and tax efficient path to preserve family wealth and values across generations in Spain.

Read the article

Nicolaas Vancrombrugge
Senior Wealth Planner – Belgium and Luxembourg

How Life Insurance Can Simplify Controlled Inheritance Planning in Belgium and Luxembourg

Controlled distribution after death is a common requirement in succession planning for Belgian and Luxembourg residents. While many opt for complex and costly structures, they often overlook the effective and straightforward tools available under local insurance law. In particular, the post-mortem agreement, which enables the transfer of rights under a life insurance contract after the policyholder’s death, and the accepting (irrevocable) beneficiary clause offer powerful options for orderly succession planning.

In this article, Nicolaas Vancrombrugge, Senior Wealth Planner – Belgium and Luxembourg, explains how an insurance-based wealth solution can be used to support controlled distribution strategies, offering a simpler and more cost-effective alternative to traditional structures.

Read the article

Country Focus

UK: Pensions and IHT – What Advisers Need to Do Before 6 April 2027

Glenn McIIroy
Technical Services Manager

From April 2027, unused pension funds will, for the first time, fall within the scope of UK inheritance tax (IHT). For many clients, this could mean an unexpected rise in their taxable estate and a smaller inheritance for their beneficiaries.

For advisers, that’s a challenge, and an opportunity. Glenn McIIroy, Utmost Technical Manager, explains how advisers can rebalance drawdown strategies, use life cover in trust, gift from income, and deploy an international insurance-based solution so clients can fund retirement confidently while keeping more wealth in the family.

Read the article

France: Mitigating French Exit Tax: The Role of Life Insurance in International Mobility

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

For internationally mobile clients, leaving France can trigger taxation of unrealised gains and a web of reporting obligations – often at precisely the moment they need flexibility.

Benjamin Fiorino, Wealth Planner, France, explains how structuring investments within a unit-linked life insurance contract from the outset can notably reduce exposure to Exit Tax and keep long-term planning on track.

 

Read the article

Case Study Insights

Simon Martin
Head of UK Technical Services

Anticipating the UK Autumn Budget: Using A Lifestyle Trust to Balance Access and IHT Planning

Simon Martin, Head of UK Technical Services, shows how a UK national and long-term resident can prepare for possible Autumn Budget changes to inheritance tax (IHT).

By using a reversionary interest (lifestyle) trust, clients can retain access to capital, support family gifting in a controlled manner, and move future growth outside the estate.

Read the Case Study

Ester Carbonell van Reck
Senior Wealth Planner – 
Spain and LatAm

A Spanish Grandmother’s Legacy: Deferred Inheritance Through Life Insurance

Ester Carbonell van Reck, Senior Wealth Planner – Spain and LatAm, outlines how a mixed-term life insurance policy can be used to support deferred succession planning for a high-net-worth client in Spain.

The structure would allow the client to retain access to capital during her lifetime, while ensuring a controlled and tax-efficient transfer of wealth to her grandchildren under specific conditions.

Read the Case Study

Nicolaas Vancrombrugge
Senior Wealth Planner – Belgium and Luxembourg

Using A Post-Mortem Clause to Support Family Succession Goals in Belgium

In this case study, Nicolaas Vancrombrugge, Senior Wealth Planner – Belgium and Luxembourg, demonstrates how a post-mortem clause within a life insurance contract could be used to support succession planning for a Belgian client with a blended family.

The structure would allow the policyholder to retain control over asset distribution during their lifetime, while enabling a gradual and protected transfer of wealth to the next generation under clearly defined conditions.

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

Hong Kong

Hubbis Wealth Planning and Structuring Forum

22 October 2025

Find out more

Hong Kong

Three Weeks to UK Budget Day: IFS insights on tax, spending and the state of the economy.

Join Marc Acheson, Global Wealth Specialist at Utmost Wealth Solutions and Ben Zaranko, Associate Director at the Institute for Fiscal Studies (IFS), just 3 weeks out from the UK budget as we hear from the IFS on the current state of the economy, what that means for any Fiscal headroom the UK government needs and to discuss likely tax and/or spending changes we may see.

24th November 2025, 9.30am GMT

Find out more

Italy (Milan)

Annual Associazione Italiana Private Banking (AIPB) Private Banking Forum 2025

5 November 2025

Find out more

Hong Kong

STEP Asia Conference

6-7 November 2025

Find out more

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To contact the team, simply get in touch via the Ask Us Anything form below.

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